table of contents list of issue, by party, by witness 6 table i-2 | summary of operations and...

Application No A.19-08-013

Exhibit No. SCE-54

2021 General Rate Case

Joint Comparison Exhibit

Before the

Public Utilities Commission of the State of California

Rosemead, CA

August 2020

Table of ContentsList of Issue, By Party, By Witness 6

Table I-2 | Summary of Operations and Maintenance-Related Issues 22

Table I-3 | Summary of Capital Expenditure Related Issues 39

Table I-4 | Summary of Rate Base Related Issues 47

Chapter 1 | Issues Where Parties Agree To Revisions

SCE-001 | SCE Agrees to Intervenors

51

Chapter 2 | Ratemaking and Company-Wide-Related Issues 74

52

TURN-115 | Other Recommendations for Decommissioning Analysis 75

TURN-116 | Recovery of Infrastructure Costs Replaced by Wildfire Mitigation-Driven Activities 76

TURN-117 | Recovery of Net Book Value of Aged Pole Replacements 77

TURN-119 | Renewed Requests for Project Funding 78

TURN-120 | Establishment of the Wildfire Risk Mitigation Balancing Account (WRMBA) 79

PAO-124 | Establishment of a Property Tax Memorandum Account 80

PAO-125 | Establishment of an Aerial Inspections Memorandum Account 81

TURN-127 | TURN's Proposed Changes to the Gross Revenue Sharing Mechanism (GRSM) and SCE's Non-tariffed Products and Services (NTP&S) Offerings

82

EPUC-128 | Change to Capital-Related Added Facilities Rates 83

CUE-129 | Distribution Infrastructure Replacement 84

PAO-130 | Financial Examination Recommendation - Technology Assessment 85

PAO-131 | Financial Examination Recommendation - Grid Modernization – Transmission and Distribution (T&D) Deployment Readiness

86

PAO-132 | PAO Recommendations on Risk Informed Strategy and Business Plan 87

TURN-133 | TURN Recommendations on Risk Informed Strategy and Business Plan-1 88


SBUA-135 | SBUA Companywide Issue #1 90



SBUA-138 | SBUA Companywide Issue #4 and #5 93





TURN-146 | Affordability 98

TURN-147 | Relationship Between Rate Increases and Customer Disconnections and Arrearages 99

NDC-148 | Consumer Affairs Complaints and Inquiry Tracking 100

PAO-149 | COVID-19 Capital Expenditure Adjustment 1011

Table of Contents

Chapter 3 | Summary Of Differences

Section 1 | SCE-02 Operations and Maintenance-Related Issues

Section 2 | SCE-02 Capital Expenditure-Related Issues

115

116

131



PAO-158 | Adjustment to O&M Work Order Related Expense 104


PAO-CUE-123 | Modification of the Safety and Reliability Investment Incentive Mechanism (SRIIM) 109

PAO-TURN-121 | Establishment of the Vegetation Management Balancing Account (VMBA) 107

PAO-TURN-122 | Establishment of the Risk Management Balancing Account (RMBA) 108

PAO-TURN-154 | Interest on Customer Deposits 110

PAO-TURN-165 | 2019 Recorded Capital Expenditures 111

PAO-TURN166 | Renewed Requests for Project Funding - Grid Modernization 112

PAO-TURN-91 | Proposed Acceleration of Recovery of Previously Authorized (Capitalized) Wildfire Liability Insurance 106

PAO-TURN-134 | Post-Test Year Ratemaking (PTYR) - Primary (Illustrative Impacts) 114

PAO-TURN-160 | Post-Test Year Ratemaking (PTYR) - Alternative (Illustrative Impacts) 115

PAO-48 | Alternative forecast for Distribution Overhead Detailed Inspections 117

PAO-49 | Distribution Preventive and Breakdown O&M Maintenance 118

PAO-51 | IT Project Support O&M 119

PAO-54 | Load Side Support O&M 120

PAO-56 | Monitoring Bulk Power System - Grid Control Center 121

PAO-63 | Technology Assessment O&M 122

PAO-64 | Inspections & Maintenance 123




PAO-143 | Grid Network Solutions 127

PAO-TURN-68 | Vegetation Management SB 247 128

PAO-13 | Distribution Preventive and Breakdown Capital Maintenance 132

TURN-15 | Automation Capital Forecast 133

PAO-20 | Distribution Transformers Capital Forecast 134

PAO-26 | Meter Engineering Routine Work 135

PAO-28 | Distribution Pole Loading Program (PLP) Prefabrication 136

PAO-TURN-50 | Vegetation Management 129

2

Table of Contents





165

148

167

177

TURN-30 | Residential New Service Connections Forecast 137

PAO-31 | Aerial Inspection Maintenance Forecast Methodology 138

PAO-33 | Joint Pole Credits 139

PAO-34 | Pole Capital Expenditures 140

PAO-145 | Rule 20A Conversion 143

PAO-TURN-21 | Engineering and Planning Software Tools Capital Forecast 144

PAO-TURN-23 | Grid Management System (GMS) Capital Forecast 146

PAO-57 | Postage 149

TURN-76 | Uncollectible Expense Factor Adjustment for the Disconnection OIR Requirement 150

TURN-78 | Customer Experience Management 151

TURN-79 | Customer Programs Management 152

TURN-80 | Digital Operations and Management 154

PAO-TURN-41 | Billing 155

PAO-TURN-42 | Business Account Management 157

PAO-TURN-43 | Hydraulic Services is Properly Funded in the GRC 159

TURN-NDC-44 | Credit and Payment 160

PAO-TURN-61 | Service Guarantee Program 161

PAO-TURN-69 | Transportation Electrification 162

PAO-TURN-NDC-45 | Customer Communications, Education and Outreach: AIM Initiative & Other 163

PAO-46 | Cybersecurity O&M 168

PAO-82 | Wildfire EOI O&M 169

PAO-83 | Wildfire Organizational Change Management O&M 170

TURN-84 | Distribution Fault Anticipation O&M 171

PAO-85 | Community Resiliency Incentives 172

PAO-86 | Business Continuation O&M 173

PAO-87 | Enhanced Situational Awareness 174

PAO-88 | Fire Science and Advanced Modeling 175

PAO-90 | Security Technology Operations & Maintenance 176

3

Table of Contents





191

194

200

219

PAO-18 | Cybersecurity Capital 178

TURN-19 | Distribution Fault Anticipation 180

TURN-22 | Vertical Switches 181

PAO-24 | Grid Mod Cybersecurity Capital 182

PAO-29 | Protection of Grid Infrastructure 183

PAO-TURN-14 | Business Continuation Capital 186

PAO-TURN-CUE-35 | Wildfire Covered Conductor Program 190

TURN-70 | Palo Verde 192

PAO-TURN-16 | Planned Replacement of Catalina Diesel Generation Plants 195

PAO-TURN-25 | Hydro Decommissioning Capital for San Gorgonio 197

PAO-TURN-27 | Removal of the Mountainview Rotor Replacement Capital Project 199

PAO-39 | Accounting, Financial Compliance, and Financial Reporting 201

PAO-40 | Audits 202

PAO-47 | Rebuttal Policy, External Engagement and Ratemaking 203

PAO-53 | Non-Wildfire 204

PAO-58 | EEI Membership Dues 205

PAO-59 | Property 206

PAO-60 | Recognition 207

PAO-62 | Software Maintenance and Replacement O&M 208

TURN-81 | Executive Compensation 209

PAO-89 | Fixed Price Technology and Maintenance O&M 211

NDC-92 | Supplier Diversity 212

PAO-TURN-52 | Wildfire 213

PAO-TURN-55 | Long-Term Incentive (LTI) Program 214

PAO-TURN-74 | Executive Benefits 216

PAO-TURN-75 | Short-Term Incentive Compensation Program 217

TURN-17 | Infrastructure Upgrade - Blythe 220

TURN-157 | Facility and Land Operations Capital Expenditures - Substation Reliability Upgrade 221

TURN-161 | Infrastructure Upgrade - Santa Barbara 2234

Table of Contents



Section 13 | SCE-07 Rate Base, Depreciation and Tax-Related Issues

Section 14 | Summary Of Differences Related to Other Issues

PAO-199 | Differences related to Other Issues 254

Appendix A | Settlements

Appendix B | SCE and Cal Advocates CPUC Comparison Reports

257

261

226

228

230

253

TURN-162 | Infrastructure Upgrade - T&D Training Center 224

TURN-163 | Infrastructure Upgrade - Vehicle Maintenance 225

PAO-93 | Fuel and Purchased Power 231

PAO-94 | Wildfire Insurance Premiums 232

TURN-95 | Goods and Services 233

TURN-96 | Depreciation Expense 234

TURN-97 | Synchronized Interest Adjustment 235

TURN-98 | Taxes Based on Income 236

TURN-99 | Materials and Supplies 237

PAO-TURN-100 | Customer Deposits 238

TURN-101 | T&D Service Lives - Account 352 (Transmission Structures and Improvements) 239

TURN-102 | T&D Service Lives - Account 354 (Transmission Towers and Fixtures) 240

TURN-103 | T&D Service Lives - Account 356 (Transmission OH Conductor) 241

TURN-104 | T&D Service Lives - Account 361 (Distribution Structures and Improvements) 242

TURN-105 | T&D Service Lives - Account 362 (Distribution Station Equipment) 243

TURN-106 | T&D Service Lives - Account 366 (Distribution UG Conduit) 244

TURN-107 | T&D Service Lives - Account 369 (Services) 245

TURN-108 | T&D Service Lives - Account 370 (Meters) 246

TURN-111 | Escalation in Generation Decommissioning Estimates 247

TURN-112 | Recovery of Perris Solar Decommissioning and Unrecovered Original Investment 248

TURN-113 | Palo Verde Interim Retirement Rate 249

TURN-114 | Recovery of Fuel Cell Decommissioning 250

PAO-TURN-109 | T&D Net Salvage 251

PAO-TURN-110 | Hydro Decommissioning 252

5


List Of Issues, By Party, By Witness

6

List of Issues, By Witness

SCE Page

Anderson, Brandi




SCE-001 | SCE Agrees to Intervenors 52




Baltaji, Abdallah


Bennett, Mark





Benoliel, Alex


Bernaudo, David


Boucher, Timothy




Cabbell, Dana






Champ, Tom


Childs, Mark

7

List of Issues, By WitnessSCE-001 | SCE Agrees to Intervenors 73


Condit, Timothy









Daigler, Donald





Fielder, Brent



Frierson, Tarrance


Garcia, Kelly



Gardner, Kari


Garris, Lori



Gueorguiev, Ilia


86



List of Issues, By WitnessGunn, David











Haddox, Glenn

PAO-18 | Cybersecurity Capital 178



Janney, John


Jiang, Jim



Jiang, Josh


Jocelyn, Melanie



Joseph, Paul








Lee, David 9

List of Issues, By WitnessPAO-124 | Establishment of a Property Tax Memorandum Account 80

LeMoine, Robert







Li, April


PAO-TURN-91 | Proposed Acceleration of Recovery of Previously Authorized (Capitalized) Wildfire Liability Insurance

106



Lim, Jessica





Neal, Don






Ochoa , Alfred


Ohanian, Terry







List of Issues, By WitnessPayne, Kevin


Prescott, Carter


Reeves, Tracee


Roy, Rajdeep




Rumble, Jonathan



Sheng, Hongyan


Smith, Aaron



Smith, Jennifer



Snow, Douglas

PAO-TURN-165 | 2019 Recorded Capital Expenditures 111





Stern, Gary

PAO-47 | Rebuttal Policy, External Engagement and Ratemaking 203


Swenerton, Lisa


82

Swisher, Andrew11

List of Issues, By WitnessTURN-19 | Distribution Fault Anticipation 180



Thomas, Robert



Thompson, Chris


Tran, Joanne

PAO-40 | Audits 202

Tran, Sarah




TURN-96 | Depreciation Expense 234



Trapp, Jacqueline



Trehan, Vik


Trumbo, Gary








Tucker, Robert


Varvis, Alan

12

List of Issues, By WitnessTURN-116 | Recovery of Infrastructure Costs Replaced by Wildfire Mitigation-Driven Activities 76

White, Randall


White, Ronald







Wong, Desiree




PAO Page

Burns, Truman


Godfrey, Tamera














Hadiprodjo Nawaz, Chia

PAO-40 | Audits 202

13

List of Issues, By WitnessPAO-47 | Rebuttal Policy, External Engagement and Ratemaking 203


Hadiprodjo, Fransiska



86

Hunter, Stacey





Lasko, Yakov




Leon Diaz, Fidel A






Lin, Jerry



Li, Pui-Wa



Loethen, Lindsay


Logan, Scott






Oh, Jerry

PAO-124 | Establishment of a Property Tax Memorandum Account 80


Phan, Dao










Roberts, Thomas





Waterworth, Mark










106



Weaver, Monica


List of Issues, By WitnessPAO-18 | Cybersecurity Capital 178











Wilson, Greg












TURN Page

Borden, Eric





TURN-116 | Recovery of Infrastructure Costs Replaced by Wildfire Mitigation-Driven Activities 76




16

List of Issues, By WitnessTURN-159 | TURN Recommendations on Risk Informed Strategy and Business Plan-4 105

TURN-19 | Distribution Fault Anticipation 180




Cheng, David










82






Defever, John







Dowdell, Jennifer






17

List of Issues, By WitnessTURN-96 | Depreciation Expense 234



Finkelstein, Robert





106


Garrett, David










Jones, Garrick









Marcus, William



















Sugar, John


Marcus, William / Robert Finkelstein


CUE Page

Earle, Robert




EPUC Page

Brubaker, Maurice


NDC Page

Bautista, Faith






List of Issues, By Witness

SBUA Page

J Moss, Steven / Richard McCann









20


Summary Of Operation and Maintenance Issues

21

SOUTHERN CALIFORNIA EDISON2021 GENERAL RATE CASE APPLICATION (A.19-08-013)Table I-2 | Summary of Operations and Maintenance-Related Issues, By Exhibit (Total Company)

2018$ in Thousands

Differences, By Exhibit (Total Company) 2021 Test Year

Activity Issue Description Issue Number 2018$ in ThousandsExhibit

PAO-66Inspections & Maintenance SCETransmission Line Rating Remediation (TLRR)

SCE-02

PAO

PAO Difference

TURN

TURN Difference

959

(831)

N/A

N/A

1,790

125

See Page

PAO-TURN-68Vegetation Management SB 247 SCEWildfire Vegetation ManagementSCE-02

PAO

PAO Difference

TURN

TURN Difference

TBD

TBD

TBD

TBD

20,937

128

See Page

PAO-TURN-50Vegetation Management SCEWildfire Vegetation ManagementSCE-02

PAO

PAO Difference

TURN

TURN Difference

25,052

(31,136)

20,738

(35,450)

56,188

129

See Page

PAO-TURN-68Vegetation Management SB 247 SCETransmission Routine Vegetation Management

SCE-02

PAO

PAO Difference

TURN

TURN Difference

TBD

TBD

TBD

TBD

2,927

128

See Page

PAO-67Inspections & Maintenance SCETransmission O&M MaintenanceSCE-02

PAO

PAO Difference

TURN

TURN Difference

12,208

(8,856)

N/A

N/A

21,064

126

See Page

Southern California Edison 22


2018$ in Thousands



PAO-65Inspections & Maintenance SCETransmission Line PatrolsSCE-02

PAO

PAO Difference

TURN

TURN Difference

5,330

(1,893)

N/A

N/A

7,223

124

See Page

PAO-64Inspections & Maintenance SCETelecommunication Inspection and Maintenance

SCE-02

PAO

PAO Difference

TURN

TURN Difference

2,419

(2,455)

N/A

N/A

4,874

123

See Page

PAO-63Technology Assessment O&M SCETechnology AssessmentSCE-02

PAO

PAO Difference

TURN

TURN Difference

8,657

(724)

N/A

N/A

9,381

122

See Page

PAO-56Monitoring Bulk Power System - Grid Control Center

SCEMonitoring Bulk Power SystemSCE-02

PAO

PAO Difference

TURN

TURN Difference

9,339

(726)

N/A

N/A

10,065

121

See Page

PAO-TURN-68Vegetation Management SB 247 SCEDead, Dying and Diseased Tree RemovalSCE-02

PAO

PAO Difference

TURN

TURN Difference

TBD

TBD

TBD

TBD

10,439

128

See Page



2018$ in Thousands



PAO-TURN-50Vegetation Management SCETransmission Routine Vegetation Management

SCE-02

PAO

PAO Difference

TURN

TURN Difference

12,760

0

N/A

N/A

12,760

129

See Page

PAO-TURN-50Vegetation Management SCEDead, Dying and Diseased Tree RemovalSCE-02

PAO

PAO Difference

TURN

TURN Difference

35,120

0

N/A

N/A

35,120

129

See Page

PAO-143Grid Network Solutions SCEMonitoring Bulk Power SystemSCE-02

PAO

PAO Difference

TURN

TURN Difference

35,767

(9,086)

N/A

N/A

44,853

127

See Page

PAO-48Alternative forecast for Distribution Overhead Detailed

Inspections

SCEDistribution Overhead Detail Inspections

SCE-02

PAO

PAO Difference

TURN

TURN Difference

6,550

1,676

N/A

N/A

4,875

117

See Page

PAO-49Distribution Preventive and Breakdown O&M Maintenance

SCEDistribution Preventive and Breakdown O&M Maintenance

SCE-02

PAO

PAO Difference

TURN

TURN Difference

98,724

(8,515)

N/A

N/A

107,239

118

See Page



2018$ in Thousands



PAO-TURN-50Vegetation Management SCEDistribution Routine Vegetation Management

SCE-02

PAO

PAO Difference

TURN

TURN Difference

103,257

(3,755)

N/A

N/A

107,012

129

See Page

PAO-TURN-68Vegetation Management SB 247 SCEDistribution Routine Vegetation Management

SCE-02

PAO

PAO Difference

TURN

TURN Difference

TBD

TBD

TBD

TBD

71,191

128

See Page

PAO-51IT Project Support O&M SCEIT Project SupportSCE-02

PAO

PAO Difference

TURN

TURN Difference

2,473

(2,104)

N/A

N/A

4,577

119

See Page

PAO-54Load Side Support O&M SCELoad Side SupportSCE-02

PAO

PAO Difference

TURN

TURN Difference

172

(205)

N/A

N/A

377

120

See Page

TURN-78Customer Experience SCECustomer Experience ManagementSCE-03

PAO

PAO Difference

TURN

TURN Difference

N/A

N/A

N/A

N/A

7,398

151

See Page



2018$ in Thousands



TURN-76Uncollectible Expense Factor Adjustment for the Disconnection

OIR Requirement

SCEUncollectible ExpensesSCE-03

PAO

PAO Difference

TURN

TURN Difference

N/A

N/A

N/A

N/A

15,907

150

See Page

PAO-TURN-42Business Account Management SCEBusiness Account ManagementSCE-03

PAO

PAO Difference

TURN

TURN Difference

14,136

(5,542)

N/A

N/A

19,678

157

See Page

PAO-TURN-43Hydraulic Services is Properly Funded in the GRC

SCEBusiness Account Management ServicesSCE-03

PAO

PAO Difference

TURN

TURN Difference

3,858

(1,151)

N/A

N/A

5,009

159

See Page

PAO-TURN-NDC-45

Customer Communications, Education and Outreach: AIM

Initiative & Other

SCECustomer Communications, Education and Outreach

SCE-03

PAO

PAO Difference

TURN

TURN DifferenceNDC

NDC Difference

3,993

(5,200)

N/A

N/A9,193

0

9,193

163

See Page

TURN-79Customer Programs Management SCECustomer Programs ManagementSCE-03

PAO

PAO Difference

TURN

TURN Difference

N/A

N/A

N/A

N/A

13,832

152

See Page



2018$ in Thousands



TURN-80Digital Operations and Management

SCEDigital Operations and ManagementSCE-03

PAO

PAO Difference

TURN

TURN Difference

N/A

N/A

N/A

N/A

2,603

154

See Page

PAO-57Postage SCEPostageSCE-03

PAO

PAO Difference

TURN

TURN Difference

13,407

(222)

N/A

N/A

13,629

149

See Page

PAO-TURN-61Service Guarantee Program SCEService Guarantee ProgramSCE-03

PAO

PAO Difference

TURN

TURN Difference

0

985

N/A

N/A

(985)

161

See Page

PAO-TURN-69Transportation Electrification SCETransportation ElectrificationSCE-03

PAO

PAO Difference

TURN

TURN Difference

0

(3,566)

N/A

N/A

3,566

162

See Page

PAO-TURN-41Billing SCEBillingSCE-03

PAO

PAO Difference

TURN

TURN Difference

32,602

(4,833)

N/A

N/A

37,435

155

See Page



2018$ in Thousands



TURN-NDC-44Credit and Payment SCECredit and PaymentSCE-03

PAO

PAO Difference

TURN

TURN DifferenceNDC

NDC Difference

N/A

N/A

N/A

N/A0

(637)

637

160

See Page

PAO-90Security Technology Operations & Maintenance

SCESecurity Technology Operations and Maintenance

SCE-04

PAO

PAO Difference

TURN

TURN Difference

16,662

(524)

N/A

N/A

17,186

176

See Page

PAO-86Business Continuation O&M SCEAll Hazards Assessment, Mitigation and Analytics

SCE-04

PAO

PAO Difference

TURN

TURN Difference

3,779

(204)

N/A

N/A

3,983

173

See Page

PAO-46Cybersecurity O&M SCECybersecurity Delivery and IT Compliance

SCE-04

PAO

PAO Difference

TURN

TURN Difference

20,928

(11,304)

N/A

N/A

32,232

168

See Page

TURN-84Distribution Fault Anticipation O&M

SCEDistribution Fault AnticipationSCE-04

PAO

PAO Difference

TURN

TURN Difference

N/A

N/A

N/A

N/A

68

171

See Page



2018$ in Thousands



PAO-82Wildfire EOI O&M SCEEnhanced Overhead Inspections and Remediations

SCE-04

PAO

PAO Difference

TURN

TURN Difference

14,225

(40,006)

N/A

N/A

54,232

169

See Page

PAO-87Enhanced Situational Awareness SCEEnhanced Situational AwarenessSCE-04

PAO

PAO Difference

TURN

TURN Difference

3,060

(534)

N/A

N/A

3,594

174

See Page

PAO-88Fire Science and Advanced Modeling

SCEFire Science and Advanced ModelingSCE-04

PAO

PAO Difference

TURN

TURN Difference

2,204

(1,744)

N/A

N/A

3,948

175

See Page

PAO-83Wildfire Organizational Change Management O&M

SCEOrganizational SupportSCE-04

PAO

PAO Difference

TURN

TURN Difference

0

(3,354)

N/A

N/A

3,354

170

See Page

PAO-85Community Resiliency Incentives SCECommunity Resiliency IncentivesSCE-04

PAO

PAO Difference

TURN

TURN Difference

1,150

(2,300)

N/A

N/A

3,450

172

See Page



2018$ in Thousands



TURN-70Palo Verde SCEPalo VerdeSCE-05

PAO

PAO Difference

TURN

TURN Difference

N/A

N/A

N/A

N/A

73,096

192

See Page

TURN-81Executive Compensation SCEExecutive CompensationSCE-06

PAO

PAO Difference

TURN

TURN Difference

N/A

N/A

N/A

N/A

18,128

209

See Page

PAO-89Fixed Price Technology and Maintenance O&M

SCEFixed Price Technology and Maintenance

SCE-06

PAO

PAO Difference

TURN

TURN Difference

71,586

(5,046)

N/A

N/A

76,632

211

See Page

PAO-199Differences related to Other Issues SCEFranchise FeesSCE-06

PAO

PAO Difference

TURN

TURN Difference

74,574

(7,265)

N/A

N/A

81,840

254

See Page

PAO-199Differences related to Other Issues SCEGroup Life InsuranceSCE-06

PAO

PAO Difference

TURN

TURN Difference

1,263

(86)

N/A

N/A

1,349

254

See Page



2018$ in Thousands



PAO-TURN-74Executive Benefits SCEExecutive Benefits (Service)SCE-06

PAO

PAO Difference

TURN

TURN Difference

1,610

(1,814)

N/A

N/A

3,423

216

See Page

NDC-92Supplier Diversity SCESupplier Diversity and DevelopmentSCE-06

PAO

PAO Difference

TURN

TURN DifferenceNDC

NDC Difference

N/A

N/A

N/A

N/A3,240

(182)

3,422

212

See Page

PAO-199Differences related to Other Issues SCEDental PlansSCE-06

PAO

PAO Difference

TURN

TURN Difference

12,266

(837)

N/A

N/A

13,103

254

See Page

PAO-199Differences related to Other Issues SCEUncollectible ExpensesSCE-06

PAO

PAO Difference

TURN

TURN Difference

15,402

(505)

N/A

N/A

15,907

254

See Page

PAO-199Differences related to Other Issues SCEExecutive Benefits (Service)SCE-06

PAO

PAO Difference

TURN

TURN Difference

(7)

(7)

N/A

N/A

0

254

See Page



2018$ in Thousands



PAO-TURN-74Executive Benefits SCEExecutive Benefits (Non-Service)SCE-06

PAO

PAO Difference

TURN

TURN Difference

5,895

(6,642)

N/A

N/A

12,537

216

See Page

PAO-199Differences related to Other Issues SCEExecutive Benefits (Non-Service)SCE-06

PAO

PAO Difference

TURN

TURN Difference

(27)

(27)

N/A

N/A

0

254

See Page

PAO-62Software Maintenance and Replacement O&M

SCESoftware Maintenance and Replacement

SCE-06

PAO

PAO Difference

TURN

TURN Difference

85,818

(11,427)

N/A

N/A

97,245

208

See Page

PAO-47Rebuttal Policy, External Engagement and Ratemaking

SCEDevelop and Manage Policy and Initiatives

SCE-06

PAO

PAO Difference

TURN

TURN Difference

859

(89)

N/A

N/A

948

203

See Page

PAO-59Property SCEProperty InsuranceSCE-06

PAO

PAO Difference

TURN

TURN Difference

19,234

(1,228)

N/A

N/A

20,462

206

See Page



2018$ in Thousands



PAO-199Differences related to Other Issues SCECapitalized P&B ExpenseSCE-06

PAO

PAO Difference

TURN

TURN Difference

(218,839)

8,099

N/A

N/A

(226,938)

254

See Page

PAO-199Differences related to Other Issues SCECapitalized A&G ExpenseSCE-06

PAO

PAO Difference

TURN

TURN Difference

(192,582)

78,282

N/A

N/A

(270,863)

254

See Page

PAO-40Audits SCEAuditsSCE-06

PAO

PAO Difference

TURN

TURN Difference

8,926

(784)

N/A

N/A

9,710

202

See Page

PAO-199Differences related to Other Issues SCEDisability Management - ProgramsSCE-06

PAO

PAO Difference

TURN

TURN Difference

16,485

(1,138)

N/A

N/A

17,623

254

See Page

PAO-199Differences related to Other Issues SCEMedical ProgramsSCE-06

PAO

PAO Difference

TURN

TURN Difference

92,635

(6,319)

N/A

N/A

98,954

254

See Page



2018$ in Thousands



PAO-199Differences related to Other Issues SCEVision Service PlanSCE-06

PAO

PAO Difference

TURN

TURN Difference

2,590

(177)

N/A

N/A

2,766

254

See Page

PAO-199Differences related to Other Issues SCEAdjustment for Shareholder P&B - 926SCE-06

PAO

PAO Difference

TURN

TURN Difference

(692)

70

N/A

N/A

(763)

254

See Page

PAO-199Differences related to Other Issues SCE401K Savings PlanSCE-06

PAO

PAO Difference

TURN

TURN Difference

87,811

(5,765)

N/A

N/A

93,577

254

See Page

PAO-39Accounting, Financial Compliance, and Financial Reporting

SCEAccounting, Financial Compliance and Financial Reporting

SCE-06

PAO

PAO Difference

TURN

TURN Difference

22,165

(2,083)

N/A

N/A

24,248

201

See Page

PAO-199Differences related to Other Issues SCEAdjustment for Shareholder P&B - 925SCE-06

PAO

PAO Difference

TURN

TURN Difference

(2,896)

861

N/A

N/A

(3,757)

254

See Page



2018$ in Thousands



PAO-199Differences related to Other Issues SCEIncome Tax Component of ContributionSCE-06

PAO

PAO Difference

TURN

TURN Difference

26,938

(645)

N/A

N/A

27,583

254

See Page

PAO-TURN-52Wildfire SCELiability Insurance - WildfireSCE-06

PAO

PAO Difference

TURN

TURN Difference

467,853

(155,951)

N/A

N/A

623,804

213

See Page

PAO-199Differences related to Other Issues SCEReduction in A&G For CatalinaSCE-06

PAO

PAO Difference

TURN

TURN Difference

(960)

174

N/A

N/A

(1,134)

254

See Page

PAO-TURN-55Long-Term Incentive (LTI) Program SCELong-term IncentivesSCE-06

PAO

PAO Difference

TURN

TURN Difference

0

(11,602)

N/A

N/A

11,602

214

See Page

PAO-TURN-75Short-Term Incentive Compensation Program

SCEShort-Term Incentive Program - Transmission & Distribution

SCE-06

PAO

PAO Difference

TURN

TURN Difference

26,820

(54,666)

N/A

N/A

81,485

217

See Page



2018$ in Thousands



PAO-199Differences related to Other Issues SCEMiscellaneous Benefit ProgramsSCE-06

PAO

PAO Difference

TURN

TURN Difference

5,825

(397)

N/A

N/A

6,223

254

See Page

PAO-199Differences related to Other Issues SCEParticipant Credits and Charges - 930SCE-06

PAO

PAO Difference

TURN

TURN Difference

11,073

1

N/A

N/A

11,072

254

See Page

PAO-58EEI Membership Dues SCEProfessional Development and Education

SCE-06

PAO

PAO Difference

TURN

TURN Difference

211

(1,669)

N/A

N/A

1,880

205

See Page

PAO-60Recognition SCERecognitionSCE-06

PAO

PAO Difference

TURN

TURN Difference

37

(37)

N/A

N/A

74

207

See Page


SCEShort-Term Incentive Program - A&GSCE-06

PAO

PAO Difference

TURN

TURN Difference

23,024

(46,231)

N/A

N/A

69,255

217

See Page



2018$ in Thousands




SCEShort-Term Incentive Program - Customer Service

SCE-06

PAO

PAO Difference

TURN

TURN Difference

6,247

(13,283)

N/A

N/A

19,530

217

See Page


SCEShort-Term Incentive Program - Generation

SCE-06

PAO

PAO Difference

TURN

TURN Difference

2,809

(5,216)

N/A

N/A

8,025

217

See Page

PAO-53Non-Wildfire SCELiability Insurance (Non-Wildfire)SCE-06

PAO

PAO Difference

TURN

TURN Difference

32,266

(3,585)

N/A

N/A

35,851

204

See Page



Summary of Capital Expenditure Issues

38

Capital Expenditure Related Issues, By Exhibit (Total Company) 2021 Test Year

Exhibit

SOUTHERN CALIFORNIA EDISON2021 GENERAL RATE CASE APPLICATION (A.19-08-013)Table I-3 | Summary of Capital Expenditure Related Issues, By Exhibit (Total Company)

$ in Thousands

Issue Description Issue Number Intervenor 2020 Total 2021 Total

Grid Modernization | Automation

TURN-15Automation Capital ForecastSCE-02 SCE

PAO Difference

TURN Difference

N/A N/A

(24,918) (15,155)

TURN 9,891 8,717

N/A N/APAO34,809 23,872

133

See Page

Poles | Distribution Deteriorated Pole Replacement

PAO-34Pole Capital ExpendituresSCE-02 SCE

PAO Difference

TURN Difference

(18,364) (14,264)

N/A N/A

TURN N/A N/A

218,875 194,694PAO237,239 208,958

140

See Page

Poles | Distribution Joint Pole Capital Credits

PAO-33Joint Pole CreditsSCE-02 SCE

PAO Difference

TURN Difference

(8,807) (12,701)

N/A N/A

TURN N/A N/A

(96,468) (114,225)PAO(87,660) (101,524)

139

See Page

Poles | Distribution Pole Loading Program Pole Replacement


PAO Difference

TURN Difference

(11,781) (17,879)

N/A N/A

TURN N/A N/A

140,121 243,293PAO151,902 261,172

140

See Page

Inspections & Maintenance | Distribution Preventive and Breakdown Capital Maintenance

PAO-13Distribution Preventive and Breakdown Capital Maintenance

SCE-02 SCE

PAO Difference

TURN Difference

342 260

N/A N/A

TURN N/A N/A

277,715 286,457PAO277,373 286,197

132

See Page

Capital Related Expense & Other | Distribution Transformers



Exhibit


$ in Thousands


PAO-20Distribution Transformers Capital ForecastSCE-02 SCE

PAO Difference

TURN Difference

325 3,904

N/A N/A

TURN N/A N/A

98,569 109,147PAO98,244 105,243

134

See Page

Poles | Distribution Wood Pole Disposal


PAO Difference

TURN Difference

0 0

N/A N/A

TURN N/A N/A

3,061 2,997PAO3,061 2,997

140

See Page

Poles | Distribution Wood Pole Disposal - Pole Loading Program


PAO Difference

TURN Difference

0 0

N/A N/A

TURN N/A N/A

934 1,679PAO934 1,679

140

See Page

Grid Modernization | Engineering and Planning Software Tools

PAO-TURN-21Engineering and Planning Software Tools Capital Forecast

SCE-02 SCE

PAO Difference

TURN Difference

(25,145) (27,213)

(25,145) (27,213)

TURN 0 0

0 0PAO25,145 27,213

144

See Page

Grid Modernization | Grid Management System

PAO-TURN-23Grid Management System (GMS) Capital Forecast

SCE-02 SCE

PAO Difference

TURN Difference

0 (10,155)

0 (10,155)

TURN 35,724 37,456

35,724 37,456PAO35,724 47,611

146

See Page

Meter Activities | Meter Engineering



Exhibit


$ in Thousands


PAO-26Meter Engineering Routine WorkSCE-02 SCE

PAO Difference

TURN Difference

(2,300) (2,300)

N/A N/A

TURN N/A N/A

41,942 28,648PAO44,242 30,948

135

See Page

Capital Related Expense & Other | Prefabrication

PAO-28Distribution Pole Loading Program (PLP) Prefabrication

SCE-02 SCE

PAO Difference

TURN Difference

(1,261) (4,388)

N/A N/A

TURN N/A N/A

17,582 18,010PAO18,843 22,398

136

See Page

New Service Connections | Residential New Service Connections

TURN-30Residential New Service Connections ForecastSCE-02 SCE

PAO Difference

TURN Difference

N/A N/A

0 (31,267)

TURN 137,670 118,520

N/A N/APAO137,670 149,787

137

See Page

Customer Requested System Modifications | Rule 20A Conversions

PAO-145Rule 20A ConversionSCE-02 SCE

PAO Difference

TURN Difference

(6,179) (6,372)

N/A N/A

TURN N/A N/A

11,205 11,553PAO17,384 17,925

143

See Page

Poles | Telecommunication Deteriorated Pole Replacement


PAO Difference

TURN Difference

4 5

N/A N/A

TURN N/A N/A

121 230PAO117 225

140

See Page

Poles | Telecommunication Pole Loading Program Replacement



Exhibit


$ in Thousands



PAO Difference

TURN Difference

2 26

N/A N/A

TURN N/A N/A

61 1,124PAO59 1,098

140

See Page

Inspections & Maintenance | Transmission Capital Maintenance

PAO-31Aerial Inspection Maintenance Forecast Methodology

SCE-02 SCE

PAO Difference

TURN Difference

0 (7,461)

N/A N/A

TURN N/A N/A

0 15,000PAO0 22,461

138

See Page

Poles | Transmission Deteriorated Pole Replacement


PAO Difference

TURN Difference

3,128 2,297

N/A N/A

TURN N/A N/A

86,578 98,270PAO83,450 95,973

140

See Page

Poles | Transmission Joint Pole Capital Credits

PAO-33Joint Pole CreditsSCE-02 SCE

PAO Difference

TURN Difference

(1,519) (2,608)

N/A N/A

TURN N/A N/A

(16,661) (23,475)PAO(15,142) (20,867)

139

See Page

Poles | Transmission Pole Loading Program Replacement


PAO Difference

TURN Difference

574 1,028

N/A N/A

TURN N/A N/A

15,855 43,909PAO15,281 42,881

140

See Page

Business Continuation | All Hazards Assessment, Mitigation and Analytics



Exhibit


$ in Thousands


PAO-TURN-14Business Continuation CapitalSCE-04 SCE

PAO Difference

TURN Difference

0 (2,737)

(3,841) (5,874)

TURN 47,059 34,726

50,900 37,863PAO50,900 40,600

186

See Page

Business Continuation | Climate Adaptation and Severe Weather

PAO-TURN-14Business Continuation CapitalSCE-04 SCE

PAO Difference

TURN Difference

0 0

0 0

TURN 200 1,360

200 1,360PAO200 1,360

186

See Page

Cybersecurity | Cybersecurity Delivery and IT Compliance

PAO-18Cybersecurity CapitalSCE-04 SCE

PAO Difference

TURN Difference

150 (19,727)

N/A N/A

TURN N/A N/A

40,000 42,558PAO39,850 62,285

178

See Page

Wildfire Management | Distribution Fault Anticipation

TURN-19Distribution Fault AnticipationSCE-04 SCE

PAO Difference

TURN Difference

N/A N/A

0 (6,270)

TURN 0 0

N/A N/APAO0 6,270

180

See Page

Wildfire Management | Enhanced Overhead Inspections and Remediations

TURN-22Vertical SwitchesSCE-04 SCE

PAO Difference

TURN Difference

N/A N/A

0 (804)

TURN 0 0

N/A N/APAO0 804

181

See Page

Cybersecurity | Grid Mod Cybersecurity



Exhibit


$ in Thousands


PAO-24Grid Mod Cybersecurity CapitalSCE-04 SCE

PAO Difference

TURN Difference

408 (19,703)

N/A N/A

TURN N/A N/A

24,949 25,542PAO24,542 45,245

182

See Page

Physical Security | Protection of Grid Infrastructure Assets

PAO-29Protection of Grid InfrastructureSCE-04 SCE

PAO Difference

TURN Difference

(22,161) (10,894)

N/A N/A

TURN N/A N/A

16,491 16,821PAO38,652 27,715

183

See Page

Wildfire Management | Wildfire Covered Conductor Program

PAO-TURN-CUE-35Wildfire Covered Conductor ProgramSCE-04 SCE

PAO Difference

TURN Difference

CUE

26,358 (199,221)

N/A (524,827)

TURN N/A 208,197

533,803 533,803PAO507,445 733,024

507,445 733,024

0 0

CUE

189

See Page

Fossil Fuel Generation | Catalina - Diesel

PAO-TURN-16Planned Replacement of Catalina Diesel Generation Plants

SCE-05 SCE

PAO Difference

TURN Difference

(500) (5,300)

(500) (5,300)

TURN 0 0

0 0PAO500 5,300

195

See Page

Hydro | Hydro - Decommissioning

PAO-TURN-25Hydro Decommissioning Capital for San Gorgonio

SCE-05 SCE

PAO Difference

TURN Difference

0 0

(2,250) (2,250)

TURN 0 0

2,250 2,250PAO2,250 2,250

197

See Page

Fossil Fuel Generation | Mountainview



Exhibit


$ in Thousands


PAO-TURN-27Removal of the Mountainview Rotor Replacement Capital Project

SCE-05 SCE

PAO Difference

TURN Difference

0 0

0 0

TURN 4,950 6,440

4,950 6,440PAO4,950 6,440

199

See Page

Facility & Land Operations | CRE Project Management

TURN-157Facility and Land Operations Capital Expenditures - Substation Reliability Upgrade

SCE-06 SCE

PAO Difference

TURN Difference

N/A N/A

(5,077) 0

TURN 0 0

N/A N/APAO5,077 0

221

See Page

TURN-161Infrastructure Upgrade - Santa BarbaraSCE-06 SCE

PAO Difference

TURN Difference

N/A N/A

0 0

TURN 0 0

N/A N/APAO0 0

223

See Page

TURN-162Infrastructure Upgrade - T&D Training CenterSCE-06 SCE

PAO Difference

TURN Difference

N/A N/A

(6,438) (30,942)

TURN 0 0

N/A N/APAO6,438 30,942

224

See Page

TURN-163Infrastructure Upgrade - Vehicle MaintenanceSCE-06 SCE

PAO Difference

TURN Difference

N/A N/A

0 0

TURN 0 0

N/A N/APAO0 0

225

See Page

TURN-17Infrastructure Upgrade - Blythe SCE-06 SCE

PAO Difference

TURN Difference

N/A N/A

0 0

TURN 0 0

N/A N/APAO0 0

220

See Page



Summary of Rate Base Issues

46

SOUTHERN CALIFORNIA EDISON2021 GENERAL RATE CASE APPLICATION (A.19-08-013)Table I-4 | Summary of Rate Base Related Issues, By Issue (Total Company)

2018$ in Thousands


Issue DescriptionIssue Number 2018$ in Thousands

Wildfire Insurance Premiums

PAO

PAO Difference

TURN

TURN Difference

377,017

(19,483)

N/A

N/A

396,500SCEPAO-94

232

See Page

Goods and Services

PAO

PAO Difference

TURN

TURN Difference

N/A

N/A

18,889

(15,361)

34,250SCETURN-95

233

See Page

Depreciation Expense

PAO

PAO Difference

TURN

TURN Difference

N/A

N/A

207,785

(89,149)

296,934SCETURN-96

234

See Page

Taxes Based on Income

PAO

PAO Difference

TURN

TURN Difference

N/A

N/A

(282,427)

(265,945)

(16,482)SCETURN-98

236

See Page

Materials and Supplies

PAO

PAO Difference

TURN

TURN Difference

N/A

N/A

237,191

(433)

237,624SCETURN-99

237

See Page

Customer Deposits

PAO

PAO Difference

TURN

TURN Difference

(8,460)

(8,460)

(262,082)

(262,082)

0SCEPAO-TURN-100

238

See Page

Fuel and Purchased Power

PAO

PAO Difference

TURN

TURN Difference

72,302

(60,844)

N/A

N/A

133,146SCEPAO-93

231

See Page



2018$ in Thousands



SCE Agrees to Intervenors

PAO

PAO Difference

TURN

TURN Difference

(16,482)

0

N/A

N/A

(16,482)SCESCE-001

73

See Page

T&D Service Lives - Account 362 (Distribution Station Equipment)

PAO

PAO Difference

TURN

TURN Difference

N/A

N/A

(2,726)

(2,181)

(545)SCETURN-105

243

See Page

T&D Service Lives - Account 352 (Transmission Structures and Improvements)

PAO

PAO Difference

TURN

TURN Difference

N/A

N/A

(544)

(578)

34SCETURN-101

239

See Page

T&D Service Lives - Account 354 (Transmission Towers and Fixtures)

PAO

PAO Difference

TURN

TURN Difference

N/A

N/A

(85)

(128)

43SCETURN-102

240

See Page

T&D Service Lives - Account 361 (Distribution Structures and Improvements)

PAO

PAO Difference

TURN

TURN Difference

N/A

N/A

(2,647)

(1,184)

(1,463)SCETURN-104

242

See Page

T&D Service Lives - Account 366 (Distribution UG Conduit)

PAO

PAO Difference

TURN

TURN Difference

N/A

N/A

(4,301)

(5,973)

1,672SCETURN-106

244

See Page

T&D Service Lives - Account 369 (Services)

PAO

PAO Difference

TURN

TURN Difference

N/A

N/A

(4,483)

(5,230)

747SCETURN-107

245

See Page



2018$ in Thousands



T&D Service Lives - Account 370 (Meters)

PAO

PAO Difference

TURN

TURN Difference

N/A

N/A

(29,023)

(27,203)

(1,820)SCETURN-108

246

See Page

T&D Net Salvage

PAO

PAO Difference

TURN

TURN Difference

60,252

(138,915)

50,089

(149,079)

199,168SCEPAO-TURN-109

251

See Page

Hydro Decommissioning

PAO

PAO Difference

TURN

TURN Difference

6,759

(20,617)

10,104

(17,273)

27,376SCEPAO-TURN-110

252

See Page

Escalation in Generation Decommissioning Estimates

PAO

PAO Difference

TURN

TURN Difference

N/A

N/A

26,816

(6,413)

33,229SCETURN-111

247

See Page

Recovery of Perris Solar Decommissioning and Unrecovered Original Investment

PAO

PAO Difference

TURN

TURN Difference

N/A

N/A

4,507

1,970

2,537SCETURN-112

248

See Page

Palo Verde Interim Retirement Rate

PAO

PAO Difference

TURN

TURN Difference

N/A

N/A

18,031

(1,767)

19,798SCETURN-113

249

See Page

Recovery of Fuel Cell Decommissioning

PAO

PAO Difference

TURN

TURN Difference

N/A

N/A

453

(547)

1,000SCETURN-114

250

See Page



2018$ in Thousands



T&D Service Lives - Account 356 (Transmission OH Conductor)

PAO

PAO Difference

TURN

TURN Difference

N/A

N/A

(512)

(717)

205SCETURN-103

241

See Page

Synchronized Interest Adjustment

PAO

PAO Difference

TURN

TURN Difference

N/A

N/A

(70,865)

(70,865)

0SCETURN-97

235

See Page



Chapter 1 | Issues Where Parties Agree To Revisions

51

SOUTHERN CALIFORNIA EDISON2021 GENERAL RATE CASE APPLICATION (A.19-08-013)Summary of Difference, By Issue

2021 Test Year

Exhibit:

Cost Component:

BPG:

Witness:

Issue Title:

SECTION 1 - ISSUE DETAIL

SECTION 2 - POSITIONS

SECTION 3 - FINANCIAL IMPACT

2018$ in Thousands


O&M

Billing & Payments

Brandi Anderson (SCE), Faith Bautista (NDC)

SCE agrees with NDC to remove $0.008 million related to a change in customer growth rate.

SCE-14, Vol. 1, p. 18

NDC Position: NDC points out that the customer growth rate of 0.73 percent used for Credit and Payment Services incoming work should be corrected to the 0.6 percent growth rate stated in SCE-07, Vol.1A2 at 77.

NDC-01, p. 13-19

SCE Position:

SCE-03, Vol. 1A

SCEFERCAccount

BPEGRC Activity

NDC vs SCE

NDC

903 | Credit and Payment

Labor 8 (8) 0

Total 8 (8) 0

This difference reflects a change in SCE's request. NDC recommended disallowing the entire $637,000 requested increase in labor costs, and maintaining 2018 recorded labor costs (NDC-01 p14). As one part of the entirety of our arguments against SCE’s forecast calculations, we noted that the customer growth rate of 0.73% that SCE used was inconsistent with the 0.6% rate used elsewhere in testimony (NDC-01 p13-14). In rebuttal, SCE states that using a corrected customer growth rate of 0.65% with all their original assumptions would reduce their labor forecast by approximately $8,000 (SCE-14 p18). However, NDC has not yet responded to this new calculation, it does not reflect our primary recommendation, and it does not resolve the overall issue. See issue TURN-NDC-44 | Credit and Payment.

Credit and Payment

8 (8) 0Total

Southern California Edison Chapter 152


2021 Test Year

Exhibit:

Cost Component:

BPG:

Witness:

Issue Title:




2018$ in Thousands


O&M

Hydro

Timothy Condit (SCE), William Marcus (TURN)

SCE accepts TURN’s recommendation of a $0.242 million reduction in Hydro O&M non-labor expenses. SCE also recommends an additional reduction of $0.029 million to its Hydro O&M labor forecast. This reduction is the result of incorrect timecard entries made to the Hydro O&M labor accounts by Catalina Water & Gas employees in 2018.

SCE-16, Vol. 1

TURN Position: TURN recommends removing the five-year average forecast expenses for non-labor costs of $261,000 for operating the retired Borel plant, and instead suggests utilizing 2018 last recorded year non-labor costs of $19,000, a reduction, resulting in a forecast reduction of $242,000 to non-labor.

TURN-09, pp. 14-15

SCE Position:

SCE-05, Vol. 1

SCEFERCAccount

BPEGRC Activity

TURN vs SCE

TURN

535 | Hydro

Labor 1580158

Total 0 158158

536 | Hydro

Labor 303

Non-Labor 5,06905,069

Total 0 5,0725,071

539 | Hydro

Labor 13,761(29)13,790

Non-Labor 10,705(242)10,947

Total (271) 24,46624,737

545 | Hydro

Labor 8,53508,535

Non-Labor 3,52803,528

Total 0 12,06312,062

This difference reflects a change in SCE's request. SCE and TURN are in agreement on this issue. After this adjustment is made, there is no difference between SCE's and TURN's position.

Hydro

(270) 41,75842,028Total



2021 Test Year

Exhibit:

Cost Component:

BPG:

Witness:

Issue Title:




2018$ in Thousands


O&M

Fossil Fuel Generation


SCE does not oppose TURN’s recommendation to reduce the 2021 Test Year O&M by $0.103 million for the removal of the atypical outage.

SCE-16, Vol. 1, p.25

TURN Position: TURN recommends reducing the non-labor O&M forecast by $0.103 million, to remove an atypical outage that is unlikely to occur with repowered or renewable generation after 2021.

TURN-09, p. 26

SCE Position:

SCE-05, Vol. 1

SCEFERCAccount

BPEGRC Activity

TURN vs SCE

TURN

549 | Catalina - Diesel

Labor 2,37202,372

Non-Labor 1,399(58)1,456

Total (58) 3,7703,828

554 | Catalina - Diesel

Labor 5080508

Non-Labor 1,099(45)1,145

Total (45) 1,6071,653

This difference reflects a change in SCE's request. SCE and TURN are in agreement on this issue. After this adjustment is made, there is no difference between SCE's and TURN's position.

Catalina - Diesel

(103) 5,3785,481Total



2021 Test Year

Exhibit:

Cost Component:

BPG:

Witness:

Issue Title:




2018$ in Thousands


O&M



SCE agrees with TURN’s recommendation. SCE and General Electric (GE) are in active negotiations on the future of the Mountainview’s Contract Service Agreement (CSA), which may impact future expenses.

SCE-16, Vol. 1, pp.18-20, SCE-05, Vol. 1E

TURN Position: TURN notes that the operations of the plant are changing and the payments to GE are declining as a result. Instead of using a four- year average (2015-2018), TURN recommends using $2.616 million, a reduction of $0.822 million, based on recent data reflecting the changes to the operations of Mountainview.

TURN-09, pp. 20-22

SCE Position:

SCE-05, Vol. 1

SCEFERCAccount

BPEGRC Activity

TURN vs SCE

TURN

546 | Mountainview

Labor 1130113

Total 0 113113

549 | Mountainview

Labor 2,45802,458

Non-Labor 4,61904,619

Other 71071

Total 0 7,1487,148

554 | Mountainview

Labor 6,19206,192

Non-Labor 12,431012,431

Other 2,545(822)3,367

Total (822) 21,16821,990

This difference reflects a change in SCE's request. SCE and TURN are in agreement on this issue. After this adjustment is made, there is no difference between SCE and TURN's position. SCE’s position includes an errata adjustment for $0.158M.

Mountainview

(822) 28,42929,251Total



2021 Test Year

Exhibit:

Cost Component:

BPG:

Witness:

Issue Title:




2018$ in Thousands


O&M



SCE does not oppose TURN’s recommendation to reduce 2021 Test Year and 2022 and 2023 each by $0.018 million to correct a double counting resulting from SCE including the interconnection fees in the non-labor cost category.

SCE-16, Vol. 1

TURN Position: TURN proposes a small adjustment to prevent double counting the facilities charges for 2014-2017 included in non-labor expenses, which were then averaged.

TURN-09

SCE Position:

SCE-05, Vol. 1

SCEFERCAccount

BPEGRC Activity

TURN vs SCE

TURN

549 | Fuel Cell

Labor 303

Non-Labor 470(18)488

Total (18) 473491

553 | Fuel Cell

Non-Labor (16)0(16)

Other 16016

Total 0 00

This difference reflects a change in SCE's request. SCE and TURN are in agreement on this issue. After this adjustment is made, there is no difference between SCE and TURN's position.

Fuel Cell

(18) 473491Total



2021 Test Year

Exhibit:

Cost Component:

BPG:

Witness:

Issue Title:




2018$ in Thousands


O&M

Employee Support

Jacqueline Trapp (SCE), Garrick Jones (TURN)

OU Support Services spans across the Company, but are not specific to an OU. The responsibilities of this activity include supporting the Operating Units as a whole, such as Business Partner Support and Organizational Development/Organizational Effectiveness Support, while other actions include employee specific activities, like Employee Relations, Labor Relations, Internal Communications, and Administrative Support. SCE agrees to TURN’s recommendations as described below.

SCE-17, Vol. 03, p. 8

TURN Position: SCE selected a last recorded year forecast method for its OU Support Services, with adjustments which decreased the overall forecast.; SCE then applied a 2.9 percent escalation rate to its labor forecast. TURN states it is not appropriate to apply any labor escalation to the 2018 base year, as the Results of Operations Model (RO Model) will apply all escalation. TURN also recommends a $2.204 disallowance to OU Support Services non-labor forecast on two grounds: (a) costs anticipated for union-negotiated benefit changes did not materialize; and (2) SCE’s data request response, which explained that this money would be used for additional groups attempting to organize within the Company, was vague and speculative.

TURN-04 p. 26

SCE Position:

SCE-06, Vol. 3 Pt. 1

SCEFERCAccount

BPEGRC Activity

TURN vs SCE

TURN

923 | OU Support Services

Labor 1,978(118)2,097

Non-Labor 86(24)110

Total (143) 2,0642,207


Labor 2,960(177)3,136

Non-Labor 4,573(1,303)5,876

Total (1,480) 7,5329,012


Labor 16,653(994)17,647

Non-Labor 3,074(876)3,950

Total (1,870) 19,72721,597

This difference reflects a change in SCE's request. SCE and TURN are in agreement on this issue. After this adjustment is made, there is no difference between SCE's and TURN's position. The difference excludes the $111k reduction for AB 560, resulting in a net SCE forecast of $29.212M; see SCE-52 A2 Update Testimony.

OU Support Services

(3,493) 29,32332,816Total



2021 Test Year

Exhibit:

Cost Component:

BPG:

Witness:

Issue Title:




2018$ in Thousands


O&M

Financial Oversight & Transactional Processing

April Li (SCE), Mark Waterworth (PAO)

SCE agrees with PAO’s recommendation.

SCE-17, Vol. 02, p. 12

PAO Position: PAO recommends using $(13.089) million based on a 5-year historical average for both AP Vendor Discount program and other miscellaneous payments for 2014 through 2018, resulting in a $1.877 million decrease. PAO states that considering in each of the historical years there has been some level of activity in other miscellaneous payments, there is a greater likelihood that such activity will occur on a regular basis over the forecast period.

PAO-10, Part 1, pp. 13-14

SCE Position:

SCE-06, Vol. 2

SCEFERCAccount

BPEGRC Activity

PAO vs SCE

PAO

930 | Vendor Discount and Other Miscellaneous Payments

Non-Labor (1,877) (13,089)(11,212)

Total (1,877) (13,089)(11,212)

This difference reflects a change in SCE's request. SCE and PAO are in agreement on this issue. After this adjustment is made, there is no difference between SCE's and PAO’s position.

Vendor Discount and Other Miscellaneous Payments

(1,877) (13,089)(11,212)Total



2021 Test Year

Exhibit:

Cost Component:

BPG:

Witness:

Issue Title:




2018$ in Thousands


O&M

Policy & External Engagement

Gary Stern (SCE), Chia Hadiprodjo Nawaz (PAO)

SCE agrees with PAO for removal of $92,000 ($7,500 + $22,500 + $62,262) in one-time or non-recurring costs.

SCE-17, Vol. 6, pp. 4-6

PAO Position: PAO performed an audit examination of SCE’s financial and accounting records in response to SCE’s Application for authority to increase Test Year 2021 GRC revenue requirements. Based on PAO' examination, it recommends a downward adjustment of $181,524 to the 2018 recorded non-labor expenses for costs that were identified as one-time or could not be independently verified due to SCE’s assertion of legal privilege.

PAO-18, pp. 7-8

SCE Position:

SCE-06, Vol. 6

SCEFERCAccount

BPEGRC Activity

PAO vs SCE

PAO

920921 | Develop and Manage Policy and Initiatives

Non-Labor (92) 092

Total (92) 092

This difference reflects a change in SCE's request. SCE and PAO are in agreement on this issue. After this adjustment is made, there is no difference between SCE's and PAO's position.

Develop and Manage Policy and Initiatives

(92) 092Total



2021 Test Year

Exhibit:

Cost Component:

BPG:

Witness:

Issue Title:




2018$ in Thousands


O&M

Billing & Payments

Brandi Anderson (SCE), Dao Phan (PAO), David Cheng (TURN)

SCE agrees with PAO and TURN and has reduced the Test Year forecast by $0.200 million to account for the Commission’s authorization to close the remaining Rural Offices.

SCE-14, Vol. 1, pp. 15-20; SCE-3, Vol.1AE

SCE Position:

PAO Position:

TURN Position:

SCE-03, Vol. 1A

PAO believes the forecast should be updated to reflect a reduction of $0.2 million in 2021$ ($0.18 in 2018$) for the closure of 11 Rural Offices.

PAO-08, p. 14

TURN recommends removing $0.2 million in 2021$ ($0.18 in 2018$) for closing the remaining 11 Rural Offices.

TURN-06, p.10

SCEFERCAccount

BPEGRC Activity

PAO vs SCE

TURN vs SCE

TURNPAO


Labor (200) (200)200 00

Total (200) (200)200 0 0

Credit and Payment

(200) (200)200 0 0Total

This difference reflects a change in SCE's request. SCE, PAO, and TURN are in agreement on this issue. After this adjustment is made, there is no difference between SCE's, PAO's, and TURN's position. In Update Testimony SCE-52 A2 severed on 8/19/2020, SCE made a correction to the RO model to properly reflect the rural office closure concession.



2021 Test Year

Exhibit:

Cost Component:

BPG:

Witness:

Issue Title:




2018$ in Thousands


O&M


April Li (SCE), Mark Waterworth (PAO), William Marcus (TURN)

SCE agrees with PAO’s recommendation.

SCE-17, Vol. 02, p. 13

SCE Position:

PAO Position:

TURN Position:

SCE-06, Vol. 2

PAO considers using a 5-year average (2014-2018) as a better forecasting methodology for Other (P&B). PAO agrees that P&B loading rates can fluctuate significantly; and, thus the use of a 5- year average better captures the fluctuations.

PAO-10, pp. 14-16

TURN agrees with A&G/P&B loading rates and recommends a reduction in the forecast as a result of decreasing Generation O&M labor.

TURN-09 p. 11

SCEFERCAccount

BPEGRC Activity

PAO vs SCE

TURN vs SCE

TURNPAO

926 | Participant Credits and Charges - 926

Other (2,801) (874)10,554 9,6807753

Total (2,801) (874)10,554 7,753 9,680

Participant Credits and Charges - 926

(2,801) (874)10,554 7,753 9,680Total

This difference reflects a change in SCE's request. SCE, PAO, and TURN are in agreement on this issue. After this adjustment is made, there is no difference between SCE's, PAO's, and TURN's position.



2021 Test Year

SECTION 1 - ISSUE DETAILS

Exhibit:

Cost Component:

Witness:


BPE:

Capital Expenditures

Inspections & Maintenance

Terry Ohanian (SCE), Greg Wilson (PAO)

SCE agrees with PAO’s proposal to update the five-year average to include 2019 recorded data.

SCE-13 Vol. 01, Part 2, p. 19

PAO Position: PAO proposes to update five-year average to include 2019 recorded data.

PAO-04, p. 18


$ in Thousands

Issue Title: SCE-001 | SCE Agrees to Intervenors

SCE Position:


BPE | GRC Activity 2019 2020 2021 2022 2023 TotalID

Inspections & Maintenance | Distribution Claim

14 | CET-PD-CL-DC-MTW

SCE

PAO

123,902

41,848 42,167 43,495 Post-Test Year Post-Test Year 127,509

41,848 40,385 41,669 42,875 44,108

PAO vs SCE 0 1,782 1,826 N/A N/A 3,607

SCE

Total Distribution Claim:

PAO

123,90244,10842,87541,66940,38541,848


PAO vs SCE 0 1,782 1,826 N/A N/A 3,607

This difference reflects a change in SCE's request. SCE and PAO are in agreement on this issue. After this adjustment is made, there is no difference between SCE's and PAO's position. PAO’s Post-Test Year amounts in 2022-2023 will be derived based on the Post-Test Year ratemaking proposal. Totals represent 2019-2021. In Update Testimony SCE-52 A2 served on 8/19/2020, SCE made a correction to the RO model to properly reflect the Distribution Claim concession.



2021 Test Year


Exhibit:

Cost Component:

Witness:


BPE:


Customer Requested System Modifications

Paul Joseph (SCE), Greg Wilson (PAO)

SCE agrees to PAO’s proposal to use an updated five-year average to include 2019 recorded data, but with the full constant-to-nominal conversion rate, which decreases PAO's 2020 forecast by $0.002 million and increases the 2021 forecast by $0.002 million.

SCE-13 Vol. 04 Part 3, p. 20

PAO Position: PAO proposes to use an updated five-year average to include 2019 recorded data.

PAO-04, p. 41


$ in Thousands


SCE Position:



Customer Requested System Modifications | Distribution Added Facilities

570 | CET-PD-AF-CS-MTW

SCE

PAO

17,807


5,725 5,946 6,136 6,313 6,495

PAO vs SCE (3,500) (774) (800) N/A N/A (5,074)

571 | CET-PD-AF-DA-MTW

SCE

PAO

26,433


8,498 8,827 9,108 9,371 9,641

PAO vs SCE (3,506) (1,150) (1,186) N/A N/A (5,842)

SCE

Total Distribution Added Facilities:

PAO

44,24016,13615,68415,24414,77414,223


PAO vs SCE (7,006) (1,924) (1,986) N/A N/A (10,916)

This difference reflects a change in SCE's request. SCE and PAO are in agreement on this issue. After this adjustment is made, there is no difference between SCE's and PAO's position. PAO’s Post-Test Year amounts in 2022-2023 will be derived based on the Post-Test Year ratemaking proposal. Totals represent 2019-2021.



2021 Test Year


Exhibit:

Cost Component:

Witness:


BPE:




SCE agrees to PAO’s proposal to use an updated five-year average to include 2019 recorded data.

SCE-13 Vol. 04 Part 3, p. 10

PAO Position: PAO proposes to use an updated five-year average to include 2019 recorded data.

PAO-04, p. 27


$ in Thousands


SCE Position:



Customer Requested System Modifications | Distribution Relocations

572 | CET-PD-CR-RL-MTW

SCE

PAO

159,494


47,747 54,999 56,748 58,390 60,069

PAO vs SCE 0 (2,747) (2,850) N/A N/A (5,597)

SCE

Total Distribution Relocations:

PAO

159,49460,06958,39056,74854,99947,747


PAO vs SCE 0 (2,747) (2,850) N/A N/A (5,597)




2021 Test Year


Exhibit:

Cost Component:

Witness:


BPE:




SCE agrees with PAO’s recommendation, but with the inclusion of corrected 2019 recorded figures.

SCE-13 Vol. 04 Part 3, p. 17

PAO Position: For Rule 20B/C conversions, PAO proposes to update five-year average to include 2019 recorded data.

PAO-04, p. 36, 38


$ in Thousands


SCE Position:



Customer Requested System Modifications | Rule 20 B/C Conversions

574 | CET-PD-CR-TB-TREAST

SCE

PAO

17,029


5,336 5,785 5,909 6,021 6,159

PAO vs SCE (675) 51 60 N/A N/A (563)

575 | CET-PD-CR-TC-TREAST

SCE

PAO

7,052


1,613 2,690 2,748 2,800 2,864

PAO vs SCE 555 (1,080) (1,102) N/A N/A (1,627)

576 | CIT-00-OP-NS-000003

SCE

PAO

1,128

236 311 310 Post-Test Year Post-Test Year 857

513 308 307 307 307

PAO vs SCE (277) 3 3 N/A N/A (271)

577 | CIT-00-OP-NS-000004

SCE

PAO

858


592 133 133 133 133

PAO vs SCE (490) (53) (53) N/A N/A (597)

578 | CET-PD-CR-2B-MTW

SCE

PAO

48,558


12,763 17,617 18,178 18,704 19,242

PAO vs SCE 1,278 (698) (721) N/A N/A (142)



2021 Test Year

579 | CET-PD-CR-2C-MTW

SCE

PAO

34,391


9,971 12,019 12,401 12,760 13,127

PAO vs SCE (391) 388 400 N/A N/A 397

SCE

Total Rule 20 B/C Conversions:

PAO

109,01641,83240,72539,67638,55230,788


PAO vs SCE 0 (1,389) (1,413) N/A N/A (2,802)




2021 Test Year


Exhibit:

Cost Component:

Witness:


BPE:



Paul Joseph (SCE), David Cheng (TURN)

SCE agrees with TURN’s recommendation.

SCE-13 Vol. 04 Part 3, p. 14

TURN Position: TURN proposes to reduce the Rule 20A conversions forecast by $7.779 million, in 2018 constant dollars, per year, to account for the $31.116 million balance in the Rule 20A Balancing Account.

TURN-06 p. 31


$ in Thousands


SCE Position:




580 | CIT-00-OP-NS-000018

SCE

TURN

1,818

103 369 252 259 266 1,249

342 369 369 369 369

TURN vs SCE (239) 0 (117) (117) (103) (569)

581 | CET-PD-2A-2A-MTW

SCE

TURN

87,600

12,229 17,015 9,014 9,265 9,521 57,044

16,381 17,015 17,556 18,064 18,584

TURN vs SCE (4,152) 0 (8,542) (8,542) (9,063) (30,556)

SCE

Total Rule 20A Conversions:

TURN

89,41818,95318,43317,92517,38416,723

12,332 17,384 9,266 9,524 9,787 58,293

TURN vs SCE (4,391) 0 (8,659) (8,909) (9,166) (31,125)

This difference reflects a change in SCE's request. SCE and TURN are in agreement on this issue. After this adjustment is made, there is no difference between SCE's and TURN's position. TURN’s financial position represents SCE’s conversion of TURN's recommendations from 2018 Constant $ to Nominal $. TURN has not verified SCE’s conversion calculation.



2021 Test Year


Exhibit:

Cost Component:

Witness:


BPE:




SCE agrees to PAO’s proposal to update the five-year average to include 2019 recorded data.

SCE-13 Vol. 04 Part 3, p. 12

PAO Position: PAO proposes to update five-year average to include 2019 recorded data; PAO did not address the 2022-2023 forecast.

PAO-04, p. 29


$ in Thousands


SCE Position:



Customer Requested System Modifications | Transmission Relocations

583 | CET-PD-CR-TR-TREAST

SCE

PAO

39,532


9,012 15,098 15,422 0 0

PAO vs SCE 0 (2,887) (2,957) N/A N/A (5,844)

SCE

Total Transmission Relocations:

PAO

39,5320015,42215,0989,012


PAO vs SCE 0 (2,887) (2,957) N/A N/A (5,844)

This difference reflects a change in SCE's request. SCE and PAO are in agreement on this issue. After this adjustment is made, there is no difference between SCE's and PAO's position. The 2022-2023 forecast is excluded because PAO did not address the 2022-2023 forecast. PAO’s Post-Test Year amounts in 2022-2023 will be derived based on the Post-Test Year ratemaking proposal. Totals represent 2019-2021.



2021 Test Year


Exhibit:

Cost Component:

Witness:


BPE:


New Service Connections

Hongyan Sheng (SCE), Eric Borden (TURN)

SCE accepts TURN's commercial new service connections proposal.

SCE-13 Vol. 04 Part 3, p. 8

TURN Position: TURN proposes using the average number of commercial meters installed over the last five recorded years (2015-2019) as a more reasonable forecast.

TURN-02C, p. 58-59


$ in Thousands


SCE Position:



New Service Connections | Commercial New Service Connections

569 | CET-PD-NS-CL-MTW

SCE

TURN

505,564

94,111 97,968 88,533 91,094 93,714 465,420

94,111 97,968 101,244 104,300 107,941

TURN vs SCE 0 0 (12,711) (12,711) (14,227) (40,144)

SCE

Total Commercial New Service Connections:

TURN

505,564107,941104,300101,24497,96894,111

94,111 97,968 88,533 91,094 93,714 465,420

TURN vs SCE 0 0 (12,711) (13,206) (14,227) (40,144)

This difference reflects a change in SCE's request. SCE and TURN are in agreement on this issue. After this adjustment is made, there is no difference between SCE's and TURN's position. SCE’s New Service Connections forecast is dependent on the new meter forecast and the capital expenditures should automatically adjust based on the new meter forecast ultimately authorized.



2021 Test Year


Exhibit:

Cost Component:

Witness:


BPE:


$ in Thousands



Fossil Fuel Generation1

Timothy Condit (SCE), Scott Logan (PAO), William Marcus (TURN)

SCE agrees to TURN's recommendation to remove the planned replacement of the turbine rotors from the 2020 and 2021 capital forecast. SCE also recommends that the 2019 forecast be based on the actual recorded amount.

SCE-16, Vol. 1, pp. 20-21

SCE Position:

PAO Position:

TURN Position:

SCE-05, Vol. 1

PAO recommends that the forecast of Mountainview generation-related capital expenditures for 2019-2021 be adopted as initially proposed.

PAO-09, p. 2

TURN recommends adjustment of the Mountainview capital forecast by $54 million because SCE no longer plans to purchase new turbine rotors that it forecast: $18 million in 2020 and $36 million in 2021.

TURN-09, p.19


Fossil Fuel Generation1 | Mountainview

855 | CG0-00-PP-MV-000104

2,992 22,950 42,440 0 0

1,228 4,950 6,440 0 0

SCE 68,382

12,618

12,618TURN

PAO

1,228 4,950 6,440 0 0

(1,764)PAO vs SCE

TURN vs SCE (1,764)

(18,000)

(18,000)

(36,000)

(36,000)

0

0

0

0

(55,764)

(55,764)

2,992SCE

PAO

Total Mountainview

1,228

1,228

22,950

4,950

4,950

42,440

6,440

6,440

0

0

0

0

0

0

68,382

12,618

12,618

PAO vs SCE

TURN vs SCE

(1,764)

(1,764)

(18,000) (36,000) 0 0

(18,000) (36,000) 0 0

(55,764)

(55,764)

This difference reflects a change in SCE's request. SCE and TURN are in agreement on this issue. After this adjustment is made, there is no difference between SCE and TURN's position. See issue-xx for 2019 capex.

TURN



2021 Test Year


Exhibit:

Cost Component:

Witness:


BPE:


$ in Thousands



Load Growth

Dana Cabbell (SCE), Thomas Roberts (PAO)

Although SCE’s methodology for identifying the forecast impacts of Distributed Energy Resources (DER) growth is based on sound engineering principles (as set forth in SCE’s direct testimony and workpapers), SCE acknowledges that, at this time, there is some uncertainty with respect to the timing and magnitude of the DER-driven violations on the grid as forecast DER growth becomes realized DER adoption.

SCE-02 Vol. 04 Pt. 2 pp. 52 - 62; SCE-13 Vol. 04, Pt. 2 pp. 8 - 10

SCE Position:

PAO Position:


PAO recommends that the Commission authorize zero dollars within this rate case of SCE’s requested 2020- 2021 forecast of $43.035M for five activities within SCE’s DER-driven Grid Reinforcement Program. PAO recommends that the costs associated with upgrading the grid due to DER growth be tracked in a memorandum account and be reviewed for reasonableness in subsequent GRC applications.

PAO-05P, Part 3, pp. 48 - 66


Load Growth | DER-Driven Circuit Breaker Upgrades

131 | CET-ET-GM-CB-781700

0 455 1,608 2,409 2,538

0 0 0 0 0

SCE 7,011

0PAO

0PAO vs SCE (455) (1,608) (2,409) (2,538) (7,011)

Load Growth | DER-Driven Substation Transformer Upgrades

133 | CET-ET-GM-TB-781700

0 57 843 1,093 0

0 0 0 0 0

SCE 1,992

0PAO

0PAO vs SCE (57) (843) (1,093) 0 (1,992)

Load Growth | New DER-Driven DSP Circuits

399 | CET-PD-GM-CI-MTW

0 0 17,138 12,410 13,445

0 0 0 0 0

SCE 42,992

0PAO

0PAO vs SCE 0 (17,138) (12,410) (13,445) (42,992)



2021 Test Year


Load Growth | DER-Driven Distribution Circuit Upgrades

132 | CET-PD-GM-LR-MTW

0 0 13,876 2,046 3,303

0 0 0 0 0

SCE 19,225

0PAO

0PAO vs SCE 0 (13,876) (2,046) (3,303) (19,225)

0SCE

PAO

Total DER-Driven Grid Reinforcement Program:

0

512

0

33,465

0

17,958

0

19,286

0

71,221

0

PAO vs SCE 0 (512) (33,465) (17,958) (19,286) (71,221)

This difference reflects a change in SCE's request. SCE and, PAO are in agreement on this issue. After this adjustment is made, there is no difference between SCE's and PAO's position.



2021 Test Year

Exhibit:

Cost Component:

Witness:

Issue Title:




2018$ in Thousands


Working Capital

PAO Position:

SCE Position: SCE agrees with PAO's recommendation of 61.8 lag days for Federal taxes and 55.4 lag days for State taxes based on the calendar accrual midpoint dates of July 2, 2009 and July 2, 2016, respectively.

SCE-18, Vol. 02, pp. 32-37

SCEIssue Name PAO PAO vs SCE

Capital-Related Working Cash

Line

PAO recommends 61.8 lag days for Federal taxes and 55.4 lag days for State taxes based on the calendar accrual midpoint dates of July 2, 2009 and July 2, 2016, respectively.

PAO-15, pp. 11-12

Mark Childs (SCE), Fidel A. Leon Diaz (PAO)

SCE-07, Vol. 02 and SCE-18, Vol. 02

1 (16,482) (16,482) 0Working Capital

Total (16,482) (16,482) 0



Chapter 2 | Ratemaking and Company-Wide-Related Issues

74


2021 Test Year

Cost Component:

Witness:

Issue Title:



TURN-115 | Other Recommendations for Decommissioning Analysis

Company-Wide

TURN Position:

SCE Position: SCE agrees with TURN's proposal to conduct additional decommissioning studies for its Peakers, Mountainview, and solar units for the next GRC.

SCE-18, Vol. 03 pp. 38

TURN recommends that SCE conduct a decommissioning study for Mountainview, a representative peaker, and a representative solar plant for its next GRC.

TURN-09, pp. 41

David Gunn (SCE), William Marcus (TURN)



2021 Test Year

Cost Component:

Witness:

Issue Title:



TURN-116 | Recovery of Infrastructure Costs Replaced by Wildfire Mitigation-Driven Activities

Company-Wide

TURN Position:

SCE Position: SCE rejects TURN's proposal to deny recovery of assets replaced under the wildfire mitigation project that have been installed in the last 5 years, arguing that; 1) these assets are facing near-term risk of failure, 2) some level of early retirements are part of group depreciation and cost of service ratemaking, and 3) there is no allegation of imprudence surrounding these replacements.

SCE-18, Vol. 02 pp. 8-13

TURN states that SCE is replacing existing assets installed within the last five years are still operational and not facing near-term risk of failure, thus creating prematurely replaced asset costs. TURN's claim is that customers will bear the cost of two assets even though only one remains in service. TURN recommends removal of "net recorded plant amount of assets installed less than 5 years ago" from rate base, and at a minimum reducing the authorized rate of return for those assets to a figure no higher than the cost of debt.

TURN-02, pp. 26-28

Neither party has quantified the financial impact because the amount of plant associated with assets installed within the past five years and subsequently replaced due to the wildfire mitigation project is not known at this time.

Alan Varvis (SCE), Eric Borden (TURN)



2021 Test Year

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Issue Title:



TURN-117 | Recovery of Net Book Value of Aged Pole Replacements

Company-Wide

TURN Position:

SCE Position: SCE proposes to include in rate base (starting in 2021) the net book value of the replacement poles installed in connection with the Aged Pole Program. The conduct the Commission determined was imprudent has been sufficiently remedied by the cumulative impact of disallowances imposed in the 2015 and 2018 GRCs. That is because the cost to customers of the replacement poles, on a Present Value Revenue Requirement basis, is lower than what customers would have paid even absent the Aged Pole Program. SCE’s proposal is reasonable because the goal is to make customers indifferent to SCE’s actions, not to put them in a better position.

SCE-07, Vol. 02A, pp. 7-8; SCE-18, Vol. 03, pp. 2-8

TURN recommends the Aged Pole disallowance remain in effect through this GRC cycle. The utility’s support for its request is very similar in nature to what it presented in the 2018 GRC, when the Commission rejected the request and described the need for a demonstration of the prudence of the Aged Pole Program. If the Commission decides here that SCE’s logic might warrant a different outcome here, it should still deny the request because of flaws in the remaining life calculations underlying the utility’s request. Correcting those calculations indicates that the poles replaced in the Aged Pole program could reasonably be expected to have remained in service until 2026-27, on average.

TURN-11

David Gunn (SCE), Robert Finkelstein & William Marcus (TURN)



2021 Test Year

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TURN-119 | Renewed Requests for Project Funding

Company-Wide - Ratemaking

TURN Position:

SCE Position: Renewed proposals for these capital projects should be approved because SCE used authorized funds to accomplish other work on behalf of customers that emerged as necessary and was not otherwise forecast. Assigning the burden of project proposals to shareholders violates ubiquitous principles of ratemaking. Utilities are not and cannot be held to a standard of perfect forecasting in a rate case, and unless it can be shown that the diverted spending was unreasonable, assigning future project costs to shareholders has no basis. There is no unjust enrichment to shareholders if approved capital for a specific project is deployed to a different capital project.

SCE-18 Vol. 1, Page 6

TURN agrees with PAO that the Commission should deny funding for previously-requested and previously- authorized capital projects. Previously authorized funds that were never spent must have been redirected to other spending or shareholder profits. Ratepayers paid for a return on the project even though SCE did not complete it, netting a return to SCE for money it never invested.

TURN-04, Page 5; TURN-10, Page 10; TURN-09, Page 16

Douglas Snow (SCE), William Marcus (TURN)



2021 Test Year

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TURN-120 | Establishment of the Wildfire Risk Mitigation Balancing Account (WRMBA)


TURN Position:

SCE Position: SCE proposes to create a new two-way balancing account, the Wildfire Risk Mitigation Balancing Account (WRMBA) to record the difference between: (1) the revenue requirement related to recorded O&M expenses and capital expenditures for activities approved in SCE's 2021-2023 Wildfire Mitigation Plans (WMPs), but excluding vegetation management activities; and (2) the authorized revenue requirement associated with forecast O&M and capital expenditures adopted in this proceeding. TURN's proposal for a one-way balancing account is, among other issues, inconsistent with Public Utilities Code §8386.4, and SCE maintains the position that a two-way balancing account with no after-the-fact reasonableness review of cost spent in excess of the adopted forecast is appropriate for three reasons: (1) SCE is prevented by statute to shift funds authorized for wildfire mitigation plan-related spending to non-wildfire-mitigation programs; (2) the scope of wildfire mitigation activities themselves are reviewed; and (3) a two-way balancing account is appropriate for differences in actual costs and recorded data used in this proceeding. SCE provides an alternative rebuttal WRMBA proposal in light of TURN's testimony, in which the WRMBA would be a balancing account with a soft- cap of 120% of initial authorization levels. The Commission should reject TURN's recommendations and adopt SCE's initial WRMBA, or alternatively adopt SCE's alternative WRMBA proposal.


TURN opposes SCE's request for a two-way WRMBA, both as presented in SCE’s direct testimony and the alternative proposal presented for the first time in rebuttal testimony. TURN’s testimony in TURN-02 recommended a one-way balancing account, however, that recommendation is evolving, and TURN’s final position will be as set forth in its briefs. As a general matter, SCE’s reliance on two-way balancing accounts in this GRC proceeding would effectively assign to ratepayers the entire cost recovery risk, an outcome that is inconsistent with forecast-based ratemaking or memorandum accounts subject to after-the-fact reasonableness review. Annual “compliance” reviews of the WRMBA in the ERRA review would be an inadequate substitute for a reasonableness review. Furthermore, SCE's proposal appears to undermine or even violate Public Utilities Code §8386.4, which describes reliance on a memorandum account and reasonableness review of those costs prior to cost recovery.

TURN-01, Pages 24-26; TURN-02, Page 30

Desiree Wong (SCE), Robert Finkelstein (TURN)



2021 Test Year

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PAO-124 | Establishment of a Property Tax Memorandum Account


PAO Position:

SCE Position: SCE used a simple average methodology to forecast property taxes. Cal Advocates supports a five-year trend method. The difference between SCE’s forecast (of $428.37 million) and Cal Advocates’ forecast (of $423.96 million) is $4.41 million. SCE is willing to accept Cal Advocates’ proposal because it maintains the status quo forecasting methodology for California property taxes, but this concession is contingent on rejection of Cal Advocates’ second proposal—to establish a new memo account just for California property taxes.

SCE-18 Vol. 1, Page 30; SCE-18, Volume 2

PAO recommends that SCE continue using the five-year trend method for calculating Ad Valorem Taxes for California and be authorized to establish a memorandum account to record any differences between actual and forecasted California property taxes for future disposition.

PAO-2, Page 3

David Lee (SCE), Jerry Oh (PAO)



2021 Test Year

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PAO-125 | Establishment of an Aerial Inspections Memorandum Account


PAO Position:

SCE Position: The Commission should reject PAO's recommendation to establish an Aerial Inspections Memorandum Account. If the Commission has concerns with SCE's forecast level of spending on this activity, it is more appropriate to establish a two-way balancing account authorized at SCE's request level.

SCE-18 Vol. 1, Page 30; SCE-13, Volume 2

If SCE finds Aerial Inspection Maintenance costs to be above $15 million, PAO recommends SCE request the Commission to approve a memorandum account to track costs for Aerial Inspection Maintenance.

PAO-3, Page 12

Gary Trumbo (SCE), Yakov Lasko (PAO)



2021 Test Year

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TURN Position:

SCE Position: TURN provides no evidence for its claims, just speculation. Additionally, TURN’s claims are false and demonstrate a misunderstanding of ECS, NTP&S, and the Affiliate Transaction Rules.

SCE-18 Vol. 1, Page 57-61

ECS has failed to allocate all costs associated with its NTP&S offerings to shareholders and that there are inappropriate conflicts of interest between shareholders and ratepayers when ECS utilizes resources that are funded by ratepayers. Another conflict of interest results from the fact that SCE is the sole decision-maker in the “but for” test to determine which costs should be paid for by ratepayers instead of shareholders.

TURN-06/Cheng Pages 25-30

Lisa Swenerton (SCE), David Cheng (TURN)



2021 Test Year

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EPUC-128 | Change to Capital-Related Added Facilities Rates


EPUC Position:

SCE Position: Costs for Added Facilities are paid for by specific customers who request them and not by the balance of general customers. If Added Facilities OOR is not compensatory, all other customers will inequitably subsidize Added Facilities customers. EPUC's proposals should be rejected, as they are inconsistent with cost-of-service ratemaking and overlook key cost components accounted for in SCE's Added Facilities rates. The long- standing methodology is based on levelized rates, which is the same levelized rate used each month until a Commission-approved decision. EPUC's proposal that capital-related payments should be terminated once the Added Facilities asset has reached the end of its book life is inconsistent with ratemaking principles, as Added Facilities customers would only pay for the “book life” of the asset in the cases that it reached its expected useful life but not in cases where it is retired earlier. That result would be fundamentally one-sided and unfair to the millions of other SCE customers who would be required to pay for the shortfall. EPUC asserts that SCE has over-accumulated depreciation on Added Facilities, but this interpretation of Accumulated Depreciation and Net Investment is incomplete and overlooks removal and disposal costs, which are key cost components accounted for in SCE's depreciation accrual.


EPUC proposes three changes to the Commission-approved methodology for calculating the monthly bill in cases where the customer elects to have SCE finance the Added Facilities (instead of personal financing). EPUC advocates that SCE: (1) immediately cease collection of return on investments for all investments for 1988 or prior, as well as for any subsequent years' investments in which rate base becomes negative between now and the time the Commission issues its decision in this proceeding, (2) cease charging depreciation on a vintage when the accumulated depreciation equals the initial investment plus the amount estimated for removal cost, (3) monitor future accumulations of depreciation and be required to cease collection of depreciation and return of each vintage of asset consistent with the other two recommendations.

EPUC-01, Page 1-3

Abdallah Baltaji (SCE), Maurice Brubaker (EPUC)



2021 Test Year

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CUE-129 | Distribution Infrastructure Replacement


CUE Position:

SCE Position: SCE disagrees with CUE’s proposed IR Plan and that includes three elements of explaining how SCE will achieve steady-state replacement, a ten-year IR plan, and a discussion of resource constraints.

SCE-13, Vol. 01, Part 1, pp. 6-9

SCE should develop an IR Plan as part of each GRC application. The IR Plan should include 1) How SCE will achieve steady-state replacement of aging infrastructure 2) A ten-year forward infrastructure replacement plan, 3) A discussion of potential resource constraints, including personnel constraints and how it will address them. The IR Plan submitted with the next GRC application should address work deferred because of the focus on wildfire mitigation activities, including but not limited to the Worst Circuit Rehabilitation program, Cable-in-Conduit program, Underground Switch Replacement program, and capacitor banks.

CUE-01, p. 5, 17-18, 21, 24, 27-28, 29-30

Robert Tucker (SCE), Robert Earle (CUE)



2021 Test Year

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PAO-130 | Financial Examination Recommendation - Technology Assessment


PAO Position:

SCE Position: SCE also does not dispute that there were incorrectly charged expenses in 2018 for the GRC activity Technology Assessments, and that the incorrectly-charged spending should have been recorded as capital expenditures. However, Cal Advocates’ recommendation to remove $31,150 from 2018 recorded O&M non-labor expenses for Technology Assessment should not be adopted. SCE previously addressed in a data request response the specific recorded costs referenced by Cal Advocates. The costs represent the purchase of $93,420 worth of hybrid poles that were going to be deployed in the field as a demonstration project. SCE explained in its data request response that these particular costs will not be recurring costs, because the expenditure was inadvertently charged to O&M and should be a capital expenditure. The removal of these inadvertent O&M expenses would result in the reduction of $93,420 from recorded 2018 O&M expenses, not $31,150. SCE used a five-year historical average (2014 – 2018) to calculate the labor and non-labor forecasts for Technology Assessments in 2021. By excluding the $93,420 of non-labor recorded O&M expenses in 2018, SCE’s 2021 forecast will be decreased by $18,684 in 2021. SCE has reflected this reduction in its rebuttal position in Exhibit SCE-13, Vol. 04, Part 1.

SCE-21 pg. 6

Cal Advocates recommends the removal of $31,150.00 from 2018 recorded O&M non-labor expenses for Technology Assessment because SCE identified the amount as a capital cost, which SCE incorrectly recorded to the 2018 O&M expenses.

PAO-18, p. 11, lines 9-12

Jennifer Smith (SCE), Fransiska Hadiprodjo (PAO)



2021 Test Year

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PAO Position:

SCE Position: SCE does not dispute that the costs of approximately $567,000 were one-time costs; however, Cal Advocates’ recommendation that it “should be excluded for the purpose of forecasting” is incorrect. SCE did not use 2018 recorded costs to develop its forecast for non-labor expenses for T&D Deployment Readiness. As stated in SCE’s supporting workpapers, “the OCM Consultant 2019 - 2021 forecast is based on the need for approximately 5-6 consultant resources and 2 business analysts consultants each year and additional costs for an analyst needed to perform OCM workstream analysis.” Since these costs were not used in the development of SCE’s forecast, removing these costs would not impact SCE’s proposed 2021 forecast.

SCE-21 pg. 5

Cal Advocates recommends an adjustment of $567,159.06 from 2018 recorded O&M non-labor expenses for Grid Modernization – Transmission and Distribution (T&D) Deployment Readiness. Cal Advocates believes this amount should be excluded for the purpose of forecasting because SCE has identified it as a one-time cost.

PAO-18, p. 11, lines 4-7

Ilia Gueorguiev (SCE), Fransiska Hadiprodjo (PAO)



2021 Test Year

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PAO-132 | PAO Recommendations on Risk Informed Strategy and Business Plan


PAO Position:

SCE Position: SCE did include realistic alternatives in its RAMP Filing, and will continue to evolve its explorations of alternative Mitigation Plans in future RAMP filings. SCE appreciates the feedback provided by Cal Advocates, but respectfully notes that SCE’s careful and consistent reporting of two distinct alternative mitigation plans in each of its RAMP risk chapters was consistent with Commission requirements. PAO makes a generalized suggestion that some unstated number of SCE’s alternative mitigation plans were somehow “unrealistic.” But Cal Advocates does not provide any specific instances of such “unrealistic” alternatives, other than the hydro example that SCE addresses in detail in our rebuttal testimony in SCE-12 Vol. 02. Per the Commission’s direction and guidance, SCE’s RAMP presented, for each safety risk, two full alternative mitigation plans to the proposed plan that SCE ultimately chose. In each RAMP risk chapter, SCE explained in detail why the proposed mitigation plan was chosen, and why the alternative mitigation plans were not. Moreover, SCE also included a showing regarding certain safety-related risks that were ultimately not included in its RAMP report, and explained why each of these risks was not included.

SCE-12 Vol. 02 pp. 7 - 9

PAO’ second recommendation states that “SCE should identify and evaluate realistic mitigation plans that it considered during the RAMP Phase of its risk-informed decision-making process.”

PAO-14 p. 5, lines 3 - 5 and p. 7 lines 7 - 10

Robert LeMoine (SCE), Pui-Wa Li (PAO)



2021 Test Year

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TURN-133 | TURN Recommendations on Risk Informed Strategy and Business Plan-1


TURN Position:

SCE Position: Like TURN, SCE pays careful attention to the affordability of the services and benefits that SCE is providing to our customers. We are always striving to provide safe and reliable service of clean energy at reasonable cost. The affordability of SCE’s electric service is discussed at length in our opening testimony devoted to affordability, as well as addressed in considerable detail in Mr. Payne’s policy testimony, SCE-01 Vol. 01. SCE will consider, for its next GRC, whether a more specific discussion of affordability should also be included within the Risk-Informed Decision Making and Strategy testimony exhibit.

SCE-12 Vol. 02 pg. 10

TURN provides four recommendations in its testimony regarding SCE’s risk decision-making framework and risk modeling, and notes that the recommendations are “primarily for improvements that should occur in the utility’s subsequent RAMP or GRC filing.” The first recommendation is that the utility should transparently address in its RAMP and GRC risk analyses the issues of affordability and cost-effectiveness and identify how the utility has incorporated cost effectiveness into its proposals. TURN notes that in this proceeding, SCE’s risk chapter does not present any risk calculations, explain its prioritization or mention the term “affordability.” TURN also states SCE does not explain how it balances safety with the constraint of affordability.

TURN-02 pp. 30 - 31

Robert LeMoine (SCE), Eric Borden (TURN)



2021 Test Year

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TURN Position:

SCE Position: As stated in its testimony, SCE-01 Vol. 02 pg. 16, SCE continues to evolve its risk analysis methodology, along with its modeling capabilities. As TURN correctly points out, the “top down” system-wide risk modeling approach used as the basis of its 2018 RAMP filing and the “bottoms-up” approach used to inform covered conductor deployment are used for different purposes. In a data request response to TURN, SCE discussed the two distinct purposes of these models, and explained how the inputs themselves are different; accordingly, the outputs are directionally in alignment, but are not directly comparable. As SCE continues to refine, evolve, and improve its modeling capabilities, SCE will continue to seek opportunities to improve the consistency of these analyses, including mitigation effectiveness.

SCE-12 Vol. 02 pg. 10

TURN provides four recommendations in its testimony regarding SCE’s risk decision-making framework and risk modeling, and notes that the recommendations are “primarily for improvements that should occur in the utility’s subsequent RAMP or GRC filing.” The second recommendation is SCE’s “top-down” and “bottoms-up” risk analyses should be validated against each other to ensure consistent and verifiable wildfire risk modeling. TURN contends that, in this proceeding, rather than validating one another, the two analyses find different levels of risk reduction from the various mitigations deployed. TURN recommends that SCE incorporate the more granular analysis bottoms-up analysis into its next RAMP.

TURN-02 pp. 30 - 33




2021 Test Year

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SBUA-135 | SBUA Companywide Issue #1


SBUA Position:

SCE Position: SBUA’s recommendation that SCE be required to “re-file” its GRC “to reflect the drastic changes that have occurred to the California economy and associated energy use” is unjustified. The short-term effects of the global health crisis on SCE’s 2021-2024 forecast costs are unknown and unknowable at this point. But this Track 1 of SCE’s General Rate Case (GRC) will set a forecast revenue requirement for the company to fund the critical work necessary to safely maintain and operate the grid. The Commission has already taken wide-ranging proactive near-term steps to protect customers from the financial consequences of the health crisis, including a statewide moratorium on residential and small commercial disconnections. Any further such policy decisions to protect customers now should be carefully considered on a statewide basis, not litigated in a utility’s individual rate case setting a prospective base rates revenue requirement through 2024.

SBUA’s Direct Testimony pp. 1-2; pp. 5-6

SBUA recommends that the Commission order SCE to withdraw its present application and refile it with updated forecasts and assumptions that better fit the changed circumstances caused by the ongoing crisis. In its Response, SBUA clarifies its request as seeking “the filing of Supplemental Testimony by SCE to revise its Application where necessary to reflect conditions that differ substantially from last August when the Application was filed. The SCE update would reflect the drastic changes that have occurred to the California economy and associated energy use, as opposed to the current application that no longer reflects the current world or the most likely path going forward.

SBUA Revised Direct Testimony p. 7 and SBUA Response to Motion to Strike, p. 2

Douglas Snow (SCE), Richard McCann & Steven J Moss (SBUA)



2021 Test Year

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SBUA Position:

SCE Position: The Commission should not adopt SBUA’s proposal for the Commission to order SCE to “freeze all but essential utility investment,” a term which it only vaguely defines as “those that are determined to be immediately essential or directly linked to effectively differing [sic] utility investment that would otherwise have to be made in the next three years” It is not in customers best interests to “freeze” long-term capital investments that will have benefits for many decades to come due to what is hopefully a relatively short-term health-related economic downturn. Doing so would potentially lead to serious safety and reliability consequences (depending on how “essential” was defined) and could compromise SCE’s ability to provide safe, reliable, affordable and clean power. In addition, despite SBUA’s claim that it “fully supports the state’s and Commission’s efforts to address climate change,” it does not adequately explain how an investment “freeze” would allow the state to continue on its carbon-reduction trajectory to 2030, even if short-term carbon emissions are temporarily and artificially suppressed due to the current pandemic. Finally, it is unclear why SBUA’s load-growth-centric definition of “essentiality” should carry the day – there are other stakeholders in this proceeding that probably consider many of SCE’s other investments, that are completely unrelated to load growth, to be “essential” for their constituents.

SCE-22 pp. 3 - 4

In order to control SCE’s future revenue requirements in the near term during the pandemic crisis, SBUA proposes the Company freeze all but "essential" utility investment. SBUA advocates that essential investment should be limited to either: (a) activities required to maintain the existing system, which does not include additions in anticipation of load growth unlikely to occur in the near future, and (b) as part of a transformative process that could be seriously disrupted by a halt such as the minimal spending needed to maintain the path towards the state’s goal for mitigating climate change. Many of the activities funded by these investments or related activities conducted by others have already been stopped by the Governor’s COVID-19 executive order. SCE should not be authorized to expend funds for these activities if the activities are not happening. SBUA recommends that SCE should immediately identify which of its planned expenditures are tied to these types of activities and inform the Commission as to the amount that is being deferred by closure of the state’s economy.

SBUA Revised Direct Testimony pp. 27-28

Brent Fielder (SCE), Richard McCann & Steven J Moss (SBUA)



2021 Test Year

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SBUA Position:

SCE Position: SBUA acknowledges that “[n]ew technology – including storage, electric vehicle charging deployment, and distributed investment decisions, [] is being examined in the DRP and other proceedings.” That is where the consideration of such broad policy issues should remain. D.18-12-004 established the Distribution Investment Deferral Framework (DIDF). DIDF identifies and captures opportunities for DERs to cost-effectively defer or avoid traditional IOU investments that are planned to mitigate forecasted deficiencies of the distribution system. In January of 2020, a Second Amended Scoping Memo was issued in that proceeding that included in Track 1 consideration of “issues from the upcoming ruling requesting comments in improving the 2020 [DIDF] process” and in Track 3 consideration of the “[f]requency and process for future and ongoing revisions to Growth Scenario, [DIDF], and Grid Modernization frameworks and process.”

Motion of Southern California Edison Company To Strike Portions Of Opening Testimony Of Small Business Utility Advocates pp 12

SBUA recommends that SCE be required to prioritize deployment of beneficial, flexible, DERs in lieu of fixed distribution investments within its Grid Modernization program. Edison should develop a distribution investment protocol that is customer-focused and flexible to mitigate immediate impacts on small firms. DERs can meet consumer energy needs and provide valuable services to electricity grids, providing multiple benefits to customers, utilities, and grid operators.

SBUA Revised Direct Testimony p. 29

Ilia Gueorguiev (SCE), Richard McCann & Steven J Moss (SBUA)



2021 Test Year

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SBUA-138 | SBUA Companywide Issue #4 and #5


SBUA Position:

SCE Position: SBUA’s load forecasting recommendations are in direct conflict of the DRP Proceeding, the DRP requirement that SCE use the demand forecast from the CEC’s Integrated Energy Policy Report (IEPR), the stakeholder process held by the CEC to develop the IEPR demand forecast, and the outcome of the multi-party Demand Forecasting Working Group that vetted SCE’s method for disaggregating the system-wide forecast from the CEC to the individual circuits within SCE’s distribution system. On August 1, 2018, the Administrative Law Judge “ruling affirms that the Distribution Forecasting Working Group Progress Report (Progress Report) has met the requirements established in D.18-02-004, Decision on Track 3 Policy Issues, Sub-Track 1 (Growth Scenarios), and provides direction on future documentation and review of distribution forecasting methodologies.” The disaggregated DER and demand growth that SCE used to develop its 2021 GRC request was affirmed in the above ALJ ruling and the details can be found in the Planning Assumptions sheets within the 2019 GNA. The summary of the disaggregation methodology taken from the GNA Narrative directly was added to testimony workpapers through an errata submission in November 2019. This growth is added to the starting point discussed in the following section to produce SCE’s load forecast. As stated in testimony, “SCE also incorporates additional load growth that may not have been fully reflected in the CEC forecast.” SCE defines these projects as incremental load growth. The incremental load growth categories include: cultivation, LEV superchargers, mega tract homes, and agricultural pump loads. Since these categories were not included in the CEC 2017 IEPR forecast, the total load growth in the system may intentionally exceed the IEPR forecast. It is in the best interest to SCE’s customers to include consideration of these incremental projects when planning for future system needs in order to reduce the risk of overloading the system.

SCE-13 Vol. 04 Pt. 2 pp. 17 - 18

SBUA recommends that the Commission should order SCE to provide a fully transparent set of workpapers and analyses that compares and accurately explains the reasons for load forecasting disparities, including an empirically-based rationale for why SCE chooses to diverge from state policy on demand forecasts. Further, to address this systematic problem either SCE must; (1) present an empirically defensible set of criteria and underlying data beyond load forecasts to enable parties to effectively evaluate distribution system investments, with adequate time in this proceeding to fully vet these benchmarks, (2) recover investments proportionately to the utilization rate of those additions over time so that SCE has an incentive to “right size” such investments, or (3) forego making these investments until a new method can be developed to evaluate their prudency, including a demonstration of urgency that precludes the usual periodic rate case review.

SBUA Revised Direct Testimony, p. 20

Dana Cabbell (SCE), Richard McCann & Steven J Moss (SBUA)



2021 Test Year

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SBUA Position:

SCE Position: The appropriate venue for any such analysis is in the DRP OIR and in the IDER OIR. Issues within the IDER include “1) Design, for Commission consideration and adoption, alternative [DER] sourcing mechanisms or approaches that satisfy distribution planning objectives; and 2) Consider how existing programs, incentives, and tariffs can be coordinated to maximize the locational benefits and minimize the costs of distributed energy resources.”

Motion of Southern California Edison Company To Strike Portions Of Opening Testimony Of Small Business Utility Advocates pp 12- 13

Based upon SBUA review, it appears that SCE is treating its overall authorization as a pool of funds that it can spend in any manner that it wants. Edison pulls from one pot of funds to make expenditures in another pot and fails to control costs in areas such as maintenance, where it has relative stabile requirements. Therefore, SBUA recommends the Commission order SCE to refile its distribution investment plan to align its load growth planning with adopted load forecasts and shift funds to grid modernization to facilitate DER deployment. SCE’s spending in other categories should be subjected to an audit to determine if the activities are defensible and appropriate cost controls used.

SBUA Revised Direct Testimony, pp. 23-24




2021 Test Year

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SBUA Position:

SCE Position: The Commission’s Public Advocates Office has already undertaken a more-than-nine-month period of review in its traditional comprehensive audit related to this GRC, during which they served some 900 data requests and which included several thousands of supporting documents. In addition to data request responses, the Public Advocates’ Audit also included on-site review with presentations, interviews, and the review of the following additional information (among others): Board of Director Minutes, Audit Committee Minutes, Finance Committee Minutes, Internal Audit Report selections, Review of External Auditor (PwC) workpapers, and the compilation of a GRC Binder which includes details of reconciliation of the GRC data for 2018 from FERC Form 1 amounts to the GRC Application data.

Motion of Southern California Edison Company To Strike Portions Of Opening Testimony Of Small Business Utility Advocates pp 9 - 10

SBUA has found serious discrepancies in past utility spending that raises legitimate concerns. As such, SBUA recommends the Commission order an audit of SCE's spending in other categories to determine if the activities are justified and appropriate cost controls are in place. SCE believes that the Public Advocates Office is the only party with the right to propose alternative reasonableness approaches. This belief insults the integrity of due process and, if adopted, would hobble parties’ ability to participate effectively in proceedings. The fact that the Public Advocates conducted work in this area is irrelevant. SBUA’s recommendation is not a duplicative effort, but rather additive.

SBUA Revised Direct Testimony, p. 5; SBUA Response to Motion to Strike, p. 13




2021 Test Year

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SBUA Position:

SCE Position: SCE must meet customers’ foundational expectations for safe and reliable electric service. Accordingly, SCE plans for forecast peak loading to enable the distribution system to serve its customers when the electricity will be needed. Basing recovery on percent of utilization undercuts the principles in preparing the distribution system to be ready for foreseeable peak loading events. The electric utility industry plans for, invests, and operates high voltage equipment that, without proper safety precautions, can pose significant public safety hazards to employees and to the general public. SCE conducts extensive engineering and technical evaluations to ensure the equipment it energizes is safe for operational use and can withstand the stresses of high voltage electricity. Attempting to “right-size” every distribution component to the projected level of need raises safety concerns by introducing non-standard equipment and equipment arrangements. Distribution investments must meet SCE’s standards for safety and reliability. Additionally, trying to “right-size” equipment can lead to higher costs in customized equipment procurement. SBUA’s proposal – to base cost recovery of distribution investments on utilization rates – would introduce adverse consequences for utilities who plan their system with safety and reliability as top priorities. SCE invests in distribution equipment precisely to meet these priorities. These investments are used and useful, provide benefits to customers, and allow for the system to accommodate anticipated and unanticipated extreme events that can and do stress the electric grid.

SCE-13 Vol. 04 Pt. 2 pg. 23

SBUA proposes that SCE should calculate each circuit and substation the ratio of recorded peak usage to the rated capacity net the allowed margin, and multiply that by the dollar amount invested in each circuit and substation. Under SBUA’s recommendation, SCE is incented to only invest in circuits and substations that truly are nearing capacity. In addition, SCE can often restructure its network in a manner that shifts demand to better use total area capacity, but it has no real incentive to do so now—this would further incent this practice. As it stands now, ratepayers carry all of the risk of growth failing to materialize and use the installed capacity. SBUA’s proposal would shift a portion of that risk to Edison shareholders.

SBUA Revised Direct Testimony, pp. 21-22




2021 Test Year

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Issue Title:





SBUA Position:

SCE Position: To accomplish this, SBUA recommends that SCE’s “revenues be scaled to infrastructure utilization rates.” In other words, for example, if a piece of infrastructure’s peak usage is 70% of its rated capacity, then SCE would be able to recover less than 100% of its investment in that infrastructure. Setting aside how impractical such a proposal is and the perverse incentives it would provide for SCE to overload equipment, more basically SBUA’s proposal would fundamentally change how utility ratemaking is effectuated and turn the century-old “used and useful” doctrine on its head.

Motion of Southern California Edison Company To Strike Portions Of Opening Testimony Of Small Business Utility Advocates p. 9

SBUA recommends that the Commission should order SCE to provide a fully transparent set of workpapers and analyses that compares and accurately explains the reasons for load forecasting disparities, including an empirically-based rationale for why SCE chooses to diverge from state policy on demand forecasts. Further, to address this systematic problem either SCE must; (1) present an empirically defensible set of criteria and underlying data beyond load forecasts to enable parties to effectively evaluate distribution system investments, with adequate time in this proceeding to fully vet these benchmarks, (2) recover investments proportionately to the utilization rate of those additions over time so that SCE has an incentive to “right size” such investments, or (3) forego making these investments until a new method can be developed to evaluate their prudency, including a demonstration of urgency that precludes the usual periodic rate case review.

SBUA p. 20




2021 Test Year

Cost Component:

Witness:

Issue Title:



TURN-146 | Affordability


TURN Position:

SCE Position: SCE’s proposed rate increases, while significant, are necessary to provide our customers with safe and reliable service, including a reduction of wildfire risk. Additionally, examining various affordability metrics collectively, rather than cherry-picking certain metrics as TURN does, demonstrates that SCE’s requests in this GRC and other proceedings produce affordable bills for those customers consuming electricity within the “essential usage” “baseline” amount.

SCE-18, Vol. 04, pp. 1 -11

SCE’s requested revenue increase wipes out a decade of customer income growth. The magnitude of SCE’s proposed rate increase coupled with SCE’s historic disconnection practices likely results in an increase in shutoffs. SCE’s current level of rates already necessitate monthly tradeoffs.

TURN-03-E, pp. 6-17

Robert Thomas (SCE), Jennifer Dowdell (TURN)



2021 Test Year

Cost Component:

Witness:

Issue Title:



TURN-147 | Relationship Between Rate Increases and Customer Disconnections and Arrearages


TURN Position:

SCE Position: SCE’s regression analyses did not find a meaningful relationship between increases in SCE’s average rates or bills, and the number of residential disconnections or amount of monthly arrearages over time.

SCE-18 Vol. 05

SCE’s conclusion that disconnections are unrelated to rates is not credible and must be rejected based on TURN's preliminary regression analysis and other data.

TURN-03-E, pp. 20-27

Robert Thomas (SCE), Jennifer Dowdell (TURN)



2021 Test Year

Cost Component:

Witness:

Issue Title:



NDC-148 | Consumer Affairs Complaints and Inquiry Tracking


NDC Position:

SCE Position: SCE's Consumer Affairs organization already tracks inquiries and complaints it receives by type and channel (e.g., written, telephone, informal, and social media (in aggregate)). Although SCE does not track social media inquiries by language, the overwhelming majority received are in English or Spanish.

SCE-14, pp. 40-41

NDC recommends that SCE track and report in future testimony Consumer Affairs complaints and inquiries by channel and language to aid in analyzing the effectiveness of SCE’s outreach activities and any planned improvements for the benefit of underserved SCE customers. NDC is not recommending a forecast reduction to this area.

NDC-1, pp. 29-30

Alfred Ochoa (SCE), Faith Bautista (NDC)



2021 Test Year

Cost Component:

Witness:

Issue Title:



PAO-149 | COVID-19 Capital Expenditure Adjustment


PAO Position:

SCE Position: The proposed adjustment by PAO is premature. No stakeholder knows about what the ultimate impacts of the pandemic will be, and the lack of evidence accompanying PAO's proposal illustrates that it is not possible to gauge this with any accuracy. The 25% figure suggested by PAO is arbitrary and unsupported. Moreover, the Commission and stakeholders are already taking measures to address the effects of COVID-related changes. SCE records incremental COVID- related costs to the Catastrophic Event Memorandum Account (CEMA) and intends to account for savings that are a direct result of governmental pandemic directives. These savings will offset CEMA costs, and SCE also records uncollectibles above GRC-authorized levels in the Commission-authorized COVID Pandemic Protections Memorandum Account (CPPMA). If any later adjustments need to be made, they can occur through ratemaking mechanisms outside the GRC and should not further delay timely processing of this GRC.

SCE-12, Vol. 1, Page 11

PAO proposes a $125 million adjustment to SCE's 2020 capital expenditure forecast, based upon the recent economic downturn associated with the COVID-19 pandemic. This $125 million reduction should be made by reducing capital expenditures for New Service Connections and Customer Requested Projects by 25%, and it is a reasonable reflection of economic conditions despite lack of exact information on pandemic impacts.

PAO-01, Page 8

Kevin Payne (SCE), Truman Burns (PAO)



2021 Test Year

Cost Component:

Witness:

Issue Title:



PAO-150 | PAO Recommendations on Risk Informed Strategy and Business Plan


PAO Position:

SCE Position: PAO cites Decision D.16-08-018, which is an interim decision. The Commission’s later decision in D.18-12-014 adopted the S-MAP Settlement Agreement with modifications. In its “Conclusions of Law,” the decision stated that the “Long Term Road Map that outlines steps to continue to migrate from relative risk scoring to more quantitative methods of optimized risk mitigation, as detailed in Section 5 of this decision, should be adopted subject to further consideration in a subsequent Order Instituting Rulemaking.” SCE looks forward to working with parties in the forthcoming S-MAP OIR that will specifically address this topic. Prior to Commission guidance on this topic from the forthcoming OIR, PAO’ recommendation appears to be premature.

SCE-12 Vol. 02 pg. 4

SCE should clearly identity and quantify the key constraints it considered when selecting its risk programs. PAO also asserts that SCE does not describe the constraints in sufficient detail to explain how they impacted SCE’s choice of risk mitigation activities for purposes of fulfilling risk mitigation objectives. PAO recommends that SCE identify and quantify the key constraints in further detail.

PAO-14 pp. 1-4

Robert LeMoine (SCE), Pui-Wa Li (PAO)



2021 Test Year

Cost Component:

Witness:

Issue Title:





TURN Position:

SCE Position: SCE used a timeless unconditional probability calculation for the Wildfire Risk model. A timeless unconditional probability, in its simplest terms, refers to a probability that is unaffected by preceding or future occurrence of other events, and is not limited to a specific time period or duration for the event to occur. TURN incorrectly states that “the probability calculation was originally intended to represent the annual probability of ignition, but the utility was not able to accomplish this.” There is no requirement that the probability calculation be an annual one. In fact, the S-MAP settlement agreement defines Likelihood or Probability as “the relative possibility that an event will occur, quantified as a number between 0% and 100% (where 0% indicates impossibility and 100% indicates certainty).” SCE’s probability calculation is between 0% and 100%.

SCE-12 Vol. 02 pg. 12

TURN provides four recommendations in its testimony regarding SCE’s risk decision-making framework and risk modeling, and notes that the recommendations are “primarily for improvements that should occur in the utility’s subsequent RAMP or GRC filing.” The third recommendation is that SCE’s probability calculations must be calculated over a specific period in time, a year or another relevant time period, rather than reflect, in TURN’s words, an instantaneous probability. TURN states that an instantaneous probability cannot reflect the likelihood of ignition as the probability of an ignition cannot be the same in a rainstorm as in windy, dry weather.

TURN-02 pp. 30 - 31, 35




2021 Test Year

Cost Component:

Witness:

Issue Title:



PAO-158 | Adjustment to O&M Work Order Related Expense

Company-Wide

PAO Position:

SCE Position: SCE agrees with PAO’s proposal to adjust Work Order related expense based on the adopted level of capital expenditures.

SCE-13, Vol. 7, pp. 4-5

Work Order related expense should be based on the adopted level of capital expenditures.

PAO-08, p. 41

Tracee Reeves (SCE), Dao Phan (PAO)



2021 Test Year

Cost Component:

Witness:

Issue Title:





TURN Position:

SCE Position: SCE appreciates TURN’s recommendation to incorporate an egress score by circuit and circuit segment in its wildfire risk model. SCE believes that qualitative factors, such as population egress and social vulnerability, could prove useful in targeting programs to specific locations. SCE plans to explore options to incorporate these conditional risk considerations in future risk modeling. However, SCE stresses that the methodology SCE may employ may differ somewhat from that of PG&E. In lieu of scoring individual circuit segments, SCE is working toward a methodology to score only the upstream portion of individual circuits in which there may be an egress issue. This will allow SCE to also develop a more holistic approach to target circuit sectionalization and help minimize the need for undergrounding and PSPS outages. Rather than apply a quantitative score to a specific circuit segment, SCE may choose to examine egress challenges associated with the entirety of particular circuits or subdivide geographic areas to represent areas of concern.

SCE-12 Vol. 02 p. 14

TURN provides four recommendations in its testimony regarding SCE’s risk decision-making framework and risk modeling, and notes that the recommendations are “primarily for improvements that should occur in the utility’s subsequent RAMP or GRC filing.” The fourth recommendation is that SCE’s consequence estimates should incorporate egress. TURN recommends that SCE explicitly incorporate egress by quantitatively estimating and ranking this attribute across the utility HFRA. This may help target programs like undergrounding to the areas with a high consequence of fire and an inability to quickly evacuate.

TURN-02 pp. 30 - 31, 35




2021 Test Year

Cost Component:

Witness:

Issue Title:




Company-Wide

SCE Position: The Commission authorized SCE to capitalize wildfire-related liability insurance premiums in prior GRCs. Several years are remaining under status quo recovery of the cost of these capitalized premiums. FERC requires expensing, not capitalizing, the cost of the “standalone” or “bifurcated” wildfire insurance premiums, but acknowledges that to the extent that certain wildfire costs are recoverable in future periods in CPUC- jurisdictional rates, the utilities may defer the costs, as appropriate, in a regulatory asset. SCE proposes to recover its regulatory asset over the current GRC cycle. Should the Commission order recovery over the GRC cycle, as SCE proposes, then it is reasonable for SCE to continue to earn a return for that period.

SCE-17, Vol. 02, pp. 34-36

April Li (SCE), Mark Waterworth (PAO), Robert Finkelstein (TURN)

PAO Position:

TURN Position:

PAO states that in SCE’s 2018 GRC, the Commission made the determination to capitalize the wildfire insurance premiums, and the Commission is not mandated to follow FERC guidance. In addition, SCE’s proposal provides no evidence that changing the current treatment has any benefit to ratepayers.

PAO-10, Part 1, pp. 23 - 24

TURN’s position is that there is nothing in the FERC order that requires expensing, not capitalizing, stand-alone wildfire insurance premiums. Instead, the FERC order provides that capitalization is acceptable if the insurance costs “are recoverable in future periods in CPUC-jurisdictional rates,” which is the case given SCE’s regulatory asset for such costs. The Commission should deny the proposed acceleration in its entirety. If the acceleration is authorized, an outcome TURN vigorously opposes, the Commission should reject SCE’s proposed return on the uncollected amount during this GRC period, and instead treat the $95 million as an expense to be amortized over the GRC cycle with no further return.

TURN-01, pp. 20 - 23



2021 Test Year

Cost Component:

Witness:

Issue Title:



PAO-TURN-121 | Establishment of the Vegetation Management Balancing Account (VMBA)


SCE Position: SCE proposes to create a new two-way balancing account, the Vegetation Management Balancing Account (VMBA) to record the difference between recorded vegetation management O&M expenses and authorized vegetation management O&M expenses, including routine and wildfire-related (Dead, Dying, and Diseased Tree Removal and Hazard Tree Mitigation Program (HTMP)) vegetation management activities. Consolidating of all VM program costs into a single balancing account eliminates potential operational overlap and reduces potential confusion. Consolidating all of the vegetation management program costs into a single balancing account eliminates potential operational overlap and reduces potential confusion necessitated by reporting each recovery mechanism separately. Alternatively, if the Commission is inclined to require an after-the-fact reasonableness review of above-authorized vegetation management costs, SCE proposes the authorization of a balancing account with a soft cap of 120%.


Desiree Wong (SCE), Tamera Godfrey (PAO), Robert Finkelstein (TURN)

PAO Position:

TURN Position:

PAO recommends that SCE establish a two-way VMBA with an expense level of $176.1349 million for its vegetation management program O&M expenses in the Test Year (TY) and a required reasonableness review for costs in excess of SCE's TY forecast of $216.935 million.

PAO-06, Page 47

TURN recommends that the Commission reject SCE's proposal for a two-way VMBA, both as presented in SCE’s direct testimony and the alternative proposal presented for the first time in rebuttal testimony. TURN’s testimony in TURN-02 recommended a one-way balancing account specifically for the Hazard Tree Mitigation Program (HTMP) and no balancing account treatment for SCE’s Routine Vegetation Management and Dead, Dying, and Diseased Tree Removal programs; however, that recommendation is evolving and TURN’s final position will be as set forth in its briefs. As a general matter, SCE’s reliance on two-way balancing accounts in this GRC proceeding would effectively assign to ratepayers the entire cost recovery risk, an outcome that is inconsistent with forecast-based ratemaking or memorandum accounts subject to after-the-fact reasonableness review. Annual “compliance” reviews of the VMBA in the ERRA review would be an inadequate substitute for a reasonableness review. If there is a legitimate purpose to be achieved through consolidation of the existing vegetation management accounts, the Commission should consider creating a consolidated memorandum account.

TURN-01, pp. 24 - 27



2021 Test Year

Cost Component:

Witness:

Issue Title:



PAO-TURN-122 | Establishment of the Risk Management Balancing Account (RMBA)


SCE Position: SCE proposes to create a new two-way balancing account, the Risk Management Balancing Account (RMBA) to record the difference between recorded insurance premium expense for wildlife liability coverage and the authorized insurance premium expenses adopted in this proceeding. Sharing of this cost between customers and shareholders is inconsistent with AB 1054, existing Commission precedent, and long-standing cost-of- service principles of ratemaking. SCE's forecast of 2021 wildfire liability insurance cost reflects the forecast costs of maintaining $1 billion in coverage.


Desiree Wong (SCE), Mark Waterworth (PAO), Robert Finkelstein (TURN)

PAO Position:

TURN Position:

PAO does not oppose the establish of the RMBA, but its position is contingent upon the sharing of wildlife insurance premiums between customers (75%) and shareholders (25%). The PAO believes that the RMBA should be created with the provision that the 75/25 sharing is also captured in this account for the duration of the 2021-2023 time frame.

PAO-10, Page 22

TURN opposes the establishment of the RMBA. As a general matter, SCE’s reliance on two-way balancing accounts in this GRC proceeding would effectively assign to ratepayers the entire cost recovery risk, an outcome that is inconsistent with forecast-based ratemaking or memorandum accounts subject to after-the-fact reasonableness review. Annual “compliance” reviews of the RMBA in the ERRA review would be an inadequate substitute for a reasonableness review. This is especially a concern for the RMBA, as it would mean that SCE’s decisions going forward regarding reliance on alternative risk transfer instruments such as catastrophe bonds and self-insurance are never reviewed for reasonableness. Furthermore, SCE has already requested and been provided the Wildfire Expense Memorandum Account (WEMA), which exists in part to permit the utility to track and later seek rate recovery of above-authorized wildfire liability insurance costs, based on a demonstration of reasonableness.

TURN-01, Pages 24-25, 26-27



2021 Test Year

Cost Component:

Witness:

Issue Title:



PAO-CUE-123 | Modification of the Safety and Reliability Investment Incentive Mechanism (SRIIM)


SCE Position: SCE proposes to maintain the 2018 GRC SRIIM over the 2021 GRC cycle, with proposed modifications to both the workforce and capital investment components.

SCE-18 Vol. 1, Page 25; SCE-13, Volume 02, Part 3

Gary Trumbo (SCE), Tamera Godfrey (PAO), Robert Earle (CUE)

PAO Position:

CUE Position:

PAO recommends that SCE's proposal to change SRIIM headcount target and headcount measurement mechanism that were adopted in 2018 be denied. SCE should continue the SRIIM as adopted in SCE's 2018 GRC, with the only exception being the modification to Workforce Categories. PAO agrees with SCE's proposal to remove the job classifications of Distribution Apprentice Groundman and Transmission Apprentice Groundman from these categories and include job classifications of Distribution Apparatus Technician and Distribution Apparatus.

PAO-06, Page 69

CUE agrees to SCE’s proposed changes to the workforce classification. CUE recommends that the Commission approve SCE's SRIIM capital spending proposal subject to the Commission eliminating the headcount target adjustment mechanism. CUE also recommends that the Commission increase the SRIIM headcount target to 2,608, eliminate the headcount adjustment mechanism, and reject SCE’s proposal to modify the headcount measurement mechanism by using the highest headcount over the last two quarters of the GRC cycle. CUE recommends the Commission continue to measure headcount by the average headcount for the last quarter of the GRC cycle. CUE recommends PAO’s proposal on the SRIIM headcount target be rejected.

CUE-01, Page 6, 30-37; CUE-02, Page 7



2021 Test Year

Cost Component:

Witness:

Issue Title:



PAO-TURN-154 | Interest on Customer Deposits

Company-Wide

SCE Position: The Commission considered the treatment of CDs for SDG&E and SoCalGas in Sempra’s 2019 GRC, issuing a final decision D.19-09-051 that adhered to the ratemaking principles for CDs set forth in SP U-16. SP U-16 excludes interest-bearing accounts such as CDs from working cash. Based on this determination, D.19-09-051 authorizes SDG&E and SoCalGas to exclude interest-bearing CDs from working cash. SCE's ratemaking treatment for CDs should not be different than the treatment provided to SDG&E’s and SoCalGas’ CDs, particularly given that the majority of SoCalGas’ customers are the same as SCE’s customers. Extending D.19-09-051 findings on this issue to SCE’s CDs would ensure the ratemaking treatment for CD is being applied fairly and equally to SoCalGas’ and SCE’s common customers.

SCE-18 Vol. 02, pp. 37 - 42

Jonathan Rumble (SCE), Fidel A. Leon Diaz (PAO), Jennifer Dowdell (TURN)

PAO Position:

TURN Position:

Cal Advocates suggests that CDs for SCE be treated in the same manner as they are for PG&E as “established in D.14-08-032 and continued by the Settlement terms approved in D.17-05-013.” Specifically, that CDs be treated as an offset to long-term debt, proposing that the forecast amount of CDs be reflected in the capital structure as a form of low-cost debt and adjusting SCE’s revenue requirement accordingly.

PAO-15C, p. 14

TURN does not believe that the Commission intended its treatment of Sempra to indicate a policy change given SDG&E and SoCal are in very different positions than SCE due to the under-collections in their balancing accounts. TURN recommends that SCE be required to continue to account for Customer Deposits as an adjustment to working capital and offset to rate base.

TURN-03, p. 51



2021 Test Year

Cost Component:

Witness:

Issue Title:



PAO-TURN-165 | 2019 Recorded Capital Expenditures

Company-Wide

SCE Position: SCE recommends updating 2019 forecast capital expenditures with recorded figures that became known during the pendency of the GRC proceeding. Updating to recorded capital expenditures for the first forecast year for all capital expenditures is principled and is consistent with Commission practice in the last three rate cases.

SCE-12, Vol. 1

Douglas Snow (SCE), Various (PAO), Various (TURN)

PAO Position:

TURN Position:

With the exception of certain areas, PAO developed its 2019 forecast capital expenditures using recorded values.

TURN’s position on 2019 capital expenditures is as set forth on the JCE page on each specific project involving 2019 capital expenditures that TURN addressed.



2021 Test Year

Cost Component:

Witness:

Issue Title:



PAO-TURN166 | Renewed Requests for Project Funding - Grid Modernization


SCE Position: To SCE’s knowledge, the Commission has never ordered a utility to continue to expend funds on a capital project found to be used and useful for customers, yet be precluded from recovery of those prudent capital expenditures. In this case, intervenors have proposed that amounts incurred above SCE’s 2018 GRC levels for Grid Modernization E&P Tools and the GMS be funded by shareholders even though the investments are beneficial and necessary on behalf of customers. Both the intervenors and the Commission have concluded that these capital investments are in alignment with and driven by evolving compliance requirements of the Commission’s DRP proceeding. Cal Advocates’ proposal violates a fundamental principle that has long guided ratemaking by the Commission: utilities are obligated to provide safe, reliable service, and in exchange they have the opportunity to earn a reasonable rate of return on their prudent capital expenditures. SCE’s 2018 GRC Grid Modernization forecasts reflected the information that was reasonably available at the time of filing in September 2016. As described in SCE-13 Vol. 04 Pt. 1, the fact that SCE’s forecast has increased since the 2018 GRC due to changing DRP compliance requirements and the unanticipated complexity of implementation for these projects does not constitute imprudence. Parties have proposed to disallow all rate recovery for capital expenditures on these projects above SCE’s 2018 GRC authorized levels. Quite simply, this would be a penalty, yet there is no allegation, much less proof, that such expenditures are imprudent.

SCE-13, Vol. 4, Pt. 1, pp. 5-8

Brent Fielder (SCE), Thomas Roberts (PAO), Garrick Jones (TURN)

PAO Position:

TURN Position:

The Commission should deny funding for a number of requested capital projects on the grounds that these projects were already authorized in prior GRCs. The PAO recommends that SCE shareholders, rather than ratepayers, fund any remaining work required to provide the functionality described in previous GRCs.

PAO-5P, p. 34

Supports PAO’s ratemaking recommendations regarding the GMS and the E&P Tools—specifically, that the Commission authorizes a 2019-2021 forecast of $106.244 million, with $35.724 million and $37.456 million in 2020 and 2021, respectively, for the GMS; and a forecast of $1.634 million in 2019-2021 for the E&P Tools with $0 in both of 2020 and 2021. TURN further supports PAO’s recommendation that these amounts constitute full funding to deploy the GMS and E&P Tools.

TURN-04, pp. 4 - 5



2021 Test Year

Cost Component:

Witness:

Issue Title:




2021$ in Thousands

PAO-TURN-134 | Post-Test Year Ratemaking (PTYR) - Primary (Illustrative Impacts)

PAO Position:

SCE Position:

SCE-07, Vol. 04A, pp. 25-26; SCE-07, Vol. 04A, pp. 25-26, 28-30

SCEItem / Forecast Year PAO TURN TURN vs SCE

PAO vs SCE

PAO-17, p. 11

TURN Position:

TURN-07E2, pp. 2, 16, 20

Jonathan Rumble (SCE), Truman L. Burns (PAO), Catherine Yap (TURN)

Capital: Adopt capital-related cost increases using SCE’s Board-reviewed capital budget, bifurcated between wildfire and non-wildfire capital additions.

O&M: Escalate O&M expense using the same price indexes that SCE uses to escalate its O&M expense from recorded year 2018 to the test year 2021.

Primary Position: Escalate total revenue requirement by 3.5% for 2022 and by 3.5% for 2023, derived from a recent forecast of the Consumer Price Index – Urban (CPI-U) for 2022-2023 with an additional premium.

Capital: Adopt TURN’s budget-based capital additions proposal for wildfire mitigation and residential and commercial new service connections. Adopt zero escalation for all other non-wildfire capital additions.

Primary O&M Position: Escalate O&M expense by CPI-U, currently forecasted as 2.3% and 2.5% for 2022 and 2023.

Company-Wide Ratemaking

Post Test Year Ratemaking (PTYR)

2022 Forecast

2023 Forecast

8,103,887

8,633,602

7,911,927

8,188,845

7,016,496

7,354,585

(191,960)

(444,757)

(1,087,391)

(1,279,017)

Total 16,737,489 16,100,772 (636,717) 14,371,081 (2,366,408)



2021 Test Year

Cost Component:

Witness:

Issue Title:




2021$ in Thousands

PAO-TURN-160 | Post-Test Year Ratemaking (PTYR) - Alternative (Illustrative Impacts)

PAO Position:

SCE Position:

SCE-07, Vol. 04A, pp. 25-26; SCE-07, Vol. 04A, pp. 25-26, 28-30

SCEItem / Forecast Year PAO TURN TURN vs SCE

PAO vs SCE

PAO-17, pp. 16-17

TURN Position:

TURN-07E2, pp. 2, 17 - 18

Jonathan Rumble (SCE), Truman L. Burns (PAO), Catherine Yap (TURN)

Capital: Adopt capital-related cost increases using SCE’s Board-reviewed capital budget, bifurcated between wildfire and non-wildfire capital additions.

O&M: Escalate O&M expense using the same price indexes that SCE uses to escalate its O&M expense from recorded year 2018 to the test year 2021.

Alternative Position: Escalation of capital additions by 2.3% for 2022 and by 2.3% for 2023; Escalation of O&M expenses using SCE’s proposed methodology.

Capital: Adopt TURN’s budget-based capital additions proposal for wildfire mitigation and residential and commercial new service connections. Adopt zero escalation for all other non-wildfire capital additions.

Alternative O&M Position: Escalate O&M expenses by CPI-U plus 50 basis points.

Company-Wide Ratemaking

Post Test Year Ratemaking (PTYR)

2022 Forecast

2023 Forecast

8,103,887

8,633,602

7,911,927

8,188,845

7,025,473

7,373,027

(191,960)

(444,757)

(1,078,414)

(1,260,575)

Total 16,737,489 16,100,772 (636,717) 14,398,500 (2,338,989)



Chapter 3 | Summary Of Differences

115



116


2021 Test Year

Exhibit:

Cost Component:

BPG:

Witness:

Issue Title:




2018$ in Thousands

PAO-48 | Alternative forecast for Distribution Overhead Detailed Inspections

O&M


Terry Ohanian (SCE), Tamera Godfrey (PAO)

SCE's forecast is based on 2018 recorded costs, excluding costs incurred by Enhanced Overhead Inspections (EOI) in SCE’s High Fire Risk Area. SCE also proposes an alternative forecast of $6.551 million, which is equivalent to SCE’s 2018 recorded expenses less infrared inspection recorded costs, should the Commission not approve SCE’s full funding request for EOI activities.

SCE-13 Vol. 01, Part 2, p. 6

PAO Position: Adopts SCE's alternative forecast, stating that SCE’s 2018 recorded adjusted expenses is the best representation of forecasted work, and that SCE’s 2018 expenses for Distribution Overhead Detailed Inspections already include costs embedded in rates for ongoing EOI projects.

PAO-06, p. 19

SCE Position:


SCEFERCAccount

BPEGRC Activity

PAO vs SCE

PAO

580 | Distribution Overhead Detail Inspections

Labor 761 553 1,314

Non-Labor 331 (201) 130

1,092Total 352 1,444


Labor 2,564 788 3,352

Non-Labor 1,021 513 1,534

3,585Total 1,301 4,886


Labor 68 (25) 43

Non-Labor 130 48 178

198Total 23 221

Distribution Overhead Detail Inspections: 4,875 1,676 6,550

Southern California Edison Chapter 3, Section 1117


2021 Test Year

Exhibit:

Cost Component:

BPG:

Witness:

Issue Title:




2018$ in Thousands

PAO-49 | Distribution Preventive and Breakdown O&M Maintenance

O&M


Terry Ohanian (SCE), Tamera Godfrey (PAO)

SCE’s forecast is based on a four-year average of 2014 to 2017 recorded costs, plus the costs of Priority 3 maintenance items, and subtracting costs performed under the EOI program.

SCE-13 Vol. 01, Part 2, p. 10

PAO Position: PAO proposes using a five-year average of 2014-2018. The Public Advocates Office opposes SCE’s method utilized to calculate its TY forecast because it lacks substantiated estimates for proposed TY activities.

PAO-06, pp. 21, 22, 24, 27

SCE Position:


SCEFERCAccount

BPEGRC Activity

PAO vs SCE

PAO

588 | Distribution Preventive and Breakdown O&M Maintenance

Labor 23 0 23

Non-Labor 12 0 12

35Total 0 35


Labor 19,214 400 19,614

Non-Labor 22,122 (1,798) 20,324

41,335Total (1,397) 39,938


Labor 25,794 (3,607) 22,187

Non-Labor 34,849 (3,561) 31,288

60,643Total (7,168) 53,475


Labor 2,955 0 2,955

Non-Labor 1,551 34 1,585

4,506Total 34 4,540


Labor 22 0 22

Non-Labor 698 16 714

720Total 16 736

Distribution Preventive and Breakdown O&M Maintenanc 107,239 (8,515) 98,724



2021 Test Year

Exhibit:

Cost Component:

BPG:

Witness:

Issue Title:




2018$ in Thousands

PAO-51 | IT Project Support O&M

O&M

Grid Modernization

Timothy Boucher (SCE), Monica Weaver (PAO)

SCE’s non-labor forecast of $4.577 million is an itemized forecast based on actual contractual pricing and negotiations with selected vendors. The increases from 2018 to 2021 include vendor contract costs planned for the GIPT and GMS workstreams and for IT-related change management. The use of an itemized forecast for 2021 provides support for the expenses SCE actually expects to incur in 2021 in this work activity based on negotiated and contractual agreements.

SCE-02 Vol. 04, Pt. 1, pp. 24 - 26; SCE-13, Vol. 04, Pt. 1, pp. 62 - 65

PAO Position: PAO recommends $2.473 million the non-labor forecast compared to SCE’s forecast of $4.577 million. PAO used a three-year average of 2017-2019 expenses compared to SCE’s forecast methodology, which have varied significantly throughout the years.

PAO-07, Part 2, p. 11

SCE Position:


SCEFERCAccount

BPEGRC Activity

PAO vs SCE

PAO

920921 | IT Project Support

Non-Labor 4,577 (2,104) 2,473

4,577Total (2,104) 2,473

IT Project Support: 4,577 (2,104) 2,473



2021 Test Year

Exhibit:

Cost Component:

BPG:

Witness:

Issue Title:




2018$ in Thousands

PAO-54 | Load Side Support O&M

O&M

Engineering

Dana Cabbell (SCE), Monica Weaver (PAO)

Load Side Support is an SCE program that addresses issues that can arise as a result of the generation, transmission and delivery of power to our customers. The work in this C activity is for SCE to respond to and resolve customer concerns initiated by customer calls to SCE. SCE’s 2021 TY non-labor forecast increase was based on a shift to contractor workers and a higher anticipated workload.

SCE-02 Vol. 04 Pt. 2 pg. 110 - 115; SCE-13 Vol. 04 Pt. 2 pg. 28 - 30

PAO Position: PAO recommends $0.172 million for the non-labor forecast compared to SCE’s $0.377 million forecast. PAO used a three- year average of 2016-2018 recorded costs to forecast TY 2021. As SCE mentions in Ex. SCE-02, Vol. 4 Part 02, p. 115, these expenses can vary from year to year. Utilizing an average over the three past years smooths out the various fluctuations.

PAO-07, Part 2, pg. 14

SCE Position:


SCEFERCAccount

BPEGRC Activity

PAO vs SCE

PAO

587 | Load Side Support

Non-Labor 377 (205) 172

377Total (205) 172

Load Side Support: 377 (205) 172



2021 Test Year

Exhibit:

Cost Component:

BPG:

Witness:

Issue Title:




2018$ in Thousands

PAO-56 | Monitoring Bulk Power System - Grid Control Center

O&M

Grid Monitoring & Operability

Vik Trehan (SCE), Monica Weaver (PAO)

Regarding the Grid Control Center, SCE proposes last year recorded as the basis for its forecast as it is forecasting a stable labor trend. Regarding Grid Network Solutions, SCE proposes normalized costs (over 2021- 2023) including increases for staffing to support rid Modernization and hardware maintenance.

SCE-13 Vol. 03, pp. 6-10

PAO Position: Regarding the Grid Control Center labor costs, Public Advocates proposes using the average of 2016-2018 instead of SCE's use of 2018. Regarding Grid Network Solutions, Public Advocates proposes using the average of 2016-2018 for labor and non-labor.

PAO-07, p. 7

SCE Position:

SCE-02, Vol. 3

SCEFERCAccount

BPEGRC Activity

PAO vs SCE

PAO

561 | Monitoring Bulk Power System

Labor 8,445 92 8,537

Non-Labor 1,620 (818) 801

10,065Total (726) 9,339

Monitoring Bulk Power System: 10,065 (726) 9,339

Excludes $83k reduction for AB 560. See SCE’s Update Testimony, SCE-52, pages 23-24.



2021 Test Year

Exhibit:

Cost Component:

BPG:

Witness:

Issue Title:




2018$ in Thousands

PAO-63 | Technology Assessment O&M

O&M

Grid Technology Assessments, Pilots & Adoption

Jennifer Smith (SCE), Monica Weaver (PAO)

The expenses for Technology Assessment activities include payroll for engineers and management, allocated overheads, small tools, equipment, and test facility operation/maintenance costs and supplemental contract personnel. The recorded expenses for Grid Technology have varied from year to year. Accordingly, SCE used the forecasting methodology recommended by the Commission when such variations have occurred. In D.89-12- 057, and subsequently in D.04.07-022, the Commission stated that if recorded expenses have fluctuated significantly from year to year, then an average of recorded expenses is appropriate. The recommendation by PAO excludes historical data when spending is markedly higher than other historical years, but includes historical data when such data is markedly lower than other years.

SCE-02 Vol. 04 Pt. 1 pg. 128 - 132; SCE-13 Vol. 04 Pt. 1 pg. 75

PAO Position: PAO recommends $8.657 million for the labor forecast compared to SCE’s request of $9.381 million. PAO used a five-year average that includes 2014-2016 and 2018-2019. PAO used SCE’s forecast 2019 data in the average. PAO excluded 2017 from the average calculation due to the expense being significantly higher than any other year; SCE recorded $11.727 million in 2017 compared to an average of $8.911 million in all other surrounding years.

PAO-07, Part 2, pg. 12

SCE Position:


SCEFERCAccount

BPEGRC Activity

PAO vs SCE

PAO

560 | Technology Assessment

Labor 1,654 0 1,654

1,654Total 0 1,654


Labor 676 0 676

676Total 0 676


Labor 2,760 (724) 2,036

2,760Total (724) 2,036


Labor 4,290 0 4,290

4,290Total 0 4,290

Technology Assessment: 9,381 (724) 8,657



2021 Test Year

Exhibit:

Cost Component:

BPG:

Witness:

Issue Title:




2018$ in Thousands

PAO-64 | Inspections & Maintenance

O&M


Gary Trumbo (SCE), Tamera Godfrey (PAO)

SCE’s forecast is based on 2018 recorded costs with the addition of incremental costs for new work activities.

SCE-13 Vol. 02, p. 14

PAO Position: PAO utilized SCE’s 2018 recorded adjusted expenses as a basis for its TY estimate because recorded expenses for years prior to 2018 are not comparable and SCE’s forecast includes the same activities already embedded in rates.

PAO-06, pp. 38 and 40

SCE Position:

SCE-02, Vol. 2

SCEFERCAccount

BPEGRC Activity

PAO vs SCE

PAO

935 | Telecommunication Inspection and Maintenance

Labor 3,150 (1,911) 1,239

Non-Labor 1,724 (544) 1,180

4,874Total (2,455) 2,419

Telecommunication Inspection and Maintenance: 4,874 (2,455) 2,419



2021 Test Year

Exhibit:

Cost Component:

BPG:

Witness:

Issue Title:




2018$ in Thousands


O&M



SCE forecast based on 2018 last-year recorded values, with an adjustment for forecasted incremental costs for planned new aerial inspections.

SCE-13 Vol. 02, p. 5

PAO Position: PAO utilized SCE’s 2018 recorded adjusted expenses as a basis and normalized SCE’s incremental request of $2.855 million over the three year-rate case cycle to account for similar activities that have costs included in rates and to provide funding for additional TY activities.

PAO-06, pp. 35 and 37

SCE Position:

SCE-02, Vol. 2

SCEFERCAccount

BPEGRC Activity

PAO vs SCE

PAO

563 | Transmission Line Patrols

Labor 5,448 (1,070) 4,378

Non-Labor 1,776 (824) 952

7,223Total (1,893) 5,330

Transmission Line Patrols: 7,223 (1,893) 5,330



2021 Test Year

Exhibit:

Cost Component:

BPG:

Witness:

Issue Title:




2018$ in Thousands


O&M



SCE’s forecasts are project-specific based.

SCE-13 Vol. 02, p. 17

PAO Position: PAO proposes using a five-year average because SCE’s method lacks detail and its forecast cannot be substantiated.

PAO-06, pp. 41-43

SCE Position:

SCE-02, Vol. 2

SCEFERCAccount

BPEGRC Activity

PAO vs SCE

PAO

571 | Transmission Line Rating Remediation (TLRR)

Labor 596 (277) 319

Non-Labor 1,194 (554) 640

1,790Total (831) 959

Transmission Line Rating Remediation (TLRR): 1,790 (831) 959



2021 Test Year

Exhibit:

Cost Component:

BPG:

Witness:

Issue Title:




2018$ in Thousands


O&M



Regarding Transmission O&M Maintenance (Sub-Activity), SCE recommends a four-year average (2015-2018) because the work is oftentimes reactive, and therefore variable from year-to-year. Regarding Aerial Inspection Maintenance Program (Sub-Activity) SCE's forecast is based on “find-rates” data from an analogous in-progress program – HFRA aerial inspections.

SCE-13 Vol. 02, pp. 10-12

PAO Position: Regarding Transmission O&M Maintenance (Sub-Activity) PAO utilized SCE’s 2021 forecast, its 2018 recorded expenses and normalized SCE’s incremental request for Aerial Inspections due to lack of supporting data. SCE’s expenses have declined each year between 2014 and 2018.

PAO-06, pp. 31-33

SCE Position:

SCE-02, Vol. 2

SCEFERCAccount

BPEGRC Activity

PAO vs SCE

PAO

566 | Transmission O&M Maintenance

Labor 831 0 831

Non-Labor 860 0 860

1,691Total 0 1,691


Labor 10,831 (5,778) 5,053

Non-Labor 5,382 (3,078) 2,304

16,213Total (8,856) 7,357


Labor 2,079 0 2,079

Non-Labor 1,081 0 1,081

3,160Total 0 3,160

Transmission O&M Maintenance: 21,064 (8,856) 12,208



2021 Test Year

Exhibit:

Cost Component:

BPG:

Witness:

Issue Title:




2018$ in Thousands

PAO-143 | Grid Network Solutions

O&M

Grid Monitoring & Operability

John Janney (SCE), Monica Weaver (PAO)

Regarding Grid Network Solutions portion of the Monitoring Bulk Power System activity, SCE proposes normalized costs (over 2021-2023) including increases for staffing to support grid Modernization and hardware maintenance.

SCE-13 Vol. 03, pp. 8-10

PAO Position: Public Advocates proposes using the average of 2016-2018 for labor as it shows a stable trend, and for non-labor proposes the average of 2016-2018.

PAO-07, p. 7

SCE Position:

SCE-02, Vol. 03

SCEFERCAccount

BPEGRC Activity

PAO vs SCE

PAO


Other 2,056 0 2,056

2,056Total 0 2,056


Labor 29,849 (7,243) 22,606

Non-Labor 12,949 (1,843) 11,106

42,797Total (9,086) 33,711

Monitoring Bulk Power System: 44,853 (9,086) 35,767



2021 Test Year

Exhibit:

Cost Component:

BPG:

Witness:

Issue Title:




2018$ in Thousands

PAO-TURN-68 | Vegetation Management SB 247

O&M

Wildfire Management

Melanie Jocelyn (SCE), Jerry Oh (PAO), Eric Borden (TURN)

SCE updated the vegetation management forecast due to changes in cost of labor based on contract negotiations completed and changes due to new California state legislation, Senate Bill (SB) 247.

SCE-24, p. 1

PAO will state its position in its opening brief.

TURN will state its position in its opening brief.

SCE Position:

PAO Position:

TURN Position:

SCE-02, Vol. 6

SCEFERCAccount

BPEGRC Activity

PAO vs SCE

TURN vs SCE

TURNPAO

593 | Dead, Dying and Diseased Tree Removal

Non-Labor TBD TBD10,439 TBDTBD

Total TBD TBD10,439 TBD TBD

Dead, Dying and Diseased Tree Removal TBD TBD10,439 TBD TBD

593 | Distribution Routine Vegetation Management



Distribution Routine Vegetation Management TBD TBD71,191 TBD TBD

571 | Transmission Routine Vegetation Management



Transmission Routine Vegetation Management TBD TBD2,927 TBD TBD

593 | Wildfire Vegetation Management



Wildfire Vegetation Management TBD TBD20,937 TBD TBD

Includes $47k reduction for AB 560. See SCE’s Update Testimony, SCE-52, pages 23-24.

Vegetation Management SB 247 TBD TBD105,494 TBD TBD



2021 Test Year

Exhibit:

Cost Component:

BPG:

Witness:

Issue Title:




2018$ in Thousands

PAO-TURN-50 | Vegetation Management

O&M

Wildfire Management

Melanie Jocelyn (SCE), Tamera Godfrey (PAO), Eric Borden (TURN)

SCE has developed a detailed, bottoms up forecast, based on expected work volume and difficulty, reflecting the work expected in 2021 and during the GRC Cycle. SCE relied on the results of a pilot study to determine parameters that reflect the expanded clearance zones. SCE updated the forecast to reflect SB247, which mandated higher wages for qualified tree trimmers. PAO’s proposal uses 2018 recorded amounts, which did not have the expanded clearance, so are not reflecting future work conditions.

SCE-13, Vol. 6, pp. 5-10, SCE-24, SCE-24E

PAO utilized SCE’s 2019 forecast because SCE does not show any historical expenses for this activity to review and analyze and notes that its 2019 recorded expenses for Wildfire Vegetation Management were less than its 2019 forecast. There is substantial uncertainty in SCE’s TY forecast and the projects that SCE submitted for review and analysis may not be implemented. Because of this uncertainty, PAO recommends a two-way Vegetation Management Balancing Account.

PAO-06, pp. 45-47

TURN believes that the Hazard Tree Removal Program (HTMP) forecast is excessive because SCE has not demonstrated that removal of an average of 25,000 living, green trees per year – in addition to the tens of thousands of trees removed under other vegetation management programs -- is necessary to address the ignition risk posed by fewer than 200 trees per year. In light of SCE’s forecast in its verified 2020-2022 Wildfire Mitigation Plan submission, removal of an average of 5,000 trees per year under HTMP is a reasonable and conservative forecast. TURN did not take a position on SCE’s forecasts for the Distribution and Transmission Routine Vegetation Management Programs, nor the Dead, Dying and Diseased Tree Removal Program.

TURN‐02, TURN‐02E and TURN‐02E2, pp. 37‐45

SCE Position:

PAO Position:

TURN Position:

SCE-02, Vol. 6

SCEFERCAccount

BPEGRC Activity

PAO vs SCE

TURN vs SCE

TURNPAO

593 | Dead, Dying and Diseased Tree Removal

Labor 3,7620 N/A3,762 N/A

Non-Labor 31,3580 N/A31,358 N/A

Total 0 N/A35,120 35,120 N/A

Dead, Dying and Diseased Tree Removal 0 N/A35,120 35,120 N/A


Labor 624156 N/A468 N/A

Non-Labor 5,30731 N/A5,276 N/A

Total 187 N/A5,744 5,931 N/A



2021 Test Year


Labor 8,793624 N/A8,168 N/A

Non-Labor 88,533(4,566) N/A93,099 N/A

Total (3,941) N/A101,267 97,326 N/A

Distribution Routine Vegetation Management (3,755) N/A107,012 103,257 N/A



Total 0 N/A1,404 1,404 N/A


Labor 1510 N/A151 N/A


Total 0 N/A2,906 2,906 N/A


Labor 4370 N/A437 N/A


Total 0 N/A8,450 8,450 N/A

Transmission Routine Vegetation Management 0 N/A12,760 12,760 N/A

593 | Wildfire Vegetation Management

Labor 682(617) (645)1,299 653

Non-Labor 24,370(30,519) (34,805)54,889 20,085

Total (31,136) (35,450)56,188 25,052 20,738

Wildfire Vegetation Management (31,136) (35,450)56,188 25,052 20,738

Includes SCE-13 Vol. 06 Errata #2

Vegetation Management (34,891) N/A211,080 176,189 N/A




131


2021 Test Year


Exhibit:

Cost Component:

Witness:


BPE:




SCE proposes a four-year average using the period 2014 through 2017.

SCE-13 Vol. 01, Part 2, p. 21

PAO Position: PAO proposes to use the same four-year average of 2014-2017 as SCE.

PAO-04, p. 15


$ in Thousands

Issue Title: PAO-13 | Distribution Preventive and Breakdown Capital Maintenance

SCE Position:



Inspections & Maintenance | Distribution Preventive and Breakdown Capital Maintenance

15 | CET-PD-BM-BD-MTW

SCE

PAO

453,914


177,754 135,918 140,242 144,299 148,449

16 | CET-PD-CR-IF-MTW

SCE

PAO

24,744


9,244 7,629 7,871 8,099 8,332

17 | CET-PD-IR-PM-MTW

SCE

PAO

448,706


176,797 133,826 138,084 142,077 146,164


602N/AN/A2603420PAO vs SCE

927,966Post-Test YearPost-Test Year286,457277,715

927,364302,946294,474286,197277,373363,794

363,794PAO

SCE

Total Distribution Preventive and Breakdown Capital Maintenance:



2021 Test Year


Exhibit:

Cost Component:

Witness:


BPE:


Grid Modernization

Ilia Gueorguiev (SCE), Garrick Jones (TURN)

SCE’s Automation workstreams include Reliability-driven Distribution Automation, DER-driven Distribution Automation, Small-scale Deployments, Reliability-driven Substation Automation (for deployments through mid-2019) and DER-driven Substation Automation. SCE’s expenditures for Reliability-driven Distribution Automation, the only contested workstream, will enhance reliability by reducing the number of customers affected by outages and outage durations, thereby reducing CMI and the number of momentary interruptions SCE’s customers experience.


TURN Position: SCE should prioritize the installation of RCSs and Remote Fault Indicators (RFIs) because they are relatively inexpensive and much more cost-effective than Remote Intelligent Switches (RISs) and additional circuit ties, especially given SCE’s intent to expand Grid DA in the future. TURN recommends disallowance for certain Grid DA investments, including RISs and other telemetered switches, and circuit tie upgrades related to “choker” ties or extensive new circuit ties. TURN recommends $9.891 million in 2020 and $8.717 million in 2021, representing reductions of $24.918 million and $15.154 million in those years.

TURN-04 pg. 3 - 5


$ in Thousands

Issue Title: TURN-15 | Automation Capital Forecast

SCE Position:



Grid Modernization | Automation

113 | CET-PD-GM-RA-MTW

SCE

TURN

109,178

N/A 9,891 8,717 0 0 18,608

35,346 34,809 23,872 25,141 25,356

TURN opposes SCE’s previously-rejected attempt to use the GRC to adopt capital spending forecasts for the period after the 2021 test year. Therefore, TURN did not analyze SCE’s proposed capital expenditure forecasts for 2022 or 2023 and has not proposed an alternative forecast figure for those years. TURN’s position is that, as a general matter, the Commission should not adopt SCE’s 2022 or 2023 forecasts.

(90,570)(25,356)(25,141)(15,155)(24,918)N/ATURN vs SCE

18,608008,7179,891

109,17825,35625,14123,87234,80935,346

N/ATURN

SCE

Total Automation Capital Forecast:



2021 Test Year


Exhibit:

Cost Component:

Witness:


BPE:


Capital Related Expense & Other


SCE used the capital expenditures forecast for each work activity and the total count of transformers for the same activity. The forecast is based on the transformer acquisition cost multiplied by the total count of transformers for each activity and each year 2019-2023.

SCE-13 Vol. 01, Part 2, p. 23

PAO Position: PAO agrees with SCE's computer model but revised some of the 44 different types of capital forecasts.

PAO-04, p. 23


$ in Thousands

Issue Title: PAO-20 | Distribution Transformers Capital Forecast

SCE Position:



Capital Related Expense & Other | Distribution Transformers

21 | CET-PD-OT-TR-FR

SCE

PAO

8,891

0 3,784 5,107 Post-Test Year Post-Test Year 8,891

0 3,784 5,107 5,582 6,303

22 | CET-PD-OT-TR-PL

SCE

PAO

26,126


8,900 6,334 10,891 11,206 11,528

23 | CET-PD-OT-TR-TRANSF

SCE

PAO

270,903


93,532 88,126 89,245 92,439 95,097

PAO’s Post-Test Year amounts in 2022-2023 will be derived based on the Post-Test Year ratemaking proposal. Totals represent 2019-2021.

4,229N/AN/A3,9043250PAO vs SCE


305,919112,928109,226105,24398,244102,432

102,432PAO

SCE

Total Distribution Transformers Capital Forecast:



2021 Test Year


Exhibit:

Cost Component:

Witness:


BPE:


Meter Activities

David Bernaudo (SCE), Yakov Lasko (PAO)

SCE based its routine meter replacement forecast on a three-year average from 2016-2018. PAO’s characterization of 2017 as an extraordinary event that is not related to ordinary company activities is wrong. As most businesses do, SCE prudently procures materials in a manner that will allow for minimum disruption to current and future operations. In some cases, as those experienced in 2017, this requires the advanced purchase of goods to meet customer needs in a future period. This means that SCE's purchases are not static year-to-year and instead go up and down based on which such advance purchases occur. Thus, using the recorded expenditures from any single year, like 2016, to forecast SCE's capital expenditures needs in the future is not a reliable methodology. Additionally, thee recorded costs incurred for this activity in 2019 are further evidence that the type of procurement activity that occurred in 2017 is not abnormal.

SCE-13 Vol. 01 Part 3, pp. 5-6

PAO Position: PAO recommends that the Commission adopt 2016 recorded expenditures for each year in the 2019-2021 period for the routine work portion of Meter Engineering capital expenditures on the basis that PAO finds the supply chain disruption experienced by SCE in 2017 to be an extraordinary event that is not related to ordinary company activities. Furthermore, large purchases in 2017 reduced the needed demand in 2018 and therefore those numbers are not appropriate for inclusion in the forecast.

PAO-03, p. 9


$ in Thousands

Issue Title: PAO-26 | Meter Engineering Routine Work

SCE Position:



Meter Activities | Meter Engineering

30 | CET-ET-MS-CE-744000

SCE

PAO

720

60 113 118 138 116 545

236 113 118 138 116

28 | CET-ET-MS-CR-452700

SCE

PAO

37,859

16,717 26,718 3,636 4,120 3,385 54,575

0 26,718 3,636 4,120 3,385

29 | CET-ET-MS-RB-452701

SCE

PAO

116,081

8,250 15,112 24,894 25,681 21,760 95,697

24,035 17,412 27,194 25,681 21,760

(3,843)00(2,300)(2,300)757PAO vs SCE

150,81725,26129,93828,64841,942

154,66025,26129,93830,94844,24224,270

25,027PAO

SCE

Total Meter Engineering Routine Work:



2021 Test Year


Exhibit:

Cost Component:

Witness:


BPE:


Capital Related Expense & Other


For Distribution Pole Loading Program (PLP) Prefabrication use 2.83% of the forecast for Distribution Pole Loading Program Replacement program. For non-PLP Prefabrication costs, use last year recorded as the forecast.

SCE-13 Vol. 01, Part 2, p. 25

PAO Position: PAO agrees with SCE methodology but independently developed its own Pole Loading Program forecasts, which impacts the prefabrication budget.

PAO-04, p. 22


$ in Thousands

Issue Title: PAO-28 | Distribution Pole Loading Program (PLP) Prefabrication

SCE Position:



Capital Related Expense & Other | Prefabrication

24 | CET-PD-OT-PF-MTW

SCE

PAO

41,778


12,226 14,544 15,007 15,441 15,885

25 | CET-PD-OT-PF-PL

SCE

PAO

17,730


6,040 4,299 7,391 7,605 7,824


(5,649)N/AN/A(4,388)(1,261)0PAO vs SCE


59,50823,70923,04622,39818,84318,267

18,267PAO

SCE

Total Distribution Pole Loading Program (PLP) Prefabrication:



2021 Test Year


Exhibit:

Cost Component:

Witness:


BPE:


New Service Connections

Paul Joseph (SCE), Eric Borden (TURN)

SCE uses a housing start forecast provided by Moody's Analytics, with an additional modeling adjustment to reduce that housing start forecast. SCE does not agree with TURN’s proposal to take an average of 2015-2019 historical housing starts and apply it to SCE's forward-looking forecast.

SCE-13 Vol. 04 Part 3, pp. 4-9; SCE-18 Vol. 01, pp. 34-38

TURN Position: SCE has consistently over-estimated the number of new meter connections primarily due to overly-optimistic housing start forecasts. TURN finds an average of actual housing starts from 2015-2019 is a more reasonable estimate going forward.

TURN-02C, p. 55


$ in Thousands

Issue Title: TURN-30 | Residential New Service Connections Forecast

SCE Position:



New Service Connections | Residential New Service Connections

573 | CET-PD-NS-RS-MTW

SCE

TURN

727,086

110,480 137,670 118,520 125,937 157,768 650,375

110,480 137,670 149,787 162,737 166,412

TURN’s financial position represents SCE’s conversion of TURN's recommendations from 2018 Constant $ to Nominal $. TURN has not verified SCE’s conversion calculation.

(76,711)(8,644)(36,800)(31,267)00TURN vs SCE

650,375157,768125,937118,520137,670

727,086166,412162,737149,787137,670110,480

110,480TURN

SCE

Total Residential New Service Connections Forecast:



2021 Test Year


Exhibit:

Cost Component:

Witness:


BPE:



Gary Trumbo (SCE), Yakov Lasko (PAO)

SCE’s forecast was based on objective “find rate” data based on the Enhanced Overhead Inspection (“EOI”) program’s 2018 recorded and preliminary 2019 “find rates.” SCE applied the historical “find rate” for the EOI program to Aerial Inspection Maintenance. SCE’s forecast has been subsequently validated with additional objective 2019 recorded data.

SCE-13 Vol. 02, p. 21

PAO Position: PAO proposes a 49% reduction to $15M for the Aerial Inspection Maintenance sub-activity forecast because of a lack of historical data and the use of subject matter expert judgement.

PAO-03, p. 12


$ in Thousands

Issue Title: PAO-31 | Aerial Inspection Maintenance Forecast Methodology

SCE Position:

SCE-02, Vol. 2


Inspections & Maintenance | Transmission Capital Maintenance

36 | CET-PD-IR-TG-TRSJAC (CPUC)

SCE

PAO

39,671

0 0 8,653 N/A N/A 8,653

0 0 12,957 13,206 13,508

36 | CET-PD-IR-TG-TRSJAC (FERC)

SCE

PAO

9,616

0 0 2,099 N/A N/A 2,099

0 0 3,143 3,199 3,274

38 | CET-PD-IR-TP-788700

SCE

PAO

19,476

0 0 4,248 N/A N/A 4,248

0 0 6,362 6,483 6,632

PAO’s direct testimony did not correctly reference SCE’s financial position in the amended version of SCE-02, Volume 2A, which was published in November 2019, and subsequently revised in SCE’s rebuttal testimony, SCE-13 V2. PAO did not specifically address the 2022 and 2023 forecast.

(53,764)N/AN/A(7,461)00PAO vs SCE

15,000N/AN/A15,0000

68,76423,41422,88922,46100

0PAO

SCE

Total Aerial Inspection Maintenance Forecast Methodology:



2021 Test Year


Exhibit:

Cost Component:

Witness:


BPE:


Poles

Aaron Smith (SCE), Greg Wilson (PAO)

SCE's forecast is based on calculating a credit per pole from several years of data, that accurately reflects how credits may be recorded in a different calendar year from when the pole is installed. This methodology was accepted by the Commission as the basis for forecasting pole credits in the 2018 GRC decision.

SCE-13, Vol. 5, pp. 9-11

PAO Position: PAO calculates a credit per pole based on calendar year 2019 credits and pole volumes, and applies that credit to forecast volumes in 2020 and 2021.

PAO-04, pp. 56-59


$ in Thousands

Issue Title: PAO-33 | Joint Pole Credits

SCE Position:

SCE-02, Vol. 5


Poles | Distribution Joint Pole Capital Credits

764 | CET-PD-CR-JD-MTW

SCE

PAO

(195,811)

(37,809) (56,902) (75,078) Post-Test Year Post-Test Year (169,789)

(77,375) (51,707) (66,729) (45,740) (32,140)

765 | CET-PD-CR-JD-PL

SCE

PAO

(88,565)


(17,817) (35,953) (34,795) (58,721) (75,325)

Poles | Transmission Joint Pole Capital Credits

774 | CET-PD-CR-JT-PL

SCE

PAO

(5,182)


(697) (2,376) (2,109) (7,638) (10,999)

775 | CET-PD-CR-JT-TREAST

SCE

PAO

(37,161)


(5,636) (12,767) (18,758) (13,627) (10,753)


(25,635)N/AN/A(15,309)(10,327)0PAO vs SCE

-352,353Post-Test YearPost-Test Year(137,700)(113,129)

(326,718)(129,216)(125,725)(122,391)(102,802)(101,525)

(101,525)PAO

SCE

Total Joint Pole Credits:



2021 Test Year


Exhibit:

Cost Component:

Witness:


BPE:


Poles

Aaron Smith (SCE), Greg Wilson (PAO)

SCE's forecasts are based on inspection and assessments, the expected failure rates, and the compliance requirement to remediate poles in a timely manner. 2019 recorded volumes were lower than forecast, due to resources being diverted to Enhanced Overhead Inspection activities. Unit costs in 2019 were higher than forecast.

SCE-13, Vol. 5, pp. 5-8

PAO Position: Depending on the pole type, 2019 pole volumes were either higher or lower than SCE's forecast, so future pole volume forecast should be adjusted in a pro rata manner.

PAO-04, pp. 52-55


$ in Thousands

Issue Title: PAO-34 | Pole Capital Expenditures

SCE Position:

SCE-02, Vol. 5


Poles | Distribution Deteriorated Pole Replacement

762 | CET-PD-IR-DP-MTW

SCE

PAO

587,388


183,715 217,560 186,113 191,496 197,004

763 | CET-PD-IR-DU-MTW

SCE

PAO

54,082


12,608 19,208 22,266 22,910 23,569

761 | CET-PD-OT-SF-MTW

SCE

PAO

1,390

1 472 579 Post-Test Year Post-Test Year 1,051

339 472 579 595 612

Poles | Distribution Pole Loading Program Pole Replacement

766 | CET-PD-IR-PD-MTW

SCE

PAO

548,436


148,888 148,380 251,168 258,433 265,867

767 | CET-PD-IR-PU-MTW

SCE

PAO

22,588


9,062 3,522 10,004 10,293 10,589

Poles | Distribution Wood Pole Disposal

768 | CET-PD-OT-WP-WPDISP

SCE

PAO

9,037


2,979 3,061 2,997 3,084 3,173



2021 Test Year

Poles | Distribution Wood Pole Disposal - Pole Loading Program

769 | CET-PD-OT-WP-PL

SCE

PAO

4,302

1,422 934 1,679 Post-Test Year Post-Test Year 4,034

1,690 934 1,679 1,727 1,777

Poles | Telecommunication Deteriorated Pole Replacement

770 | CET-PD-IR-TR-TRTCNW (CPUC)

SCE

PAO

2,041

3,656 119 226 Post-Test Year Post-Test Year 4,001

1,704 115 221 226 231

770 | CET-PD-IR-TR-TRTCNW (FERC)

SCE

PAO

119


113 2 4 4 4

Poles | Telecommunication Pole Loading Program Replacement

771 | CET-PD-IR-PT-TRTCNW (CPUC)

SCE

PAO

1,154

204 60 1,120 Post-Test Year Post-Test Year 1,385

1 58 1,094 1,115 1,141

771 | CET-PD-IR-PT-TRTCNW (FERC)

SCE

PAO

3


0 0 3 3 3

Poles | Transmission Deteriorated Pole Replacement

772 | CET-PD-IR-TR-TRMETW (CPUC)

SCE

PAO

260,114


83,767 82,025 94,322 96,120 98,322

772 | CET-PD-IR-TR-TRMETW (FERC)

SCE

PAO

7,767


4,970 1,301 1,496 1,525 1,560

773 | CET-PD-OT-SF-TRORAN (CPUC)

SCE

PAO

318


44 123 152 154 158

773 | CET-PD-OT-SF-TRORAN (FERC)

SCE

PAO

4


0 2 2 2 3

Poles | Transmission Pole Loading Program Replacement

776 | CET-PD-IR-PT-TRMETW (CPUC)

SCE

PAO

99,342


41,355 15,235 42,752 43,567 44,565

776 | CET-PD-IR-PT-TRMETW (FERC)

SCE

PAO

292


116 46 129 132 135



2021 Test Year


(55,224)N/AN/A(28,787)(26,437)0PAO vs SCE

1,543,152Post-Test YearPost-Test Year586,195465,606

1,598,376648,711631,387614,982492,043491,352

491,352PAO

SCE

Total Pole Capital Expenditures:



2021 Test Year


Exhibit:

Cost Component:

Witness:


BPE:




SCE agrees with TURN’s recommendation.

SCE-17, Vol. 02, p. 12

PAO Position: PAO proposes to reduce SCE's forecast by the 10-year average annual percentage of the ratio of authorized to recorded underspent expenditures from 2010-2019 (35%).

PAO-04, p. 32


$ in Thousands

Issue Title: PAO-145 | Rule 20A Conversion

SCE Position:




581 | CET-PD-2A-2A-MTW

SCE

PAO

50,952


16,381 17,015 17,556 18,064 18,584

580 | CIT-00-OP-NS-000018

SCE

PAO

1,080


342 369 369 369 369


(16,942)N/AN/A(6,372)(6,179)(4,391)PAO vs SCE


52,03218,95318,43317,92517,38416,723

12,332PAO

SCE

Total Rule 20A Conversion:



2021 Test Year


Exhibit:

Cost Component:

Witness:


BPE:


$ in Thousands

Issue Title: PAO-TURN-21 | Engineering and Planning Software Tools Capital Forecast


Grid Modernization

Timothy Boucher (SCE), Thomas Roberts (PAO), Garrick Jones (TURN)

E&P Tools help to integrate Distribution Energy Resources (DERs) into SCE’s electric system planning processes through more granular DER and load forecasting, sophisticated power flow modeling to identify potential grid needs, and streamlined interconnections of customer DERs. E&P Tools include the following workstreams: (1) Grid Connectivity Model (GCM), (2) Grid Analytics Applications (GAA), (3) Long Term Planning Tool – System Modeling Tool (LTPT-SMT), (4) Grid Interconnection Processing Tool (GIPT), (5) Distribution Resource Plan External Portal (DRPEP The E&P tools forecast presented in SCE’s 2021 GRC is in alignment with and driven by evolving compliance requirements for integrating DERs into the California investor- owned utilities (IOUs) distribution planning process as part of the Commission’s DRP proceeding.

SCE-02 Vol. 04 Pt. 1 pg. 28- 57; SCE-13 Vol. 04 Pt. 1 pg. 8 - 25

PAO recommends $1.634 million for the E&P Tools for 2019-2021, compared to SCE’s request of $88.710 million. PAO bases this recommendation on its conclusion that SCE’s 2018 GRC forecast appeared to include all deployment costs within the 2018 GRC period (2016-2020), but that SCE now includes costs through 2028, and at a cost “nearly three times higher than its TY 2018 request which is significant in both percentage and absolute terms.” PAO recommends that the Commission order that the funding adopted in the 2018 GRC for E&P tools constitute full funding to deploy these software tools, and that the only future capital expenditures to be authorized should be based on “refresh” costs. PAO further states that any functionality approved in SCE’s 2018 GRC must be provided and funded by SCE shareholders, except where exceptions are noted for each tool. PAO notes that the Commission should consider upward adjustments where SCE can provide evidence additional functionality is required per Commission directives following the 2018 GRC and SCE can accurately forecast the incremental cost added to its functionality.

PAO-05P, pp. 31 - 44

TURN supports PAO’s analysis and recommendation that the Commission authorize $1.634 million for 2019-2021 for E&P Tools and disallow the remaining proposed costs for E&P Tools. SCE’s cost forecast for E&P Tools has significantly escalated in this rate case compared to its forecast in its 2018 GRC, which was already authorized by the Commission.

TURN-04 pg. 4 - 5

SCE Position:

PAO Position:

TURN Position:




120 | CIT-00-DM-DM-000263

6,059 2,246 613 0 0

0 0 0

0 0 0

SCE

PAO

TURN

8,918

0

0

0 0

0 0

(6,059)PAO vs SCE

TURN vs SCE (6,059)

(2,246)

(2,246)

(613)

(613)

0

0

0

0

(8,918)

(8,918)

121 | CIT-00-DM-DM-000264



2021 Test Year



2,383 3,844 5,037 2,626 2,195

0 0 0

0 0 0

SCE

PAO

TURN

16,085

0

0

0 0

0 0

(2,382)PAO vs SCE

TURN vs SCE (2,382)

(3,844)

(3,844)

(5,037)

(5,037)

(2,626)

(2,626)

(2,195)

(2,195)

(16,084)

(16,084)

122 | CIT-00-DM-DM-000265

1,672 1,315 1,438 2,780 2,410

1,289 0 0

1,289 0 0

SCE

PAO

TURN

9,615

1,289

1,289

0 0

0 0

(383)PAO vs SCE

TURN vs SCE (383)

(1,315)

(1,315)

(1,438)

(1,438)

(2,780)

(2,780)

(2,410)

(2,410)

(8,326)

(8,326)

123 | CIT-00-OP-NS-000520

9,926 5,424 6,124 0 0

354 0 0

354 0 0

SCE

PAO

TURN

21,474

354

354

0 0

0 0

(9,572)PAO vs SCE

TURN vs SCE (9,572)

(5,424)

(5,424)

(6,124)

(6,124)

0

0

0

0

(21,120)

(21,120)

124 | CIT-00-OP-NS-000521

9,817 6,631 8,174 6,193 4,843

0 0 0

0 0 0

SCE

PAO

TURN

35,658

0

0

0 0

0 0

(9,817)PAO vs SCE

TURN vs SCE (9,817)

(6,631)

(6,631)

(8,174)

(8,174)

(6,193)

(6,193)

(4,843)

(4,843)

(35,659)

(35,659)

125 | CIT-00-SD-PM-000247

7,142 5,684 5,827 6,129 4,435

0 0 0

0 0 0

SCE

PAO

TURN

29,217

0

0

0 0

0 0

(7,142)PAO vs SCE

TURN vs SCE (7,142)

(5,684)

(5,684)

(5,827)

(5,827)

(6,129)

(6,129)

(4,435)

(4,435)

(29,217)

(29,217)

36,998SCE

PAO

TURN

Total Engineering and Planning Software Tools

1,643

1,643

25,145

0

0

27,213

0

0

17,727

0

0

13,883

0

0

120,968

1,643

1,643

PAO vs SCE

TURN vs SCE

(35,356)

(35,356)

(25,145) (27,213) (17,727) (13,883)

(25,145) (27,213) (17,727) (13,883)

(119,325)

(119,325)

The $88.710 million refers to SCE's pre-rebuttal forecast for 2019-2021 that did not incorporate 2019 recorded capital expenditures.



2021 Test Year


Exhibit:

Cost Component:

Witness:


BPE:


$ in Thousands

Issue Title: PAO-TURN-23 | Grid Management System (GMS) Capital Forecast


Grid Modernization

Timothy Boucher (SCE), Thomas Roberts (PAO), Garrick Jones (TURN)

SCE’s GMS is an advanced software platform that will integrate multiple systems designed to operate our increasingly dynamic grid. The GMS will replace SCE’s current Distribution Management System (DMS) and Outage Management System (OMS) to provide integrated grid management functionality, enabling system operators, operations engineers and other users to receive and analyze real-time information on customer energy usage, system power flows, system outages and faults, and DER performance. SCE GMS capital expenditure forecast is based on an extensive RFP effort, which included a design phase, close interaction with the preferred vendor, and visits with other utilities that have already deployed the same solution. The capital expenditures will therefore follow a phased approach that prioritizes the most immediate needs and implements capabilities gradually to minimize deployment risks.


PAO recommends a 2019-2021 GMS forecast of $106.245 million compared to SCE’s rebuttal forecast of $115.553 million, with a reduction of $10.2 million in 2021. PAO’s primary concern is the increased GMS cost, believing the increase is not adequately supported or justified. PAO supports limiting GMS funding to SCE’s 2018 GRC approval of $134.5M and “hold[ing] SCE accountable for providing all functionality described in its testimony.” PAO suggests that the alternative to this outcome “is to treat SCE’s GMS request as a new request given the increased forecast and the fact that the GMS is now a “platform” of software rather than one integrated software tool.

PAO-05P, pp. 17 - 31

TURN supports PAO’s recommendations regarding the GMS, specifically, that the Commission authorizes $35.724 million and $37.456 million in 2020 and 2021, respectively, for the GMS. The Commission authorized $135 million in the 2018 GRC for the GMS. SCE now seeks an additional $60 million for the same project. should not allow SCE to come back with a forecast for the same work that is 42% higher than the previously authorized forecast.

TURN-04 pg. 4 - 5

SCE Position:

PAO Position:

TURN Position:




126 | CIT-00-SD-PM-781701

32,217 35,724 47,611 44,864 30,682

33,064 35,724 37,456

33,064 35,724 37,456

SCE

PAO

TURN

191,099

106,244

106,244

N/A N/A

N/A N/A

847PAO vs SCE

TURN vs SCE 847

0

0

(10,155)

(10,155)

N/A

N/A

N/A

N/A

(9,308)

(9,308)



2021 Test Year



32,217SCE

PAO

TURN

Total Grid Management System

33,064

33,064

35,724

35,724

35,724

47,611

37,456

37,456

44,864

N/A

N/A

30,682

N/A

N/A

191,099

106,244

106,244

PAO vs SCE

TURN vs SCE

847

847

0 (10,155) N/A N/A

0 (10,155) N/A N/A

(9,308)

(9,308)

TURN opposes SCE’s previously-rejected attempt to use the GRC to adopt capital spending forecasts for the period after the 2021 test year. Therefore, PAO and TURN did not analyze SCE’s proposed capital expenditure forecasts for 2022 or 2023, and has not proposed an alternative forecast figure for those years. TURN’s position is that, as a general matter, the Commission should not adopt SCE’s 2022 or 2023 forecasts.




148


2021 Test Year

Exhibit:

Cost Component:

BPG:

Witness:

Issue Title:




2018$ in Thousands

PAO-57 | Postage

O&M

Billing & Payments

Brandi Anderson (SCE), Dao Phan (PAO)

SCE’s Test Year forecast for Postage Expense should be adopted since it is unopposed. However, SCE’s Test Year forecast for Postage Expense includes a $1.780 million reduction reflecting forecast postage savings from the proposed AIM initiative in SCE-03, Vol. 2, pp. 21-24. Thus, if the Commission does not approve the funding requested for the proposed AIM initiative, SCE’s Test Year Postage forecast must be increased by $1.780 million to $15.187 million in order to account for the postage expense that would have been saved by the AIM initiative. The Postage forecast includes an adjustment of $0.222 million for the 2020 US Postal Service rate increase that was presented in Update testimony.

SCE-14, Vol. 1, pp. 14-15, SCE-52, pp. 15-16

PAO Position: PAO finds the Test Year forecast for Postage Expense to be reasonable.

PAO-08P, p. 4

SCE Position:

SCE-03, Vol. 1

SCEFERCAccount

BPEGRC Activity

PAO vs SCE

PAO

Billing & Payments

903 | Postage

Non-Labor 0 0 0

Other 13,629 (222) 13,407

13,629Total (222) 13,407

13,629

Postage Total:

(222) 13,407



2021 Test Year

Exhibit:

Cost Component:

BPG:

Witness:

Issue Title:




2018$ in Thousands

TURN-76 | Uncollectible Expense Factor Adjustment for the Disconnection OIR Requirement

O&M

Billing & Payments

Brandi Anderson (SCE), David Cheng (TURN)

SCE forecasted a Test Year Uncollectible Expense factor of 0.191 percent based on the historical 5-year average (2014-2018) with two adjustments: (1) A reduction to remove the generation component of CCA service accounts and (2) an increase to account for D.18-12-013 in the Disconnection OIR. For the second adjustment, SCE corrected a forecast calculation error reducing the D.18-12-013 adjustment from 0.017 percent to 0.006 percent resulting in a forecast uncollectible factor of 0.180 percent (0.191 - 0.017 + 0.006 percent).

SCE-14, Vol. 1, SCE-03, Vol.1A; SCE-03, Vol.1AE2

TURN Position: TURN agrees with the 5-year average forecast method for the base level on the uncollectible factor. TURN disagrees with the adjustment to SCE’s uncollectible factor as a result of D.18-12-013 in the Disconnection OIR. TURN notes that the full year impact to SCE’s uncollectible factor as a result of this decision was only 0.001 percent in 2019 and that this figure should be adopted as the Test Year adjustment for D.18-12-013. TURN also contends that SCE inappropriately assumed that 100 percent of the balances of customers not disconnected due to extreme weather limitations will be written off in its forecast for this adjustment.

TURN-06, p.11

SCE Position:

SCE-03, Vol. 1

SCEFERCAccount

BPEGRC Activity

TURN vs SCE

TURN

Billing & Payments

904 | Uncollectible Expenses

Other 15,907 15,465(442)

15,907Total (442) 15,465

15,907

Uncollectible Expenses Total:

(442) 15,465



2021 Test Year

Exhibit:

Cost Component:

BPG:

Witness:

Issue Title:




2018$ in Thousands

TURN-78 | Customer Experience Management

O&M

Customer Care Services

Jessica Lim (SCE), David Cheng (TURN)

The Customer Experience Management Test Year O&M forecast includes an increase of $659,000 for two components. The first component of $376,000 is needed for customer service process improvements to more effectively manage customers’ complaints and concerns, including at-risk customers. This funding is necessary as SCE’s past attempts to serve customers who completed the Medallia survey ended in 2017 due to resource constraints. The second component of $283,000 is for advanced analytics required to refresh data from external sources periodically to ensure that data is accurate and includes updated customer data variables. The funds are necessary to expand market research to accommodate new rate plans and programs to determine customer receptivity, ideal customer designs, and potential barriers to enrollment utilizing focus groups and purchasing secondary literature. The additional funds will also be used to test the effectiveness of pilots geared to specific customer service solutions and programs in meeting customers’ needs. These additional activities go beyond the activities SCE currently performs and would greatly enhance SCE’s Customer Experience Management.

SCE-14, Vol. 1, pp. 61-63

TURN Position: TURN rejects the $376,000 forecast increase for customer service process improvements function and rejects the $283,000 forecast increase for advanced analytics. TURN states that SCE has not supported the need for an increase and is already conducting these activities currently.

TURN-06, p. 17

SCE Position:

SCE-03, Vol. 5

SCEFERCAccount

BPEGRC Activity

TURN vs SCE

TURN


909 | Customer Experience Management

Labor 4,553 4,270(283)

Non-Labor 2,845 2,469(376)

7,398Total (659) 6,739

7,398

Customer Experience Management Total:

(659) 6,739



2021 Test Year

Exhibit:

Cost Component:

BPG:

Witness:

Issue Title:




2018$ in Thousands

TURN-79 | Customer Programs Management

O&M



SCE’s Test Year forecast includes a $458,000 forecast increase for Net Energy Metering (NEM). SCE expects the number of NEM applications to increase substantially over the next several years because of the new 2019 Building Energy Efficiency Standards, which require the installation of solar photovoltaic systems for new low- rise residential buildings effective January 1, 2020. TURN’s claim is not reasonable that SCE will not see NEM application growth based on the number of 2018-2019 applications because TURN does not dispute or account for the new building standards that will cause applications to increase significantly.

SCE-14, Vol. 1, pp. 68-69

TURN Position: TURN recommends that SCE’s unrealistic growth projection be rejected and adopt a reduction of $458,000. SCE’s forecast growth of NEM interconnection is unrealistic given recent NEM application trends. TURN notes that the number of NEM applications in 2019 were lower than 2015. Further, SCE's 2018 GRC forecast of NEM applications was 112,247 annually for 2018-2020 and, in reality, the average number of NEM applications for 2018 and 2019 combined was only about half of what SCE projected.

TURN-06, p. 19

SCE Position:

SCE-03, Vol. 5

SCEFERCAccount

BPEGRC Activity

TURN vs SCE

TURN


903 | Customer Programs Management

Labor 1,867 1,8670

1,867Total 0 1,867


Labor 334 3340

Non-Labor 167 1670

501Total 0 501


Labor 3,377 2,919(458)

Non-Labor 1,853 1,8530

5,230Total (458) 4,772



2021 Test Year

Demand Response


Labor 258 2580

Non-Labor 980 9800

1,238Total 0 1,238

Distributed Generation


Labor 1,779 1,7790

Non-Labor 164 1640

1,943Total 0 1,943

Energy Efficiency


Labor 1,953 1,9530

Non-Labor 1,100 1,1000

3,053Total 0 3,053

13,832

Customer Programs Management Total:

(458) 13,374



2021 Test Year

Exhibit:

Cost Component:

BPG:

Witness:

Issue Title:




2018$ in Thousands

TURN-80 | Digital Operations and Management

O&M

Customer Contacts


SCE's Test Year O&M forecast of $2.603 million non-labor includes an increase over the Base Year expenses of $865,000 for improved digital services. The increase requested for non-labor expenses is necessary and primarily driven by ongoing updates, enhancements, and stabilization of SCE.com and related support for evolving digital channels. SCE would not be able to perform these improved digital customer services at the current funding level.

SCE-03, Vol. 4A; SCE-14, Vol. 1, pp. 55-56

TURN Position: TURN recommends a $0.865 million reduction to non-labor because SCE already performs well in this area and did not provide justification for why it is not able to perform any needed improvements using the current non-labor funding level.

TURN-06, p. 16

SCE Position:

SCE-03, Vol. 4

SCEFERCAccount

BPEGRC Activity

TURN vs SCE

TURN

Customer Contacts

909 | Digital Operations and Management

Non-Labor 2,603 1,738(865)

2,603Total (865) 1,738

2,603

Digital Operations and Management Total:

(865) 1,738



2021 Test Year

Exhibit:

Cost Component:

BPG:

Witness:

Issue Title:




2018$ in Thousands

PAO-TURN-41 | Billing

O&M

Billing & Payments


SCE's Test Year O&M forecast for Billing Services of $37.435 million includes adjustment of $2.062 million for billing exceptions (bundled customers), $2.843 million for billing exceptions (CCA customers), and $242,000 for policy adjustments, as well as a reduction of $314,000 for savings related to mailing operations that will be realized only if funding is authorized in this GRC for the Analytics and Integrated Marketing (AIM) initiative. If the forecast O&M for the AIM initiative is not approved, the forecast $314,000 savings must be added back to the forecast for Billing Services.

SCE-14, Vol. 1, pp. 5-14

SCE Position:

PAO Position:

TURN Position:

SCE-03, Vol. 1

SCEFERCAccount

BPEGRC Activity

PAO vs SCE

TURN vs SCE

TURNPAO

PAO recommends that the 2021 Test Year O&M forecast for Billing Services be reduced by $4.833 million to $32.602 million, which is equal to 2018 recorded O&M expense. PAO rejects the Test Year Adjustments for billing exceptions (bundled customers), billing exceptions (CCA customers), and Policy Adjustments.

TURN recommends that the 2021 Test Year O&M forecast for Billing Services be reduced by $5.469 million, which reflects TURN’s proposed rejection of the Test Year Adjustments for billing exceptions (bundled customers), billing exceptions (CCA customers), and Policy Adjustments, and TURN’s additional proposed reduction for Process Oversight and Support.

PAO-08, p. 4-14

TURN-06, p.4-10

Billing & Payments

586 | Billing

Labor 03,127 3,127 3,1270

Non-Labor 0990 990 9900

Total 0 04,117 4,117 4,117

587 | Billing

Labor 013 13 130

Non-Labor 04 4 40

Total 0 018 18 18



2021 Test Year

901 | Billing

Labor 02,980 2,980 2,9800

Non-Labor 0565 565 5650

Total 0 03,545 3,545 3,545

903 | Billing

Labor (4,721)23,057 18,336 17,830(5,227)

Non-Labor (139)6,699 6,560 6,457(242)

Total (4,859) (5,469)29,756 24,896 24,287

931 | Billing

Other 260 26 00

Total 26 00 26 0

Distributed Generation

903 | Billing

Labor 00 0 00

Total 0 00 0 0

Billing

(4,833) (5,469)37,435 32,602 31,966



2021 Test Year

Exhibit:

Cost Component:

BPG:

Witness:

Issue Title:




2018$ in Thousands

PAO-TURN-42 | Business Account Management

O&M

Customer Contacts

Kelly Garcia (SCE), Dao Phan (PAO), David Cheng (TURN)

SCE's forecast increase for Business Account Management (BAM) of $5.169 million in the Test Year is comprised of several components. $2.869 million is for increased account manager support for customer TE adoption and TE programs. This increased support for TE programs is based on the anticipated growth in customer interest in TE, SCE’s TE programs and charging ports in 2021, and SCE’s account manager interactions data showing that customers are requiring more customer support for TE. The $5.169 million forecast increase also includes $552,000 for increased account manager resources and time to support Grid Resiliency, $74,000 for increased account manager resources and time to support DERs, and $1.854 million to support emerging programs and technologies. SCE plans to seek a $5.169 million reduction in its EE Annual Budget Advice Letter (ABAL) process that corresponds to the increased GRC funding for BAM sought here. SCE will confirm this reduction in its 2021 ABAL in its Opening Brief in this proceeding. In addition to the $5.169 million increase just discussed, SCE also forecasts an increase of $373,000 in the Test Year for outage communications. PAO and TURN provide no evidence or testimony supporting their proposed rejection of SCE’s Test Year adjustment of $373,000 for outage communications.

SCE-14, Vol. 1, pp. 46-55

SCE Position:

PAO Position:

TURN Position:

SCE-03, Vol. 4

SCEFERCAccount

BPEGRC Activity

PAO vs SCE

TURN vs SCE

TURNPAO

PAO recommends the 2018 recorded amount of $14.136 million for BAM, rejecting the Test Year adjustments for account management of $5.169 million and increase of $373,000 for outage communications activities. PAO contends that SCE has not adequately supported the proposed BAM increase over 2018 levels pointing out that 2019 overall account manager interactions and FTEs declined in 2019 compared to 2018. PAO also argues that SCE’s claims that its customers are requiring more account manager resources and time to support emerging programs and technologies, as well as increased customer care, are unsubstantiated. PAO also expresses concern that if the Commission approves SCE’s requested increase for these account management activities, it will result in an increase in customers’ rates contrary to SCE’s claim that it plans to seek a corresponding reduction in its Energy ABAL process.

TURN contends that the BAM increase is unsupported for several reasons. First, TURN notes that there have always been emerging technologies, and faults SCE for not providing justification for why emerging technologies today require more account manager resources than emerging technologies three years ago. Second, TURN notes that projects for Distributed Energy Resources have been decreasing. TURN also shares PAO’ concern about SCE’s claim that this GRC increase in funding for account management activities will be matched by a corresponding reduction in SCE’s ABAL process. TURN also recommends a labor reduction for the Outage Communications adjustment. TURN recommends a reduction of $5.161 million.

PAO-08, p. 23-24

TURN-06, pp. 14-15



2021 Test Year

Customer Contacts

908 | Business Account Management

Labor (5,110)17,101 11,991 11,991(5,110)

Non-Labor (59)1,212 1,153 1,2120

Total (5,169) (5,110)18,313 13,144 13,203

Outage Experience

908 | Business Account Management

Labor (51)183 132 132(51)

Non-Labor (322)1,182 860 1,1820

Total (373) (51)1,365 992 1,314

Business Account Management

(5,542) (5,161)19,678 14,136 14,517



2021 Test Year

Exhibit:

Cost Component:

BPG:

Witness:

Issue Title:




2018$ in Thousands

PAO-TURN-43 | Hydraulic Services is Properly Funded in the GRC

O&M


Kelly Garcia (SCE), Dao Phan (PAO), David Cheng (TURN)

SCE’s Test Year forecast for Business Account Management Services includes a forecasted increase of $1.151 million for Hydraulic Services. Previously, the pump test service was primarily funded through SCE’s energy efficiency program portfolio because energy savings were the primary benefit derived from the pump test service. However, since 2015, and consistent with customer needs, the hydraulic services transitioned from an energy efficiency focus to a focus on customer safety and operational efficiency and SCE system reliability. Thus, hydraulic services is properly funded in the GRC. SCE will confirm in its Opening Brief that $1.151 million of hydraulic services funding was eliminated in its 2021 EE Annual Budget Advice Letter (ABAL), due on September 1, 2020.

SCE-14, Vol. 1, pp. 64-68

SCE Position:

PAO Position:

TURN Position:

SCE-03, Vol. 5

SCEFERCAccount

BPEGRC Activity

PAO vs SCE

TURN vs SCE

TURNPAO

PAO recommends that SCE continue to request and account for the costs associated with hydraulic services in its EE portfolio funding and expresses concern that SCE has not provided sufficient evidence that the costs for hydraulic services should be moved from the EE portfolio to the GRC or that SCE will actually remove those costs from its next EE ABAL filing.

TURN rejects SCE’s requested increase because GRC funding should not be increased because SCE plans to reduce spending in EE. Furthermore, ratepayers should not simply take SCE’s word that it will seek the reduction in the next EE ABAL filing. TURN recommends a reduction of $1.151 million.

PAO-08, p. 32

TURN-06, pp. 18-19


908 | Business Account Management Services

Labor (932)4,049 3,117 3,137(912)

Non-Labor (219)960 741 721(239)

Total (1,151) (1,151)5,009 3,858 3,858

Business Account Management Services

(1,151) (1,151)5,009 3,858 3,858



2021 Test Year

Exhibit:

Cost Component:

BPG:

Witness:

Issue Title:




2018$ in Thousands

TURN-NDC-44 | Credit and Payment

O&M

Billing & Payments

Brandi Anderson (SCE), David Cheng (TURN), Faith Bautista (NDC)

SCE’s Test Year $637,000 forecast increase in labor expense is reasonable and should be based on the incoming work volume forecast method that provides a more accurate forecast of credit and payment services work volume during the GRC period.

SCE-14, Vol. 1, pp. 15-20; SCE-3, Vol.1AE

SCE Position:

TURN Position:

NDC Position:

SCE-03, Vol. 1

SCEFERCAccount

BPEGRC Activity

TURN vs SCE

TURN NDC vs SCE

NDC

TURN rejects the $637,000 labor forecast of SCE’s Test Year Adjustment for increased processing for several reasons. SCE provides no justification for its forecast and also mistakenly calculated the growth. In addition, labor costs for Credit and Payment Services has been declining from 2014 to 2018. Lastly, the mix of electronic payments has been increasing since 2014 and average cost per payment has been steadily decreasing every year since 2014.

NDC rejects the $637,000 labor forecast of SCE’s Test Year Adjustment for increased processing stating that the new forecast method SCE used does not determine that Credit and Payment Services cannot handle the volume of work being tracked.

TURN-06, pp. 8-9

NDC-01, pp. 11-18

Billing & Payments


Labor 637 0(637) (637) 0

Total (637)637 0 (637) 0

Credit and Payment

(637)637 0

SCE reduced its forecast by $8K for a change in the customer growth rate. See Issue SCE-001 Billing & Payments | Credit and Payment for additional information regarding NDC’s position.

(637) 0



2021 Test Year

Exhibit:

Cost Component:

BPG:

Witness:

Issue Title:




2018$ in Thousands

PAO-TURN-61 | Service Guarantee Program

O&M

Other Operating Revenue


SCE’s direct showing justifies the Commission reversing its current policy that Service Guarantees be funded by shareholders. Neither PAO’ nor TURN’s testimony rebut SCE’s factual showing that Service Guarantees are a reasonable cost of SCE’s business appropriate for ratepayer funding, considering the alternative of SCE spending approximately $100 million – or 100 times the cost of Service Guarantees – to achieve a near 100 percent Service Guarantee success rate. Service guarantees are a reasonable cost of providing service to customers in the most cost-effective manner.

SCE-03, Vol. 6A, SCE-14, Vol. 1

SCE Position:

PAO Position:

TURN Position:

SCE-03, Vol. 6

SCEFERCAccount

BPEGRC Activity

PAO vs SCE

TURN vs SCE

TURNPAO

PAO recommends that the Commission reject SCE’s request for ratepayer funding of Service Guarantees because SCE has not provided new or persuasive arguments for the Commission to reverse its current policy that shareholders must fund Service Guarantees.

TURN recommends that the Commission reject SCE’s request for ratepayer funding of Service Guarantees because the Commission has repeatedly rejected SCE’s request for ratepayer funding of this program in 2006, 2009, 2012, 2015, and again in 2019. The Commission noted that the service guarantee creates an incentive for SCE to meet these goals, and that incentive is most effective when it is paid 7 by the shareholders, not ratepayers.

PAO-08P, pp. 38-39

TURN-06, p. 20


451 | Service Guarantee Program

Other 985(985) 0 0985

Total 985 985(985) 0 0

Service Guarantee Program

985 985(985) 0 0



2021 Test Year

Exhibit:

Cost Component:

BPG:

Witness:

Issue Title:




2018$ in Thousands

PAO-TURN-69 | Transportation Electrification

O&M

Transportation Electrification

Carter Prescott (SCE), Dao Phan (PAO), David Cheng (TURN)

SCE has a key role in achieving the State’s transportation electrification (TE) goals and the activities that will be funded by the forecast in this GRC are not program specific or precede the approval of a program and thus cannot be charged to the program. TE work activities described in SCE’s testimony, and for which SCE requests additional GRC funding, are separate and distinct from work activities described in other SCE’s TE proceedings and require funding in this GRC. No party has identified any duplicate funding. SCE's forecast is not premature and the TE activities are key to delivering on SB 350. Lastly, the assertion that TE funding in this GRC is unfounded and unsupported by any credible evidence.

SCE-14, Vol. 1, pp.69-77.

SCE Position:

PAO Position:

TURN Position:

SCE-03, Vol. 5

SCEFERCAccount

BPEGRC Activity

PAO vs SCE

TURN vs SCE

TURNPAO

SCE already receives funding for the TE activities it requests in this GRC. The TE work activities described in SCE’s testimony, and for which SCE requests additional GRC funding are very similar to the work activities described in other SCE’s TE proceedings. PAO is concerned that if SCE’s request is authorized, ratepayers might be paying twice for services through multiple funding sources. It is premature for SCE to request TE funding in this GRC when its TE portfolio is still being evaluated.

TURN agrees with PAO position and in addition, specifically recommends rejection of SCE’s non- labor TE funding request because conference sponsorships and trade group memberships generate good public relations for SCE and external engagement sounds like lobbying activities and should be disallowed. TURN recommends a reduction of $3.566 million.

PAO-08P, pp. 35-37

TURN-06, pp. 19-20


908 | Transportation Electrification

Labor (2,816)2,816 0 0(2,816)

Non-Labor (750)750 0 0(750)

Total (3,566) (3,566)3,566 0 0


(3,566) (3,566)3,566 0 0



2021 Test Year

Exhibit:

Cost Component:

BPG:

Witness:

Issue Title:



PAO-TURN-NDC-45 | Customer Communications, Education and Outreach: AIM Initiative & Other

O&M

Communications, Education & Outreach

Jessica Lim (SCE), Dao Phan (PAO), David Cheng (TURN), Faith Bautista (NDC)

SCE's $5.2 million forecast for the Analytics & Integrated Marketing (AIM) initiative should be approved. No party disputes the AIM cost savings of approximately $3.3 million which directly offset the $5.2 million AIM cost. AIM also has substantial long-term operational benefits that show a positive benefit-to-cost ratio that negates PAO and TURN’s primary objection to funding the AIM initiative. PAO’ claim that there is no need for SCE to adopt new measures to increase customer participation in paperless billing is wrong. Additionally, PAO is wrong to assume that PSPS funds can be used for some of the AIM initiative communications. SCE’s forecast of $1.047 million for Education and Awareness, comprised of $217,000 for Critical Peak Pricing (CPP) and $831,000 for Building Electrification (BE), is reasonable for the education and outreach to the customers of those programs (note, TURN uses the amount $1.482 million which was corrected in errata to $1.047 million). NDC's recommendation concerning In-Language Outreach is not supported and there is no basis for requiring SCE to provide more information on how it determines which customers to target.

SCE-14, Vol. 1, pp. 24-38; SCE-03, Vol. 2E

PAO recommends removal of SCE’s $5.2 million AIM Test Year adjustment. PAO concludes that the AIM benefits do not justify the costs. PAO states that SCE is already among the top 10 utilities with customers receiving bills electronically, and thus there is no need to burden customers with an additional expense to continue accelerating electronic billing adoption. PAO also contends that SCE already receives annual funding for campaigns to convert customers to adopt paperless billing, so there is no need for an additional $1.232 million as part of AIM for sending targeted marketing materials encouraging paperless billing. Finally, PAO contends that $2.122 million requested as part of the AIM initiative for communications to update customer contacts in High Fire Risk Area (HFRA) is inappropriate because SCE is already receiving funding to communicate with HFRA customers in other proceedings.

PAO-08, p. 15-16

TURN rejects SCE’s $5.2 million AIM Test Year Adjustment and $1.482 million forecast for Education and Awareness for CPP and BE. TURN states that SCE’s AIM effort does not identify any cost reductions for existing analytics and marketing labor costs, nor does SCE outline a plan to develop the necessary skillsets for an in-house labor pool. With regard to Education and Awareness for CPP and BE, TURN states that SCE’s request should be rejected because it is not reasonable to spend more money on education and communication after defaulting customers to CPP than before or during the mass transition. TURN also asserts that SCE does not explain why it is not able to use existing authorized marketing to purchase mass media buys to educate customers about BE and recommends that SCE shift existing media buys to communicate a new message instead of increasing expenses for media buys.

TURN-06, pp.11-12

SCE Position:

PAO Position:

TURN Position:

SCE-03, Vol. 2

NDC does not recommend any reductions to SCE’s 2021 forecast. NDC makes recommendations concerning both SCE’s in-language outreach efforts and Energy Education Centers (EECs). For in-language outreach, NDC recommends that SCE rely upon more up-to-date survey information to target non-English speaking communities and use cost-effective means to reach out to smaller ethnic groups, such as through partnerships with CBOs. For EECs, NDC recommends SCE track the demographics by ethnicity of those who attend workshops and seminars and that SCE track and provide in future testimony an itemized breakdown of expenditures incurred for seminars and workshops conducted by the EECs.

NDC-01 pp. 21 - 23

NDC Position:



2021 Test Year


2018$ in Thousands

SCEFERCAccoun

BPEGRC Activity

PAO vs SCE

TURN vs SCE

TURN NDC vs SCE

NDCPAO

908 | Customer Communications, Education and Outreach

Labor 5870 0587 5870587

Non-Labor 5020 0502 5020502

Total 0 01,089 1,089 1,089 0 1,089

909 | Customer Communications, Education and Outreach

Labor 1,173(1,352) 01,173 1,1730(179)

Non-Labor 250(3,848) (6,682)6,932 6,93203,084

Total (5,200) (6,682)8,105 2,905 1,423 0 8,105

Customer Communications, Education and OutreachTotal:

(5,200) (6,682)9,193 3,993 2,511 0 9,193




165

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166



167


2021 Test Year

Exhibit:

Cost Component:

BPG:

Witness:

Issue Title:




2018$ in Thousands

PAO-46 | Cybersecurity O&M

O&M

Cybersecurity

Glenn Haddox (SCE), Monica Weaver (PAO)

SCE has provided a well-documented and detailed forecast of Cybersecurity O&M, based on last year recorded plus incremental amounts needed to address developing cyber threats. PAO’ forecast is based on misinterpretations of several data requests and does not account for costs associated with new initiatives.

SCE-15, Vol. 3, pp. 4-11

PAO Position: PAO’ 2021 forecast is based on the 2019 forecast for labor and 2018 recorded for non-labor. PAO oppose certain adjustments in the labor forecast, and propose the lower non-labor forecast because SCE's forecast is significantly higher than the recorded amounts.

PAO-07, pp. 22-24

SCE Position:

SCE-04, Vol. 3

SCEFERCAccount

BPEGRC Activity

PAO vs SCE

PAO

920921 | Cybersecurity Delivery and IT Compliance

Labor 19,982 (5,129) 14,853

Non-Labor 12,250 (6,175) 6,075

32,232Total (11,304) 20,928

32,232

Cybersecurity Delivery and IT Compliance Total:

(11,304) 20,928



2021 Test Year

Exhibit:

Cost Component:

BPG:

Witness:

Issue Title:




2018$ in Thousands

PAO-82 | Wildfire EOI O&M

O&M

Wildfire Management

Rajdeep Roy (SCE), Tamera Godfrey (PAO)

SCE conducts rigorous, risk-based inspections of all overhead structures in the HFRA, and conducts recommended maintenance (M&I). SCE adjusted its compliance inspection and maintenance costs to reflect these additional efforts. PAO reduces EOI M&I to zero for distribution and transmission, erroneously asserting that the compliance activities already include needed funding. PAO also reduces by two-thirds costs needed for ongoing support of EOI maintenance, which is inconsistent with PAO’ adoption of SCE’s EOI capital repairs expenditures forecast.

SCE-15, Vol. 5 pp. 52-67

PAO Position: PAO utilized SCE’s 2018 expenses as a basis and normalized SCE’s incremental request of $12.691 million for its Aerial Inspections and EOI Program Management Office of $15.395 million over the three year-rate case cycle to account for similar activities that have costs included in rates and to provide funding for additional TY activities and due to SCE’s Aerial Inspections Program lacking supporting detail.

PAO-06, pp 62-67

SCE Position:

SCE-04, Vol. 5

SCEFERCAccount

BPEGRC Activity

PAO vs SCE

PAO

571 | Enhanced Overhead Inspections and Remediations

Labor 997 (997) 0

Non-Labor 5,650 (5,650) 0

6,647Total (6,647) 0


Labor 9,626 (9,627) 0

Non-Labor 12,691 (8,461) 4,230

22,318Total (18,088) 4,230


Labor 2,183 51 2,234

Non-Labor 23,084 (15,323) 7,761

25,267Total (15,272) 9,995

54,232

Enhanced Overhead Inspections and Remediations Total:

(40,006) 14,225



2021 Test Year

Exhibit:

Cost Component:

BPG:

Witness:

Issue Title:




2018$ in Thousands

PAO-83 | Wildfire Organizational Change Management O&M

O&M

Wildfire Management

Rajdeep Roy (SCE), Tamera Godfrey (PAO)

Organization Change Management (OCM) helps to increase awareness, understanding and knowledge, internally and externally, of the many changes resulting from SCE's wildfire programs. OCM is a best practice with large scale programs and changes, as the Commission has recognized in the past. The Wildfire OCM is an incremental request, not duplicative of previous funding or other OCM programs in the company.

SCE-15, Vol. 5, pp. 45-49

PAO Position: PAO recommends no ratepayer funding in the TY. The proposed activities are to perform normal, routine, and ongoing activities and the activities are essentially duplicative to the type of organizational management functions traditionally performed by SCE and embedded in historical expenses.

PAO-06, pp. 55-56

SCE Position:

SCE-04, Vol. 5

SCEFERCAccount

BPEGRC Activity

PAO vs SCE

PAO

588 | Organizational Support

Non-Labor 645 (645) 0

645Total (645) 0

920921 | Organizational Support

Labor 0 0 0

Non-Labor 2,708 (2,708) 0

2,708Total (2,708) 0

3,354

Organizational Support Total:

(3,354) 0



2021 Test Year

Exhibit:

Cost Component:

BPG:

Witness:

Issue Title:




2018$ in Thousands

TURN-84 | Distribution Fault Anticipation O&M

O&M

Wildfire Management

Andrew Swisher (SCE), Eric Borden (TURN)

SCE plans to install Distribution Fault Anticipation, a technology utilizing a proven algorithm that will identify incipient faults avoid site visits to collect fault data from remote sites, and monitor equipment, such as capacitor banks, to identify repair or replacement prior to failure. SCE has deployed 60 devices as a pilot and was able to identify a number of incipient faults and had minimal experience with false alarms.

SCE-15, Vol. 5, p. 44

TURN Position: TURN's position on DFA O&M follows its position on DFA capital. DFA is an unproven technology that SCE is piloting. A full and deployment should wait until SCE delivers the Commission a full report demonstrating that SCE is able to isolate only those voltage and current signatures that indicate equipment will soon fail. TURN also raises concerns related to false alarms diverting resources.

TURN-02, pp. 8 - 10

SCE Position:

SCE-04, Vol. 5

SCEFERCAccount

BPEGRC Activity

TURN vs SCE

TURN

592 | Distribution Fault Anticipation

Non-Labor 68 0(68)

68Total (68) 0

68

Distribution Fault Anticipation Total:

(68) 0



2021 Test Year

Exhibit:

Cost Component:

BPG:

Witness:

Issue Title:




2018$ in Thousands

PAO-85 | Community Resiliency Incentives

O&M

Wildfire Management

Kari Gardner (SCE), Tamera Godfrey (PAO)

The Community Resiliency Equipment program provides certain customers with incentives to acquire microgrid control technology to enable self-supply and provide support to the community during PSPS events and disasters. The program also offers incentives to low-income medical baseline customers to acquire battery backup. PAO's unsupported assertion that there is overlap with funding with the SGIP is wrong, and their assertion that shareholders benefit from the program is similarly unfounded and wrong.

SCE-15, Vol. 5, pp. 69-74

PAO Position: PAO normalized SCE’s incremental request over the three year-rate case cycle to account for similar activities that have costs included in rates. SCE’s proposal lacks specific details regarding the relationship and administration of this program and the Self-Generation Incentive Program that has costs embedded in rates. PAO’s recommendation will provide additional funding to continue to help close the gap for some customers who may decide to invest in an energy storage system with islanding capabilities.

PAO-06, pp. 51-55

SCE Position:

SCE-04, Vol. 5

SCEFERCAccount

BPEGRC Activity

PAO vs SCE

PAO

908 | Community Resiliency Incentives

Labor 191 (122) 69

Non-Labor 3,259 (2,178) 1,081

3,450Total (2,300) 1,150

3,450

Community Resiliency Incentives Total:

(2,300) 1,150



2021 Test Year

Exhibit:

Cost Component:

BPG:

Witness:

Issue Title:




2018$ in Thousands

PAO-86 | Business Continuation O&M

O&M

Business Continuation

Donald Daigler (SCE), Monica Weaver (PAO)

All Hazards Assessment and Mitigation forecasts are based on a detailed, bottoms-up analysis of the costs and activities needed to support SCE's all hazards, seismic and climate change mitigation efforts. Costs have increased from 2016- 2018 as activities have increased, and correspond to the increasing level of capital expenditures for hazards and seismic mitigation. Because the costs trended up, PAO is incorrect in characterizing them as 'fluctuating'.

SCE-15, Vol. 1, pp. 4-6

PAO Position: Non-labor costs have fluctuated so the 2019 forecast should be used, as this smooth out the fluctuations.

PAO-07, pp. 18-19

SCE Position:

SCE-04, Vol. 1

SCEFERCAccount

BPEGRC Activity

PAO vs SCE

PAO

935 | All Hazards Assessment, Mitigation and Analytics

Non-Labor 2,500 0 2,500

2,500Total 0 2,500

920921 | All Hazards Assessment, Mitigation and Analytics

Labor 479 0 479

Non-Labor 1,004 (204) 800

1,483Total (204) 1,279

3,983

All Hazards Assessment, Mitigation and Analytics Total:

(204) 3,779



2021 Test Year

Exhibit:

Cost Component:

BPG:

Witness:

Issue Title:




2018$ in Thousands

PAO-87 | Enhanced Situational Awareness

O&M

Wildfire Management

Donald Daigler (SCE), Tamera Godfrey (PAO)

Enhanced Situational Awareness; Comprehensive Situational awareness is fundamental to all- hazards emergency response and operational decision making. SCE has created the Situational Awareness Center, and staffed it with meteorologists with access to precise weather forecasts and analytics to support forecasting and wildfire preparation. SCE is requesting capital and expense funding for advanced weather stations and high definition cameras to support the analytics needed for wildfire forecasting. SCE’s request for Enhanced Situational Awareness is a based on a bottoms-up, detailed analysis and is incremental to its ongoing activities, included as part of the Emergency Management volume, SCE-04, Vol. 2. PAO’s proposed O&M reductions are inconsistent with the full funding for capital expenditures, and would result in SCE installing new weather stations, but not being able to maintain or replace them, or to utilize the data provided by the stations to improve prediction of wildfires or improve response time.

SCE-04 Vol. 5A, pp. 88-95, SCE-15, Vol. 5, pp. 75-77

PAO Position: SCE’s request for Enhanced Situational Awareness does not reflect embedded funding in similar, on-going situational awareness activities.

PAO-6, pp. 59-62

SCE Position:

SCE-04, Vol. 5

SCEFERCAccount

BPEGRC Activity

PAO vs SCE

PAO

920921 | Enhanced Situational Awareness

Labor 460 (68) 392

Non-Labor 3,134 (466) 2,668

3,594Total (534) 3,060

3,594

Enhanced Situational Awareness Total:

(534) 3,060



2021 Test Year

Exhibit:

Cost Component:

BPG:

Witness:

Issue Title:




2018$ in Thousands

PAO-88 | Fire Science and Advanced Modeling

O&M

Wildfire Management

Donald Daigler (SCE), Mark Waterworth (PAO)

Fire Science is the gathering and integration of science and technology to help wildfire mitigation efforts. This is new science on new hardware, using newly collected data, and funding for this was adopted as part of the GSRP settlement. PAO’s assertion that funding should be reduced because of similar sounding activities is unfounded. PAO’s reduction for O&M is inconsistent with its propose dull funding of the corresponding capital expenditures, and would result in having computers for modeling, but no data to model.

SCE-15, Vol. 5, pp. 78-80

PAO Position: The test year forecast should be reduced because SCE has failed to include similar historical costs in its calculations.

PAO-10, pp. 56-59

SCE Position:

SCE-04, Vol. 5

SCEFERCAccount

BPEGRC Activity

PAO vs SCE

PAO

920921 | Fire Science and Advanced Modeling

Non-Labor 3,948 (1,744) 2,204

3,948Total (1,744) 2,204

3,948

Fire Science and Advanced Modeling Total:

(1,744) 2,204



2021 Test Year

Exhibit:

Cost Component:

BPG:

Witness:

Issue Title:




2018$ in Thousands

PAO-90 | Security Technology Operations & Maintenance

O&M

Physical Security

Alex Benoliel (SCE), Monica Weaver (PAO)

SCE has provided a detailed, bottoms up forecast of its test year request, which PAO have not challenged. PAO have used a distorted view of historical data to argue that there are large fluctuations in historical non-labor costs, so the forecast should be based on an average. The actual costs for Security Technology have been relatively stable, undermining the premise of PAO’s position.

SCE-15, Vol. 4, pp.3-5

PAO Position: Recorded non-labor costs have fluctuated significantly, so the test year forecast should be based on the average of recorded 2018 and forecast 2019.

PAO-07, p. 25

SCE Position:

SCE-04, Vol. 4

SCEFERCAccount

BPEGRC Activity

PAO vs SCE

PAO

920921 | Security Technology Operations and Maintenance

Non-Labor 17,186 (524) 16,662

17,186Total (524) 16,662

17,186

Security Technology Operations and Maintenance Total:

(524) 16,662




177


2021 Test Year


Exhibit:

Cost Component:

Witness:


BPE:


Cybersecurity


SCE's forecast of Perimeter Defense is itemized, detailed and risk based. SCE's forecast also accurately reflects the impact from the convergence of analog operational systems being converted to digital streams. SCE’s 2021 forecast includes spending to address 4 new initiatives: 1) IGAM for access management, 2) IT/OT convergence of analog systems into the digital environment, 3) foundational tools, and 4) Labs. The 2021 levels for these initiatives are not reflected in the 2019 recorded or the 2020 forecast.

SCE-15, Vol. 3, pp. 11-16

PAO Position: PAO believes that expenditures for Perimeter defense have fluctuated, so proposes the two-year average forecasts of 2019-2020 for the 2021 forecast.

PAO-07, pp. 33-34.


$ in Thousands

Issue Title: PAO-18 | Cybersecurity Capital

SCE Position:

SCE-04, Vol. 3


Cybersecurity | Cybersecurity Delivery and IT Compliance

795 | CIT-00-TR-RM-000001

SCE

PAO

20,907

3,208 2,478 5,478 5,678 4,479 21,321

2,793 2,478 5,478 5,678 4,479

PAO vs SCE 414 0 0 0 0 414

796 | CIT-00-TR-RM-000002

SCE

PAO

156,337

16,099 19,602 17,850 37,415 35,417 126,384

26,476 19,452 37,577 37,415 35,417

PAO vs SCE (10,376) 150 (19,727) 0 0 (29,953)

797 | CIT-00-TR-RM-000003

SCE

PAO

42,986

5,991 7,268 8,571 8,571 12,373 42,775

6,203 7,268 8,571 8,571 12,373

PAO vs SCE (211) 0 0 0 0 (211)

798 | CIT-00-TR-RM-000004

SCE

PAO

40,049

8,254 8,103 8,107 8,108 8,111 40,683

7,620 8,103 8,107 8,108 8,111

PAO vs SCE 634 0 0 0 0 634



2021 Test Year

799 | CIT-00-TR-RM-000017

SCE

PAO

11,816

2,448 2,549 2,551 2,552 2,553 12,654

1,610 2,549 2,551 2,552 2,553

PAO vs SCE 838 0 0 0 0 838

Total Cybersecurity Delivery and IT Compliance:

SCE

PAO 36,000

44,701 39,850 62,285 62,324 62,934 272,095

40,000 42,558 62,324 62,934 243,817

PAO vs SCE (8,701) 150 (19,727) 0 0 (28,278)



2021 Test Year


Exhibit:

Cost Component:

Witness:


BPE:


Wildfire Management


SCE plans to install Distribution Fault Anticipation, a technology utilizing a proven algorithm that will identify incipient faults, help SCE pinpoint fault locations, and monitor equipment, such as capacitor banks, to identify repair or replacement prior to failure. SCE has deployed 60 devices as a pilot and was able to identify a number of locations for proactive remediations and had minimal experience with false alarms.

SCE-15, pp. 37-39, 42

TURN Position: DFA is an unproven technology that SCE is piloting. A full, and deployment should wait until SCE delivers the Commission a full report demonstrating that SCE is able to isolate only those voltage and current signatures that indicate equipment will soon fail. TURN also raises concerns related to false alarms diverting resources.

TURN-02, pp. 8 - 10


$ in Thousands

Issue Title: TURN-19 | Distribution Fault Anticipation

SCE Position:

SCE-04, Vol. 5


Wildfire Management | Distribution Fault Anticipation

821 | CET-PD-WM-FI-MTW

SCE

TURN

35,891

3,445 0 0 0 0 3,445

3,445 0 6,270 12,903 13,274

TURN vs SCE 0 0 (6,270) (12,903) (13,274) (32,446)

Total Distribution Fault Anticipation:

SCE

TURN 3,445

3,445 0 6,270 12,903 13,274 35,891

0 0 0 0 3,445

TURN vs SCE 0 0 (6,270) (12,903) (13,274) (32,446)



2021 Test Year


Exhibit:

Cost Component:

Witness:


BPE:


Wildfire Management


SCE has identified 190 Vertical Switches in the HFRA. Detailed inspections have shown that 45 of them present an ignition risk, and the remaining ones are at risk to create future ignition risks due to mountings on wood cross arms that are subject to changes in dimensions.

SCE-15, Vol. 5, pp. 49-52

TURN Position: SCE has not demonstrated that its proposal to replace the entire population of vertical switches will have any benefit for the prevention of ignitions that cause wildfires. TURN states that premature replacement results in stranded asset costs and a higher than necessary forecast.

TURN-02, pp. 10 - 11


$ in Thousands

Issue Title: TURN-22 | Vertical Switches

SCE Position:

SCE-04, Vol. 5


Wildfire Management | Enhanced Overhead Inspections and Remediations

823 | CET-PD-WM-OC-MTECOV

SCE

TURN

5,294

0 0 0 0 0 0

0 0 804 1,654 2,836

TURN vs SCE 0 0 (804) (1,654) (2,836) (5,294)

Total Enhanced Overhead Inspections and Remediations:

SCE

TURN 0

0 0 804 1,654 2,836 5,294

0 0 0 0 0

TURN vs SCE 0 0 (804) (1,654) (2,836) (5,294)



2021 Test Year


Exhibit:

Cost Component:

Witness:


BPE:


Cybersecurity


SCE's forecast of Grid-Mod Cybersecurity reflects the cybersecurity needs and risks posed by the deployment of multiple systems, such as the FAN, the WAN, GMS and the Common Substation Platform needed in 2021. PAO does not take issue with any of the underlying support for SCE’s forecast but artificially reduces the forecast by taking an average of two years with differing levels of activity.

SCE-15, Vol. 3, pp. 11-16

PAO Position: SCE's Grid Mod Cybersecurity forecast for 2021 is more than double 2018 recorded, so the 2021 forecast should be the average of 2019 and 2020.

PAO-07, pp. 33-34.


$ in Thousands

Issue Title: PAO-24 | Grid Mod Cybersecurity Capital

SCE Position:

SCE-04, Vol. 3


Cybersecurity | Grid Mod Cybersecurity

800 | CIT-00-TR-RM-781701

SCE

PAO

161,282

25,702 24,949 25,542 28,934 36,426 141,554

26,136 24,542 45,245 28,934 36,426

PAO vs SCE (433) 408 (19,703) 0 0 (19,728)

Total Grid Mod Cybersecurity:

SCE

PAO 25,702

26,136 24,542 45,245 28,934 36,426 161,282

24,949 25,542 28,934 36,426 141,554

PAO vs SCE (433) 408 (19,703) 0 0 (19,729)



2021 Test Year


Exhibit:

Cost Component:

Witness:


BPE:


Physical Security

Randall White (SCE), Monica Weaver (PAO)

Protection of Grid Infrastructure involves protecting of key grid assets, such as large substations, that have been subject to attacks in recent years. SCE has developed a detailed, project by project forecast of the capital expenditures for 2020 and 2021, and accepts the lower 2019 recorded figure. PAO’ methodology is flawed because it relies on a nominal five-year average, instead of using constant dollars. PAO does not question the need for any of the projects, nor the underlying forecasts. PAO’ proposal is based on the single data point, that 2019 recorded was lower than the 2019 forecast. SCE has provided a clear explanation of the 2019 outcome.

SCE-15, Vol. 4, pp. 7-9

PAO Position: PAO notes that 2019 recorded was below the 2019 forecast. Based on that PAO proposes that 2020 forecast be set at the five-year average 2015-201in nominal dollars, and 2021 forecast be set at 2020 forecast escalated by two percent.

PAO-07, pp. 35-37


$ in Thousands

Issue Title: PAO-29 | Protection of Grid Infrastructure

SCE Position:

SCE-04, Vol. 4


Physical Security | Protection of Grid Infrastructure Assets

810 | CET-ET-IR-ME-757300

SCE

PAO

28,148

4,978 3,769 3,145 3,971 9,652 25,514

510 8,834 5,182 3,971 9,652

PAO vs SCE 4,469 (5,065) (2,037) 0 0 (2,634)

811 | CET-ET-IR-ME-757301

SCE

PAO

12,385

0 47 1,783 5,047 401 7,278

3,889 110 2,938 5,047 401

PAO vs SCE (3,889) (63) (1,155) 0 0 (5,107)

813 | CET-ET-IR-ME-804200 (CPUC)

SCE

PAO

399

28 73 122 0 0 223

27 170 202 0 0

PAO vs SCE 1 (97) (80) 0 0 (176)

813 | CET-ET-IR-ME-804200 (FERC)

SCE

PAO

1,850

124 330 560 0 0 1,014

155 774 922 0 0

PAO vs SCE (31) (444) (362) 0 0 (836)



2021 Test Year

814 | CET-ET-IR-ME-804201

SCE

PAO

5,628

92 1,975 606 0 0 2,673

0 4,629 999 0 0

PAO vs SCE 92 (2,654) (393) 0 0 (2,955)

815 | CET-ET-IR-ME-804202

SCE

PAO

4,566

89 1,598 498 0 0 2,186

0 3,745 820 0 0

PAO vs SCE 89 (2,147) (322) 0 0 (2,380)

816 | CET-ET-IR-ME-804203

SCE

PAO

17,639

89 1,667 671 10,098 2,527 15,053

0 3,908 1,105 10,098 2,527

PAO vs SCE 89 (2,241) (434) 0 0 (2,586)

817 | CET-ET-IR-ME-804204 (CPUC)

SCE

PAO

525

10 184 57 0 0 251

0 431 94 0 0

PAO vs SCE 10 (247) (37) 0 0 (274)

817 | CET-ET-IR-ME-804204 (FERC)

SCE

PAO

4,251

79 1,489 462 0 0 2,030

0 3,489 762 0 0

PAO vs SCE 79 (2,000) (300) 0 0 (2,221)

818 | CET-ET-IR-ME-804207

SCE

PAO

774

93 152 252 0 0 497

0 357 416 0 0

PAO vs SCE 93 (205) (164) 0 0 (277)

809 | CIT-00-DM-DM-000188

SCE

PAO

3,350

1,546 990 625 0 0 3,161

0 2,320 1,030 0 0

PAO vs SCE 1,546 (1,330) (405) 0 0 (189)

812 | COS-00-CS-CS-745400 (CPUC)

SCE

PAO

27,056

2,455 1,778 3,388 6,783 7,006 21,410

3,518 4,167 5,582 6,783 7,006

PAO vs SCE (1,063) (2,389) (2,194) 0 0 (5,646)

812 | COS-00-CS-CS-745400 (FERC)

SCE

PAO

37,159

3,369 2,440 4,650 9,310 9,615 29,384

4,854 5,719 7,661 9,310 9,615

PAO vs SCE (1,485) (3,279) (3,011) 0 0 (7,775)



2021 Test Year

Total Protection of Grid Infrastructure Assets:

SCE

PAO 12,952

12,952 38,652 27,715 35,210 29,201 143,729

16,491 16,821 35,210 29,201 110,674

PAO vs SCE 0 (22,161) (10,894) 0 0 (33,055)



2021 Test Year


Exhibit:

Cost Component:

Witness:


BPE:


$ in Thousands

Issue Title: PAO-TURN-14 | Business Continuation Capital


Business Continuation

Donald Daigler (SCE), Monica Weaver (PAO), John Defever (TURN)

SCE's forecast for the MEER buildings inside of Transmission Substations is based on third party cost estimates, adjusted up to reflect the unique operating conditions in large substations. SCE's forecasts of Non-electric buildings are developed using a cost per square foot methodology, and the cost per square foot used reflects the types of future construction included in the GRC period.

SCE-15, Vol. 1, pp. 7-11

PAO accepts 2019-2020 forecasts for Transmission Substations, but opposes the 2021 forecast. The forecast should be reduced by removing the 240% increase applied to the third-party cost estimates.

PAO-07, p. 29-30

TURN proposes to reduce spending for Non-electric facilities by removing the forecast costs included in the cost per square foot used to forecast expenditures, and removing contingency. TURN proposes to reduce Transmission Substation costs by removing the 35% contingency.

TURN-10, pp. 3-4

SCE Position:

PAO Position:

TURN Position:

SCE-04, Vol. 1


Business Continuation | Climate Adaptation and Severe Weather

791 | COS-00-BR-BR-000001

SCE

PAO

TURN

6,760

1,560

6,760

0 200 1,360 2,600 2,600

0 200 1,360

0 200 1,360 2,600 2,600

N/A N/A

0PAO vs SCE

TURN vs SCE 0

0

0

0

0

N/A

0

N/A

0

0

0

784 | COS-00-SP-BR-000000

SCE

PAO

TURN

3,920

4,500

3,920

1,220 2,100 300 300 0

2,100 2,100 300

1,220 2,100 300 300 0

N/A N/A

880PAO vs SCE

TURN vs SCE 0

0

0

0

0

N/A

0

N/A

0

880

0



2021 Test Year

785 | COS-00-SP-BR-000001

SCE

PAO

TURN

10,500

2,000

10,500

0 0 2,000 4,500 4,000

0 0 2,000

0 0 2,000 4,500 4,000

N/A N/A

0PAO vs SCE

TURN vs SCE 0

0

0

0

0

N/A

0

N/A

0

0

0

786 | COS-00-SP-PP-000000

SCE

PAO

TURN

4,057

2,400

4,057

857 800 800 800 800

800 800 800

857 800 800 800 800

N/A N/A

(57)PAO vs SCE

TURN vs SCE 0

0

0

0

0

N/A

0

N/A

0

(57)

0

787 | COS-00-SP-RE-000000

SCE

PAO

TURN

41,297

34,000

28,881

9,305 13,000 8,436 3,968 6,588

9,000 13,000 12,000

6,341 9,159 5,944 2,796 4,642

N/A N/A

(305)PAO vs SCE

TURN vs SCE (2,964)

0

(3,841)

3,564

(2,492)

N/A

(1,172)

N/A

(1,946)

3,259

(12,416)

788 | COS-00-SP-TD-000000 (CPUC)

SCE

PAO

TURN

59,444

22,811

45,057

11,376 8,640 8,224 16,912 14,292

8,640 8,640 5,531

11,376 8,640 4,842 10,951 9,248

N/A N/A

(2,736)PAO vs SCE

TURN vs SCE 0

0

0

(2,693)

(3,382)

N/A

(5,961)

N/A

(5,044)

(5,429)

(14,387)

788 | COS-00-SP-TD-000000 (FERC)

SCE

PAO

TURN

60,166

40,552

60,166

21,126 15,360 13,440 5,120 5,120

15,360 15,360 9,832

21,126 15,360 13,440 5,120 5,120

N/A N/A

(5,766)PAO vs SCE

TURN vs SCE 0

0

0

(3,608)

0

N/A

0

N/A

0

(9,374)

0

789 | COS-00-SP-TD-000002

SCE

PAO

TURN

13,900

11,300

13,900

0 4,000 3,300 3,300 3,300

4,000 4,000 3,300

0 4,000 3,300 3,300 3,300

N/A N/A

4,000PAO vs SCE

TURN vs SCE 0

0

0

0

0

N/A

0

N/A

0

4,000

0



2021 Test Year

790 | COS-00-SP-TD-000003

SCE

PAO

TURN

20,397

15,100

20,397

1,097 7,000 4,100 4,100 4,100

4,000 7,000 4,100

1,097 7,000 4,100 4,100 4,100

N/A N/A

2,903PAO vs SCE

TURN vs SCE 0

0

0

0

0

N/A

0

N/A

0

2,903

0

44,981SCE

PAO

TURN

Business Continuation Capital Total:

43,900

42,018

51,100

51,100

47,259

41,960

39,223

36,086

41,600

N/A

34,467

40,800

N/A

33,810

220,441

134,223

193,639

PAO vs SCE

TURN vs SCE

(1,081)

(2,964)

0 (2,737) N/A N/A

(3,841) (5,874) (7,133) (6,990)

(3,818)

(26,803)

SCE updated PAO position for WBS COS-00-SP-RE-000000 to reflect SCE's errata to the 2021-2023 forecast. PAO did not address the forecast for 2022-2023.



2021 Test Year


Exhibit:

Cost Component:

Witness:


BPE:


$ in Thousands

Issue Title: PAO-TURN-CUE-35 | Wildfire Covered Conductor Program


Wildfire Management

Rajdeep Roy (SCE), Scott Logan (PAO), Eric Borden (TURN), Robert Earle (CUE)

Wildfire Covered Conductor is SCE’s primary grid hardening wildfire mitigation measure, and SCE proposes to deploy it at the maximum possible rate, on a risk-prioritized basis in the HFRA. The program includes the removal of tree attachments and using fire resistant poles where appropriate. Deployment follows the risk prioritization curve, but each project requires, on average, an additional 20% in mileage to reflect operational considerations. While it is correct that the relative risk drops quickly with the miles deployed, absolute risk measures such as number of critical care customers and critical facilities, are critical, and many such customers and facilities are located further along the risk curve. Further, large fires have historically occurred on the parts of the curve with lower relative risk.

SCE-04, Vol. 5A, SCE-15, Vol. 5. Pp 10-37

SCE is unlikely to be able to execute on their ambitious goals for WCCP, so the 2021 forecast for WCCP should be set at the 2020 forecast, in nominal dollars of $533,803 (in thousands).

PAO-9, pp. 12-15

TURN proposes a slower pace for the deployment of covered conductor. Initial deployment should be targeted at the 25% of SCE’s High Fire Risk Area (HFRA) that represent around 95% of wildfire risk consequence. After the installation of 2,581 miles of covered conductor, there is a diminishing return on safety risk reduction. Given the cost of covered conductor, SCE’s proposal to address 6,200 miles, a large portion of which is for relatively low-risk circuits in the utility’s HFRA, is not reasonable. TURN’s also makes reductions to the budget for tree attachment and pole replacement consistent with the reduced scope, assuming that for 75% of poles fire resistant wrap is utilized rather than fire-resistant poles. TURN did not examine SCE’s 2020 program and has no recommendation for 2020.

TURN-02, pp. 11 - 26

SCE Position:

PAO Position:

TURN Position:

SCE-04, Vol. 5

CUE CUE supports SCE’s WCCP proposal. To the extent the Commission reduces wildfire capital management spending, the Commission should fund Distribution Infrastructure Replacement programs at higher levels.

CUE-02, pp 2-7



2021 Test Year


Wildfire Management | Wildfire Covered Conductor Program

842 | CET-PD-GR-FP-MTW

9,329 37,894 54,739 64,368 78,636

18,025 64,252 92,814 92,814 92,814

9,329 93,378 108,291 133,016

SCE

PAO

TURN

244,966

360,718

344,015

CUE 9,329 37,894 54,739 64,368 78,636 244,966

N/A

8,696PAO vs SCE

TURN vs SCE 0

26,358

N/A

38,075

38,639

28,445

43,923

14,178

54,380

115,751

99,048

CUE vs SCE 0 0 0 0 0 0

843 | CET-PD-GR-OC-MTW

239,911 454,369 656,353 771,815 942,892

127,465 454,369 419,057 419,057 419,057

239,911 108,508 99,436 80,685

SCE

PAO

TURN

3,065,339

1,839,005

528,539

CUE 239,911 454,369 656,353 771,815 942,892 3,065,339

N/A

(112,446)PAO vs SCE

TURN vs SCE 0

0

N/A

(237,296)

(547,845)

(352,758)

(672,379)

(523,835)

(862,207)

(1,226,334)

(2,536,799)

CUE vs SCE 0 0 0 0 0 0

844 | CET-PD-GR-TA-MTW

49 15,183 21,932 25,790 31,507

10,847 15,183 21,932 21,932 21,932

49 6,311 6,492 6,679

SCE

PAO

TURN

94,461

91,827

19,531

CUE 49 15,183 21,932 25,790 31,507 94,461

N/A

10,798PAO vs SCE

TURN vs SCE 0

0

N/A

0

(15,622)

(3,858)

(19,298)

(9,575)

(24,828)

(2,635)

(74,931)

CUE vs SCE 0 0 0 0 0 0

249,288SCE

PAO

TURN

Total Wildfire Covered Conductor Program

156,337

249,288

507,445

533,804

N/A

733,024

533,803

208,197

861,973

214,219

1,053,035

533,803

220,380

3,404,766

2,291,549

892,084

PAO vs SCE

TURN vs SCE

(92,952)

0

26,358 (199,221) (328,170) (519,232)

N/A (524,827) (647,754) (832,655)

(1,113,217)

(2,512,682)

249,288CUE 507,446 733,024 861,973 1,053,035 3,404,766

CUE vs SCE 0 0 0 0 0 0

533,803




191


2021 Test Year

Exhibit:

Cost Component:

BPG:

Witness:

Issue Title:




2018$ in Thousands

TURN-70 | Palo Verde

O&M

Palo Verde

Tom Champ (SCE), William Marcus (TURN)

SCE's position on TURN's recommendations: 1) SCE’s errata corrected the Test Year 2021 Palo Verde O&M non- labor forecast from nominal dollars into 2018 constant dollars. After the correction, TURN’s non-labor O&M forecast of $71.590 million is $1.516 million less than SCE’s corrected O&M non-labor forecast of $73.105 million and results from TURN’s use of the updated APS’ 2020 budget issued in July 2019 which was too late for inclusion in SCE GRC forecast. 2) the Nuclear Energy Institute (NEI) membership has provided benefits in excess of the costs of membership dues. SCE’s updated forecast removed the 2.5% dues attributed to NEI lobbying expenses and removed the Foundation for Nuclear Studies contribution totaling $8,526 (2018$, SCE share). 3) Palo Verde water sales revenues are appropriately accounted for as NTP&S revenue per D.99-09-070. Past treatment of these revenues proposed by SCE, and approved by the Commission, incorrectly offset O&M expenses to the benefit of customers. For the 2021 Test Year, water revenues should be accounted for as NTP&S.

SCE-16, Vol. 1, SCE-16, Vol. 1E, SCE-16, Vol. 1E3, SCE-05, Vol. 1, SCE-05, Vol.1E, SCE-05, Vol.1E2, SCE-05, Vol.1E3

TURN Position: TURN makes multiple recommendations for Palo Verde: 1) SCE’s Test Year Palo Verde O&M non-labor forecast should be reduced by 7.59% from 2018 actual spending or a reduction of $5.880 million in 2018 constant dollars to reflect the most recent budget adopted by the Palo Verde owners; 2) SCE’s share of Palo Verde’s annual Nuclear Energy Institute membership dues of $278,000 should be reduced by 50 percent or $139,000 consistent with Commission precedents; and 3) Palo Verde water sales revenues should be removed From Non-Tariffed Products and Services (NTP&S) and treated as an increase in Other Operating Revenues credited to customers.

TURN-09, p.4-9, 11-13

SCE Position:

SCE-05, Vol. 1



2021 Test Year

SCEFERCAccount

BPEGRC Activity

TURN vs SCE

TURN

517 | Palo Verde

Non-Labor 13,651 13,353(298)

13,651Total (298) 13,353

519 | Palo Verde

Non-Labor 7,183 7,021(162)

7,183Total (162) 7,021

520 | Palo Verde

Non-Labor 4,891 4,781(110)

4,891Total (110) 4,781

523 | Palo Verde

Non-Labor 5,936 5,803(134)

5,936Total (134) 5,803

524 | Palo Verde

Non-Labor 21,196 20,719(477)

21,196Total (477) 20,719

528 | Palo Verde

Non-Labor 3,055 2,987(69)

3,055Total (69) 2,987

529 | Palo Verde

Non-Labor 972 950(22)

972Total (22) 950

530 | Palo Verde

Non-Labor 10,513 10,277(237)

10,513Total (237) 10,277

531 | Palo Verde

Non-Labor 3,589 3,508(81)

3,589Total (81) 3,508

532 | Palo Verde

Non-Labor 1,047 1,023(24)

1,047Total (24) 1,023

556 | Palo Verde

Non-Labor 1,062 1,038(24)

1,062Total (24) 1,038

73,096Palo Verde Total:

(1,637) 71,459




194


2021 Test Year


Exhibit:

Cost Component:

Witness:


BPE:


$ in Thousands

Issue Title: PAO-TURN-16 | Planned Replacement of Catalina Diesel Generation Plants




SCE asks the commission to approve its capital forecast for the installation of new generation capacity in 2021. SCE disagrees with PAO’s recommendation that the Commission defer approval of project funding for the entire project to a separate proceeding after completion and TURN’s recommendation that SCE’s technology choices and capital spending be reviewed in the next GRC. The project as proposed in this GRC is reasonable and should be approved, based on the evidence presented by SCE: 1) Both PAO and Turn agree on the need for any replacement resources installed on Catalina to comply with air quality regulations, 2) the diesel generator technology meeting SCAQMD air emission requirements is the most technically feasible and commercially reasonable option with the least environmental impacts, 3) the near final feasibility study supports diesel engines to meet immediate emissions requirements as well as to reliably meet the full balance of electric load if and when renewables and storage would be implemented. For 2019, SCE updated its capital expenditure forecast to the recorded amounts. SCE is updating the Catalina Repower capital project based on witness testimony to reflect the fact that this project’s start date was delayed by approximately one year.

SCE-16, Vol. 01, pp. 27-35; Evidentiary Hearing, Transcripts at p. 549, line 10 through p. 551, line 12.

PAO recommends that the Catalina Repower project not be approved at this time because the study of options for new and cleaner generation capacity was not completed until early August 2020. If SCE does complete the project, SCE may file a separate application to seek cost recovery, but for the purposes of this GRC, the Catalina Repower project should be removed from the forecast.

PAO-09, p.9

TURN’s prepared testimony recommended that the Commission approve the installation and forecast for 2020-2021 but should make no prudence finding on the choice of the diesel units and project costs in the attrition years. As a result of information provided by SCE witnesses in response to cross-examination during evidentiary hearings, TURN has altered its recommendation for purposes of briefing. In briefs, TURN will urge the Commission to recognize that Rule 1135 permits SCE to request a three-year extension of the repowering requirements so long as two new diesel engines are installed by January 1, 2023. It therefore not reasonable to forecast the costs for installation of new diesel generation in 2021. Because SCE has presented only one of a number of options for compliance, TURN supports PAO’s recommendation to require SCE to file a separate application seeking cost recovery.

TURN-09, p. 23-25

SCE Position:

PAO Position:

TURN Position:

SCE-05, Vol. 1



845 | CG0-00-PP-CD-000002

756 203 5,013 6,046 0

756 0 0 0 0

756 0 0 0 0

SCE

PAO

TURN

12,019

756

756

0PAO vs SCE

TURN vs SCE 0

(203)

(203)

(5,013)

(5,013)

(6,046)

(6,046)

0

0

(11,263)

(11,263)



2021 Test Year



846 | CG0-00-PP-CD-000003

0 164 166 5,374 6,190

0 0 0 0 0

0 0 0 0 0

SCE

PAO

TURN

11,894

0

0

0PAO vs SCE

TURN vs SCE 0

(164)

(164)

(166)

(166)

(5,374)

(5,374)

(6,190)

(6,190)

(11,894)

(11,894)

847 | CG0-00-PP-CD-000004

0 133 121 80 4,810

0 0 0 0 0

0 0 0 0 0

SCE

PAO

TURN

5,143

0

0

0PAO vs SCE

TURN vs SCE 0

(133)

(133)

(121)

(121)

(80)

(80)

(4,810)

(4,810)

(5,143)

(5,143)

756SCE

PAO

TURN

Catalina - Diesel Total:

756

756

500

0

0

5,300

0

0

11,500

0

0

11,000

0

0

29,056

756

756

PAO vs SCE

TURN vs SCE

0

0

(500) (5,300) (11,500) (11,000)

(500) (5,300) (11,500) (11,000)

(28,300)

(28,300)



2021 Test Year


Exhibit:

Cost Component:

Witness:


BPE:


$ in Thousands

Issue Title: PAO-TURN-25 | Hydro Decommissioning Capital for San Gorgonio


Hydro


SCE’s 2019-2023 $6.705 million forecast for decommissioning San Gorgonio is properly in this rate case and TURN’s recommendation for a permanent disallowance should be rejected as factually and legally defective for several reasons. First, the decommissioning costs SCE has incurred are necessary to maintain the San Gorgonio facility in a safe condition and to fulfill regulatory and contractual requirements. Second, the decommissioning delays are due to third-party events beyond SCE’s control. Third, TURN impermissibly seeks to relitigate final Commission decisions regarding San Gorgonio in each of the past four GRCs that found the prior forecasts to be reasonable. Fourth, TURN mistakenly believes the $6.565 million capital forecast for San Gorgonio decommissioning in this GRC covers the entire project. The San Gorgonio decommissioning activities will take longer than five years to complete, and recent internal estimates indicate that the remaining costs of San Gorgonio decommissioning activities will exceed $48 million. SCE’s forecast also includes actual costs for 2019 of $0.790 million, an increase of $140,000 from the original forecast.

SCE-16, Vol. 1, pp. 9-17

PAO recommends that the 2019-2021 forecast of Hydro-related capital expenditures be adopted without reduction.

PAO-09, p. 2

TURN urges the Commission to reject cost recovery for this item on the basis that SCE requested and received funding for this project in the 2008, 2012, 2015, and 2018 GRCs but did not spent the authorized funds as intended and has yet to initiate the specific decommissioning activities described in each of the prior GRCs. Moreover, SCE failed to demonstrate that decommissioning activities are reasonably likely to commence during the current GRC cycle. TURN recommends a permanent disallowance of future expenditures for the San Gorgonio Decommissioning project. Alternatively, TURN recommends that the Commission authorize no expenditures in the current GRC due to the low likelihood that decommissioning activities will commence by 2023.

TURN-09, p. 15

SCE Position:

PAO Position:

TURN Position:

SCE-05, Vol. 1



850 | CG0-00-PP-HE-000017

790 2,250 2,250 1,145 270

650 2,250 2,250 1,145 270

0 0 0 0 0

SCE

PAO

TURN

6,705

6,565

0

(140)PAO vs SCE

TURN vs SCE (790)

0

(2,250)

0

(2,250)

0

(1,145)

0

(270)

(140)

(6,705)



2021 Test Year



790SCE

PAO

TURN

Hydro - Decommissioning Total:

650

0

2,250

2,250

0

2,250

2,250

0

1,145

1,145

0

270

270

0

6,705

6,565

0

PAO vs SCE

TURN vs SCE

(140)

(790)

0 0 0 0

(2,250) (2,250) (1,145) (270)

(140)

(6,705)



2021 Test Year


Exhibit:

Cost Component:

Witness:


BPE:


$ in Thousands

Issue Title: PAO-TURN-27 | Removal of the Mountainview Rotor Replacement Capital Project




SCE believes that due to changes in the generation operating profile at Mountainview, it is highly unlikely that the rotor replacement will need to occur during this GRC cycle. SCE thus does not oppose TURN’s recommendation to remove the Mountainview Rotor Replacement project from SCE’s forecast - $18 million in 2020 and $36 million in 2021. For 2019, the difference between SCE and PAO and TURN of $1.764 million is a result of recorded 2019 expenditures higher than forecast.

SCE-16, Vol. 1, pp. 20-21

PAO recommends that the forecast of Mountainview generation-related capital expenditures for 2019-2021 be adopted as initially proposed.

PAO-09, p. 2

TURN recommends adjustment of the Mountainview capital forecast by $54 million because SCE no longer plans to purchase new turbine rotors that it forecast: $18 million in 2020 and $36 million in 2021.

TURN-09, p.19

SCE Position:

PAO Position:

TURN Position:

SCE-05, Vol. 1


Fossil Fuel Generation | Mountainview

855 | CG0-00-PP-MV-000104

2,992 4,950 6,440 0 0

1,228 4,950 6,440 0 0

1,228 4,950 6,440 0 0

SCE

PAO

TURN

14,382

12,618

12,618

(1,764)PAO vs SCE

TURN vs SCE (1,764)

0

0

0

0

0

0

0

0

(1,764)

(1,764)

2,992SCE

PAO

TURN

Mountainview Total:

1,228

1,228

4,950

4,950

4,950

6,440

6,440

6,440

0

0

0

0

0

0

14,382

12,618

12,618

PAO vs SCE

TURN vs SCE

(1,764)

(1,764)

0 0 0 0

0 0 0 0

(1,764)

(1,764)

Please see SCE-001, SCE Agrees to Intervenors for the removal of the Mountainview rotor replacement capital project for SCE’s reduction in agreement to TURN.




200


2021 Test Year

Exhibit:

Cost Component:

BPG:

Witness:

Issue Title:




2018$ in Thousands

PAO-39 | Accounting, Financial Compliance, and Financial Reporting

O&M


April Li (SCE), Mark Waterworth (PAO)

SCE’s requests are modest and deliberate out of necessity. SCE's one-time recording timing difference without reducing the overall spending should not be treated as a permanent cost reduction. The temporary reduction in workforce coupled with an increase in workload is not sustainable or safe. SCE will have to add additional headcount and resume to the optimal level of personnel of staff to address and manage the increasing workload, and equally important, maintain a physically and psychologically safe working environment for our employees.

SCE-17, Vol. 02, pp. 06 -10

PAO Position: PAO recommends using the 2018 base year of $22.164 million resulting in a $2.083 million decrease. PAO claims that it is reasonable for SCE to maintain the current level (2018) of spending for both Labor and Non-Labor based on the achieved cost reductions, because additional funding beyond the base year defeats SCE’s Operational Excellence efforts.

PAO-10, Part 1, p. 13

SCE Position:

SCE-06, Vol. 2

SCEFERCAccount

BPEGRC Activity

PAO vs SCE

PAO

557 | Accounting, Financial Compliance and Financial Reporting

Labor 0 1,1151,115

Non-Labor 0 (20)(20)

1,095Total 0 1,095


Non-Labor (1,767) 8,38910,156

10,156Total (1,767) 8,389


Labor (316) 10,74911,065

Non-Labor 0 1,9321,932

12,997Total (316) 12,681

24,248

Accounting, Financial Compliance and Financial Reporting Total:

(2,083) 22,165Total



2021 Test Year

Exhibit:

Cost Component:

BPG:

Witness:

Issue Title:




2018$ in Thousands

PAO-40 | Audits

O&M

Audit, Ethics & Compliance

Joanne Tran (SCE), Chia Hadiprodjo Nawaz (PAO)

SCE asserts legal privilege with respect to the performance of a small subset of its audit reports. Neither PAO nor any other party challenged the legitimacy of SCE's assertion of legal privilege. SCE should not be punished for its lawful and reasonable protection of privileged audit material. SCE has provided PAO with unfettered access to the vast majority of audit materials, and PAO found no issues with those materials. Recent Commission precedent expressly supports SCE’s position and directly rejects PAO’ position.

SCE-17, Vol. 4, pp. 5-6; SCE-21, Vol. 1, pp. 2-5

PAO Position: PAO recommends removal of Audits O&M expenses because the value of the audit activity could not be independently verified due to SCE’s assertion of legal privilege.

PAO-18, p.4-7

SCE Position:

SCE-06, Vol. 4

SCEFERCAccount

BPEGRC Activity

PAO vs SCE

PAO

920921 | Audits

Labor (784) 3,9464,730

Non-Labor 0 4,9804,980

9,710Total (784) 8,926

9,710

Audits Total:

(784) 8,926Total



2021 Test Year

Exhibit:

Cost Component:

BPG:

Witness:

Issue Title:




2018$ in Thousands

PAO-47 | Rebuttal Policy, External Engagement and Ratemaking

O&M


Gary Stern (SCE), Chia Hadiprodjo Nawaz (PAO)

SCE agrees with PAO for removal of $92,000 ($7,500 + $22,500 + $62,262) in one-time or non-recurring costs. SCE disagrees with removal of one-time costs of $62,262 that were not included in the application (originally charged to Shareholders) and $27,000 in costs that were subject to attorney-client privilege and therefore, could not be shared with PAO to review.

SCE-17, Vol. 6, pp. 4-6

PAO Position: PAO performed an audit examination of SCE’s financial and accounting records in response to SCE’s Application for authority to increase Test Year 2021 GRC revenue requirements. Based on PAO' examination, it recommends a downward adjustment of $181,524 to the 2018 recorded non-labor expenses for costs that were identified as one-time or could not be independently verified due to SCE’s assertion of legal privilege.

PAO-18, pp. 7-8

SCE Position:

SCE-06, Vol. 6

SCEFERCAccount

BPEGRC Activity

PAO vs SCE

PAO

920921 | Develop and Manage Policy and Initiatives

Non-Labor (89) 859948

948Total (89) 859

948

Develop and Manage Policy and Initiatives Total:

(89) 859

See issue SCE-001 where SCE agreed to reduce the forecast by $92k.

Total



2021 Test Year

Exhibit:

Cost Component:

BPG:

Witness:

Issue Title:




2018$ in Thousands

PAO-53 | Non-Wildfire

O&M


Jim Jiang (SCE), Mark Waterworth (PAO)

SCE’s non-wildfire liability insurance programs include general liability, fiduciary liability, directors and officers (D&O), workers compensation, nuclear liability, cyber liability and miscellaneous liability insurance and surety bonds. SCE purchases non-wildfire general liability insurance to limit exposure to unpredictable losses that may occur as a result of lawsuits alleging third-party bodily injury, personal injury, or property damage. SCE's forecast for 2021 expense will likely vary slightly, either greater than or lower than the recorded outcome. There is no reason to assume that the percentage difference between forecast and actual will remain constant through time. In fact, with respect to non-wildfire liability insurance expense, current insurance market pricing information suggests that SCE will have higher non-wildfire liability insurance expense in 2020 than SCE’s forecasted 2020 expense, not lower. SCE has demonstrated that consistent with prior rate cases, a forecast prepared based on guidance from SCE’s insurance broker has been a sound forecasting methodology.

SCE-17, Vol. 02, pp. 29-30

PAO Position: PAO recommends a reduction of 10%, or $3.585 million, to SCE’s non-wildfire liability insurance forecast. SCE’s recorded 2019 non-wildfire liability insurance expense was approximately 10% below SCE’s forecast, which was developed by SCE’s insurance broker, Marsh. As SCE relies its broker to provide forecasts for the 2021 test year, the Public Advocates Office recommends this lower difference be applied to the TY 2021 20 forecast.

PAO-10, Part 1, p. 22

SCE Position:

SCE-06, Vol. 2

SCEFERCAccount

BPEGRC Activity

PAO vs SCE

PAO

925 | Liability Insurance (Non-Wildfire)

Non-Labor 0 00

Other (3,585) 32,26635,851

35,851Total (3,585) 32,266

35,851

Liability Insurance (Non-Wildfire) Total:

(3,585) 32,266Total



2021 Test Year

Exhibit:

Cost Component:

BPG:

Witness:

Issue Title:




2018$ in Thousands

PAO-58 | EEI Membership Dues

O&M


Chris Thompson (SCE), Lindsay Loethen (PAO)

SCE provided substantial evidence demonstrating the customer benefits received from the EEI membership and therefore, the Test Year forecast of $1.669 million for EEI membership dues should be customer funded. PAO did not provide any evidence to the contrary. Additionally, the Commission approved SDG&E’s EEI membership dues in its most recent GRC finding numerous customer benefits (e.g., training, best practices, and information from studies and research) resulting from EEI membership. The EEI membership provides the same benefits to SCE’s customers as it does to SDG&E’s customers. Because it would be inequitable to treat SCE differently than SDG&E, PAO’ recommendation should be rejected.

SCE-17, Vol. 6. pp. 7-8

PAO Position: PAO recommends a reduction of $1.669 million to SCE’s forecast for the Professional Development and Education GRC activity for the removal of SCE’s Edison Electric Institute (EEI) membership. PAO agrees with the Commission’s decision to deny SCE recovery for EEI membership in the 2018 GRC and states that SCE has not provided sufficient evidence to meet its burden that EEI membership expenses should be recovered from ratepayers.

PAO-12, p. 12

SCE Position:

SCE-06, Vol. 6

SCEFERCAccount

BPEGRC Activity

PAO vs SCE

PAO

930 | Professional Development and Education

Non-Labor (1,669) 2111,880

1,880Total (1,669) 211

1,880

Professional Development and Education Total:

(1,669) 211Total



2021 Test Year

Exhibit:

Cost Component:

BPG:

Witness:

Issue Title:




2018$ in Thousands

PAO-59 | Property

O&M


Jim Jiang (SCE), Mark Waterworth (PAO)

SCE’s recorded 2020 property insurance expense is expected to exceed its forecasted expense. SCE’s forecasted expense is greater than recorded in some years and less than recorded in other years indicates that SCE’s forecast is unbiased and does not systematically overstate or understate the recorded expense. The Commission has accepted use of the forecast of SCE’s insurance broker, Marsh, in prior General Rate Cases and should adopt it for Test Year 2021 as well.

SCE-17, Vol. 02 p. 31

PAO Position: SCE’s recorded 2019 property insurance expense was approximately 6% below SCE’s forecast, which was developed by SCE’s insurance broker, Marsh. SCE’s forecasted property insurance expense for 2019 was $16.596 million, and recorded expense was $15.55 million. PAO recommends a reduction of 6%, or $1.228 million, in SCE’s Test Year 2021 property insurance expense.

PAO-10, Part 1, pp. 22 - 23

SCE Position:

SCE-06, Vol. 2

SCEFERCAccount

BPEGRC Activity

PAO vs SCE

PAO

924 | Property Insurance

Non-Labor 0 00

Other (1,228) 19,23420,462

20,462Total (1,228) 19,234

20,462

Property Insurance Total:

(1,228) 19,234Total



2021 Test Year

Exhibit:

Cost Component:

BPG:

Witness:

Issue Title:




2018$ in Thousands

PAO-60 | Recognition

O&M

Employee Benefits & Programs

Mark Bennett (SCE), Stacey Hunter (PAO)

SCE requests recovery for its nominal cash and non-cash recognition programs. They comprise the cash awards, called Spot Awards, and non-cash awards (in the form of points redeemable for merchandise, known as Encore points. SCE’s recognition programs are important tools for recognizing and rewarding employees for exceptional performance, safety actions, and/or outstanding achievement on the spot, closer to when that outstanding performance happens. SCE has forecast 0.15 percent of labor for Test Year 2021.

SCE-06, Vol. 03 Pt. 1, pp. 68-72; SCE-17, Vol. 03, pp. 58-62

PAO Position: In prior years, SCE stated that these awards, which were formerly called “Awards to Celebrate Excellence,” recognized and reinforced behaviors such as exceptional customer service, teamwork and initiative. In this GRC, SCE states that the Encore awards are given for “ongoing, regular efforts to work safely.” In other words, with this program SCE is rewarding employees for simply doing their job in the way they were hired to do it – safely. Significant overspending in 2018 indicates that SCE does not have this program as “tightly managed” as it claims. Due to at least one job category being above market and the significant overspending on this program in recent years, the Public Advocates Office recommends that ratepayers and shareholders equally share the expense for SCE’s Recognition Programs.

PAO-11, pp. 18 - 20

SCE Position:


SCEFERCAccount

BPEGRC Activity

PAO vs SCE

PAO

926 | Recognition

Other (37) 3774

74Total (37) 37

74

Recognition Total:

(37) 37Total



2021 Test Year

Exhibit:

Cost Component:

BPG:

Witness:

Issue Title:




2018$ in Thousands

PAO-62 | Software Maintenance and Replacement O&M

O&M

Enterprise Technology

Lori Garris (SCE), Mark Waterworth (PAO)

The Software Maintenance and Replacement work activity includes costs required to maintain SCE’s operating software assets through on-premise license, cloud, subscription, and maintenance contract agreements. In addition, this work activity includes application refresh activities, which consist of the management, maintenance, optimization, and monitoring of about 800 existing IT applications and more than 3,000 interfaces through their lifecycles. SCE’s itemized forecast for 2021 includes certain expenses necessary for maintaining legacy systems through 2021 given the delay in the planned implementation of the Customer Service Re-Platform (CSRP) project from 2020 to 2021. PAO has misinterpreted this to mean that SCE is inappropriately including CSRP implementation costs that should be adjusted out. However, as stated in SCE’s amended CSRP testimony, the removal of CSRP costs and benefits to a different application necessitates that SCE include within this GRC “the addition of costs to support the operation of legacy systems through 2021.” Additionally, SCE has normalized its forecast, using the average forecast for calendar years 2021-2023 as the test year forecast, consistent with Commission practice. PAO’ opposition to this normalization on the sole basis that it increases the test year forecast is inconsistent with Commission precedent and would lead to an inequitable result.

SCE-17, Vol. 1, part 1, p. 9-14

PAO Position: PAO accepts SCE’s forecast, with two exceptions. First, PAO advocates for a $3.768 million reduction to SCE’s combined Cloud, SaaS, and Perpetual License forecast based on the use of a two-year (2019-2020) average forecasting methodology instead of SCE’s itemized test year forecast. PAO believes a $3.768 million reduction is necessary because the increase in SCE’s 2021 forecast for these sub-work activities over SCE’s 2019 and 2020 forecasts is primarily due to CSRP’s planned implementation in 2021. Second, PAO recommends a $7.659 million reduction based on the removal of SCE’s normalization adjustment on the basis that PAO does not believe that normalization is appropriate when the forecast costs in the attrition years are higher than the forecast costs in the calendar year.

PAO-10, pp. 7-8

SCE Position:


SCEFERCAccount

BPEGRC Activity

PAO vs SCE

PAO

920921 | Software Maintenance and Replacement

Labor 0 8,6898,689

Non-Labor (11,427) 77,12888,555

97,245Total (11,427) 85,818

97,245

Software Maintenance and Replacement Total:

(11,427) 85,818Total



2021 Test Year

Exhibit:

Cost Component:

BPG:

Witness:

Issue Title:




2018$ in Thousands

TURN-81 | Executive Compensation

O&M


Jacqueline Trapp (SCE), Garrick Jones (TURN)

Executive Compensation includes base salary, annual short-term incentives, associated expenses and outside service expenses for executive officers. For recorded and forecast years 2014 through 2021, Executive Compensation that is subject to SB 901 pursuant to applicable criteria has been removed. SCE carefully follows Commission and statutory precedent and guidance here. SCE forecasts $18.128 million ($18.133 million less $0.005 adjustment for AB 560 adjustment in SCE-52 Update Testimony) of expenses for Executive Compensation (salaries and short-term incentives), non-labor expenses, and outside services. Besides SCE executive officers, certain executive officers are dual officers of both SCE and its parent company, Edison International (EIX). The salaries, expenses, and incentive costs of these “Shared Officers” are allocated between SCE and EIX. The cash compensation for SCE’s executive officers is part of the competitive total compensation package (which also includes long-term incentives and benefits) designed to attract and retain well-qualified executives. SCE competes for executive talent with both utilities and companies in other industries, so SCE’s salary and incentive programs must be market-competitive.

SCE-06, Vol. 03 Pt. 1, pp. 50 - 61; SCE-17, Vol. 03, pp. 39 -49

TURN Position: TURN’s primary recommendation is to remove most of the labor forecast, $8.224 million and the portion of non- labor expense that is composed of all Vice Presidents and above’s pay, including Shared and EIX officers , pursuant to the prohibition in SB 901 against recovering officer compensation in rates. If the Commission does not agree with this recommendation, TURN requests the Commission to consider the same reduction TURN is recommending for STIP. TURN contends that SCE includes a number of metrics within the incentive programs which benefit shareholders and not customers. These include the financial goal, as well as goals around the successful completion of Commission and state regulatory proceedings. TURN also disagrees with SCE‘s proposal to increase incentive levels, and believes these ratios should remain the same as what was approved in prior rate case decisions. To maintain these prior levels, TURN recommends disallowing costs attributed to the Compensation Design Project (CDP) and the Key Contributor Incentive Program (KCIP).

TURN-04, pp. 27 - 40

SCE Position:


SCEFERCAccount

BPEGRC Activity

TURN vs SCE

TURN

923 | Executive Compensation

Non-Labor 3,290(3,705)6,995

6,995Total (3,705) 3,290


Labor 2690269

Non-Labor 8(9)17

286Total (9) 277



2021 Test Year


Labor 0(8,219)8,219

Non-Labor 1,236(1,391)2,627

10,847Total (9,611) 1,236

18,128

Executive Compensation Total:

(13,325) 4,803

TURN makes a secondary recommendation for reducing the EIC program (within Executive Compensation GRC Activity). If the Commission does not support TURN’s primary recommendation, the secondary recommendation includes reducing the EIC target forecast related to financial and lobbying goals for a total reduction of $1.133 million.

Total



2021 Test Year

Exhibit:

Cost Component:

BPG:

Witness:

Issue Title:




2018$ in Thousands

PAO-89 | Fixed Price Technology and Maintenance O&M

O&M

Enterprise Technology

Lori Garris (SCE), Mark Waterworth (PAO)

Fixed Price Technology supports a large number of activities primarily through a fixed price contract to Managed Service Providers (MSPs). SCE developed its forecast by using the last recorded year for labor and the agreed contractual MSP pricing for non-labor. PAO’s reliance on savings achieved through past prudent negotiations to support its proposed reduction to SCE’s non-labor forecast is inappropriate because there are no ongoing or planned negotiations and the agreed-upon pricing is the most reasonable estimate of the expenses SCE expects to incur in 2021. Additionally, PAO’s argument that past savings can be reproduced in the future is misplaced, as the savings PAO cites were unique to 2018 and 2019 and the result of projects that were delayed in those years but will require operational support in 2020 and 2021.

SCE-17, Vol. 1, part 1, pp. 5-8

PAO Position: PAO does not oppose the labor portion of SCE’s request. However, PAO disagrees with SCE’s use of agreed contractual MSP pricing for the non-labor forecast and contends that a four-year average (2015-2018) of recorded costs is more appropriate to use for determining the non-labor portion of the forecast because SCE underspent the amount it was authorized for this work activity in the 2018 GRC by $7.9 million due to savings incurred through prudent negotiations. Additionally, PAO argues that the downward trend in spending coupled with SCE’s 2021 forecast being similar to its 2019 forecast further supports PAO’ recommendation.

PAO-10, p. 7

SCE Position:


SCEFERCAccount

BPEGRC Activity

PAO vs SCE

PAO

920921 | Fixed Price Technology and Maintenance

Labor 0 3,0323,032

Non-Labor (5,046) 68,55473,600

76,632Total (5,046) 71,586

76,632

Fixed Price Technology and Maintenance Total:

(5,046) 71,586Total



2021 Test Year

Exhibit:

Cost Component:

BPG:

Witness:

Issue Title:




2018$ in Thousands

NDC-92 | Supplier Diversity

O&M

Supply Chain Management

Tarrance Frierson (SCE), Faith Bautista (NDC)

SCE’s Supplier Diversity and Department (SDD) is part of the Supply Chain Management organization and manages SCE’s efforts to contract with and provide outreach and training to Diverse Business Enterprises (DBEs) in compliance with CPUC General Order 156 (GO156). For test year 2021, SDD’s forecast for O&M is $3.422 million, which represents an increase of $194,000 in labor over 2018 recorded costs and decrease of $12,000 over 2018 non-labor recorded costs. SCE is requesting the increase of $194,000 in labor in order to reinstate a prior staffing level of nine full-time positions and to include one additional position to manage an expanded focus on small business programming and outreach.

SCE-17, Vol. 02, pp. 38-42

NDC Position: The National Diversity Coalition opposes SCE’s requested increase of $194,000 in labor costs and recommends that the 2021 forecast be based on 2018 recorded costs, because SCE has not developed plans to expand existing supplier diversity programs or set higher performance goals to justify the increased budget request.

NDC-01, p. 31 - 36

SCE Position:

SCE-06, Vol. 02

SCEFERCAccount

BPEGRC Activity

NDC vs SCE NDC

923 | Supplier Diversity and Development

Non-Labor 64 2,1242,060

2,060Total 64 2,124

920921 | Supplier Diversity and Development

Labor (194) 9801,174

Non-Labor (52) 136188

1,362Total (246) 1,116

3,422

Supplier Diversity and Development Total:

Total (182) 3,240



2021 Test Year

Exhibit:

Cost Component:

BPG:

Witness:

Issue Title:




2018$ in Thousands

PAO-TURN-52 | Wildfire

O&M


Josh Jiang (SCE), Mark Waterworth (PAO), Robert Finkelstein (TURN)

Consistent with prior years, SCE continues to purchase approximately $1 billion of wildfire insurance coverage to protect customers from the financial exposure of third-party legal claims resulting from wildfires alleged to be associated with SCE infrastructure. SCE may obtain this coverage through traditional insurance or through alternative risk transfer instruments such as catastrophe bonds and self-insurance. AB 1054 requires SCE to maintain a reasonable amount of insurance as determined by the Wildfire Fund Administrator. SCE believes that insurance is an essential and ubiquitous risk mitigation instrument that all responsible corporate entities and private individuals use to cover losses resulting from legal claims, including those related to inverse condemnation and negligence. Payment of claims where a litigant alleges negligence (often among a variety of other alleged causes of action) is a common cost of doing business (any business) and insurance premiums protecting against such claims are part and parcel of the regulatory compact. No prudent business, including the IOUs, should operate without insurance if reasonably feasible. In addition, “sharing” of the expense with shareholders is inconsistent with long-standing Commission precedent and basic cost-of-service ratemaking principles.

SCE-17, Vol. 02, pp. 20-27

For TY 2021, SCE requests $623.804 million. PAO recommends a sharing of the expense between ratepayers and shareholders based on a 75%/25% allocation. PAO position is that customers and shareholders both benefit from the protection of wildfire liability insurance; the increase in insurance premiums is a result of wildfires caused by utility infrastructure.

PAO-10, Part 1, pp. 17-21

TURN recommends the Commission authorize rate recovery of $312 million for wildfire liability insurance costs in the 2021 test year, based on allocating SCE’s forecast of $624 million equally between the utility’s ratepayers and shareholders. TURN believes that the risk that a wildfire in SCE’s service territory caused by SCE will occur and substantial amounts of claims paid is a risk with potential financial consequences to both ratepayers and shareholders. TURN further asserts that there is a risk that the Commission would not allow SCE’s to recover claims costs if such losses were not reasonable and prudent. As such, SCE wildfire liability insurance will mitigate such losses and will equally impact and protect both ratepayers and shareholders. Thus, shareholders should have a fair share in the wildfire liability insurance cost since both ratepayers and shareholders benefit from the protection of wildfire liability insurance.

TURN-01 pp. 4 – 9, and 19-20

SCE Position:

PAO Position:

TURN Position:

SCE-06, Vol. 2

SCEFERCAccount

BPEGRC Activity

PAO vs SCE

TURN vs SCE

TURNPAO

925 | Liability Insurance - Wildfire

Other 467,853 311,902(155,951) (311,902)623,804

Total (155,951) (311,902)623,804 467,853 311,902

Liability Insurance - Wildfire

(155,951) (311,902)623,804 467,853 311,902



2021 Test Year

Exhibit:

Cost Component:

BPG:

Witness:

Issue Title:




2018$ in Thousands

PAO-TURN-55 | Long-Term Incentive (LTI) Program

O&M


Mark Bennett (SCE), Stacey Hunter (PAO), Garrick Jones (TURN)

SCE states that LTI represents an integral part of the total compensation package for executives. LTI is provided in various forms: non-qualified stock options, restricted stock units, and performance shares. The LTI target for each executive is determined based upon the market data applicable for his or her position. While LTI is targeted at the market median, the actual grant may vary based on an annual assessment of that individual’s performance, as well as retention needs. The Total Compensation Study (TCS) confirms that SCE has a reasonable and fair mix of compensation and benefits. Providing the market level of compensation is a cost of service. SCE asserts that by removing any one of these, the total compensation of an executive would fall well below market compensation levels, and SCE would not be able to retain qualified executives. SCE also notes that AB 1054 confirmed the importance of incentive-based compensation in fostering safety and reliability of service. If the Commission were to adopt PAO and TURN’s positions, the RO model will dynamically make an adjustment to remove the rate base portion.

SCE-17, Vol. 03, pp. 53-58

PAO states that the Commission has a long history of denying funding for LTI because it is stock- based compensation tied to financial performance. PAO acknowledges that AB 1054 provides language regarding long- term incentive structure but notes that AB 1054 does not require that ratepayers fund the program. Furthermore, PAO disputes that LTI helps in the retention of higher-ranked employees, and points to the relatively higher rate of turnover in the executive population.

PAO-11, pp. 17 - 18

TURN states the Commission has denied recovery of SCE’s LTI costs over the past four rate cases. It argues that the evidence provided by SCE in this case is largely the same as in the past cases, such as the calculated costs to ratepayers if transfer occurs to base pay, and the claim that a majority of companies provide LTI. TURN also notes that AB 1054 is not a substantial basis to support a new Commission policy that requires ratepayers to fund the LTI program. TURN states that because there appears to be no new arguments, the Commission should continue to disallow LTI benefits.

TURN-04 pp. 41 - 46

SCE Position:

PAO Position:

TURN Position:


SCEFERCAccount

BPEGRC Activity

PAO vs SCE

TURN vs SCE

TURNPAO



2021 Test Year

926 | Long-term Incentives

Labor 0 02,093 2,093(2,093)

Total 2,093 2,093(2,093) 0 0

920921 | Long-term Incentives

Labor 0 0(13,695) (13,695)13,695

Total (13,695) (13,695)13,695 0 0

Long-term Incentives

(11,602) (11,602)11,602 0 0



2021 Test Year

Exhibit:

Cost Component:

BPG:

Witness:

Issue Title:




2018$ in Thousands

PAO-TURN-74 | Executive Benefits

O&M


Mark Bennett (SCE), Stacey Hunter (PAO), Garrick Jones (TURN)

SCE states that it competes with other major utilities to attract and retain well-qualified executives and that the features and qualification requirements of the Executive Benefits were preserved in the Executive Retirement Plan because of their value in (a) retaining critical executives to older ages, and (b) avoiding an excessive amount of turnover. Longevity is important, according to SCE, not only for continuity purposes but also because executive searches tend to take significantly more time, resources, and cost compared to the average hire. The cost savings resulting from the long tenures and the lower recruiting costs are then translated to the customer.

SCE-17, Vol. 03, pp. 51-52

PAO recommends ratepayer funding of no more than 50 percent of the forecast Executive Benefits expense, which would amount to ratepayer funding of $7.771 million; PAO states ratepayers should not fund benefits that are in excess of federal limits and enhance the benefits of already highly-compensated executives.

PAO-11, p. 21

Corresponding to the arguments and reasoning in the section above regarding Executive Compensation, TURN recommends that the Commission remove Executive Benefits for employees in positions of Vice President or higher from the GRC forecast, resulting in a reduction of $2.376 million from SCE’s forecast, corresponding to a recommended forecast of $13.166 million.

TURN-04 E, pp. 40-41

SCE Position:

PAO Position:

TURN Position:


SCEFERCAccount

BPEGRC Activity

PAO vs SCE

TURN vs SCE

TURNPAO

926 | Executive Benefits (Non-Service)

Other 5,895 10,342(6,642) (2,195)12,537

Total (6,642) (2,195)12,537 5,895 10,342

926 | Executive Benefits (Service)

Other 1,610 2,824(1,814) (599)3,423

Total (1,814) (599)3,423 1,610 2,824

Executive Benefits

(8,456) (2,795)15,961 7,505 13,166

Total changes may not reconcile to testimony due to changes in labor.



2021 Test Year

Exhibit:

Cost Component:

BPG:

Witness:

Issue Title:




2018$ in Thousands

PAO-TURN-75 | Short-Term Incentive Compensation Program

O&M


Mark Bennett (SCE), Stacey Hunter (PAO), John Sugar (TURN)

STIP is the annual variable pay program that gives employees an opportunity to earn a cash award based on achieving Company goals. Exempt employees participating in STIP have their award amounts further adjusted based on individual performance. In 2018, the Company launched an incentive program known as the Key Contributor Incentive Plan (KCIP), which was added after additional bonus targets for some non- executive principal-level employees were discontinued. KCIP is offered in addition to STIP, but the payout is different and not all non-executive principal employees who received STIP awards are expected to be granted KCIP. The Total Compensation Study reveals that SCE pays at market. Eliminating the funding for incentive compensation would drop authorized funding below market. The means by which SCE structures its total cash compensation should be immaterial as long as the total cost is reasonable. SCE quantified the benefits of using variable pay, and showed that in the long-term, substantial savings are projected to be achieved in SCE’s restructured compensation/benefit design. SCE also demonstrated and quantified the benefits to ratepayers of a financially sound utility. SCE also showed that efforts in critical regulatory proceedings and endeavors is of benefit to customers, and indeed in many areas these efforts are directly in line with Commission guidance and priorities.

SCE-06, Vol. 03 Pt. 1, pp. 31-32, 41-46; SCE-17, Vol. 03, pp. 11-39

PAO states that incentive criteria tied to financial goals are clearly shareholder oriented. There is no benefit to ratepayers, but there is a tangible benefit to shareholders in the form of dividends and higher stock prices. The STIP should be reduced by 30 percent to account for the financial goals which only benefit shareholders. The Commission should adopt equal sharing of the non-financial performance STIP costs between shareholders and ratepayers.; this is in line with D.14-08-032 in which the Commission found that shareholders benefit from STIP as much as or more than do ratepayers. In SCE’s last GRC, the Commission in D.19-05-020 adopted $57.592 million ($59.33 million in 2020 dollars) as the appropriate level of ratepayer funding for STIP. In this proceeding, SCE is asking for more than three times that amount, nearly $181 million. Compared to SCE's TY labor forecast of $854.820 million, this amount of STIP would result in a bonus of over 21% for every SCE employee. Ratepayers should not have to bear the burden of an additional 21% bonus for every employee. PAO recommends a forecast of $63.3 million which is similar to the amount approved by the Commission in the 2018 GRC.

PAO-11, pp. 12 - 16

STIP incentive levels should not exceed the level of increases in Edison’s labor costs. Incentive compensation should be used for employee incentives, not as a mechanism for increasing pay outside of “labor costs.” Furthermore, Edison’s increases are focused on highly paid managers and executives, without providing any evidence that the compensation increases are necessary or benefit ratepayers. TURN recommends reducing SCE’s proposed funding level to 12.11% of labor, which was the ratio of STIP to labor costs adopted by the Commission in SCE’s previous two GRCs. Furthermore, SCE includes a number of metrics which primarily benefit shareholders and not customers, including financial performance goals and goals related to SCE’s lobbying efforts. TURN recommends a reduction of $129.15 million for STIP.

TURN-05, pp. 4-20

SCE Position:

PAO Position:

TURN Position:




2021 Test Year

SCEFERCAccount

BPEGRC Activity

PAO vs SCE

TURN vs SCE

TURNPAO

920921 | Short-Term Incentive Program - A&G

Labor 23,024 20,104(46,231) (49,151)69,255

Total (46,231) (49,151)69,255 23,024 20,104

905 | Short-Term Incentive Program - Customer Service

Labor 6,247 5,670(13,283) (13,860)19,530

Total (13,283) (13,860)19,530 6,247 5,670

500 | Short-Term Incentive Program - Generation

Labor 2,809 2,330(5,216) (5,695)8,025

Total (5,216) (5,695)8,025 2,809 2,330

588 | Short-Term Incentive Program - Transmission & Distribution

Labor 26,820 23,655(54,666) (57,830)81,485

Total (54,666) (57,830)81,485 26,820 23,655

Short-Term Incentive Program Total

(119,396) (126,537)178,296 58,900 51,759

SCE’s financial position for STIP reflects the labor forecast as of SCE-52 A2 Update Testimony. PAO and TURN’s financial position reflect their proposed reductions as presented in their testimony, PAO-11 and TURN-05, respectively. PAO’s testimony position was calculated against SCE’s labor forecast as of February 2020, RO model build 1.4 CSRP Amendment. TURN’s testimony position was calculated against SCE’s labor forecast as of November 2019, RO model build 1.1 GRC Application Amendment. Differences in forecast labor impact the STIP derivation. See TURN-81 | Executive Compensation for EIC Position.




219


2021 Test Year


Exhibit:

Cost Component:

Witness:


BPE:


Facility & Land Operations

Don Neal (SCE), John Defever (TURN)

For the Blythe Service Center, SCE seeks recovery of costs incurred through 2019 in this rate case.

SCE-17, Vol. 05, pp. 3 - 24

TURN Position: TURN recommends the Commission authorize no more than what was actually spent in 2019; $11.159 million. TURN’s recommendation reduces the Company’s request by $2.054 million compared to SCE's original forecast.

TURN-10 pp. 8-9


$ in Thousands

Issue Title: TURN-17 | Infrastructure Upgrade - Blythe

SCE Position:

SCE-06, Vol. 5



985 | COS-00-RE-SC-BLYTHE

SCE

TURN

10,542

10,542 0 0 0 0 10,542

10,542 0 0 0 0

TURN vs SCE 0 0 0 0 0 0

986 | CIT-00-OP-NS-000154

SCE

TURN

616

616 0 0 0 0 616

616 0 0 0 0

TURN vs SCE 0 0 0 0 0 0

Infrastructure Upgrade - Blythe Total:

SCE

TURN 11,159

11,159 0 0 0 0 11,159

0 0 0 0 11,159

TURN vs SCE 0 0 0 0 0 0



2021 Test Year


Exhibit:

Cost Component:

Witness:


BPE:




SCE’s Substation Maintenance and Test Building program seeks to replace temporary and outdated substation facilities. The upgrade project for Devers Maintenance and Test Building addresses age, condition, and operational inefficiency (including lack of sufficient space for storage and operations). Although the start date of this project was delayed, SCE has recorded costs on this project continuously from 2016 through the present and is presently in the midst of construction. The Rector Maintenance and Test Building project addresses the age and condition of the facility and workspace limitations. By the end of 2019, SCE’s recorded expenditures for the project represented 47% of the authorized amount. Currently, the project is in the middle of construction and on track for completion in 2020.

SCE-17, Vol. 05, pp. 3 - 24

TURN Position: TURN recommends disallowance for Devers and Rector Maintenance & Test Building as SCE was authorized funding for the projects in the 2018 GRC and spent a majority of the funding on other projects, as well as the lack of support for these projects.

TURN-10 pp. 16 - 19


$ in Thousands

Issue Title: TURN-157 | Facility and Land Operations Capital Expenditures - Substation Reliability Upgrade

SCE Position:

SCE-06, Vol. 5



977 | CIT-00-OP-NS-000154

SCE

TURN

1,056

0 0 0 0 0 0

263 793 0 0 0

TURN vs SCE (263) (793) 0 0 0 (1,056)

993 | COS-00-RE-AD-SR0004 (CPUC)

SCE

TURN

428

0 0 0 0 0 0

203 226 0 0 0

TURN vs SCE (203) (226) 0 0 0 (428)

994 | COS-00-RE-AD-SR0004 (FERC)

SCE

TURN

1,943

0 0 0 0 0 0

924 1,018 0 0 0

TURN vs SCE (924) (1,018) 0 0 0 (1,943)

995 | COS-00-RE-AD-SR0006 (CPUC)

SCE

TURN

3,094

0 0 0 0 0 0

1,812 1,282 0 0 0

TURN vs SCE (1,812) (1,282) 0 0 0 (3,094)



2021 Test Year

996 | COS-00-RE-AD-SR0006 (FERC)

SCE

TURN

4,260

0 0 0 0 0 0

2,503 1,758 0 0 0

TURN vs SCE (2,503) (1,758) 0 0 0 (4,260)

Facility and Land Operations Capital Expenditures - Substation Reliability Upgrade Total:

SCE

TURN 0

5,705 5,077 0 0 0 10,782

0 0 0 0 0

TURN vs SCE (5,705) (5,077) 0 0 0 (10,782)



2021 Test Year


Exhibit:

Cost Component:

Witness:


BPE:




Santa Barbara Service Center is being relocated to an area closer to the majority of the Santa Barbara customer base and workforce in an effort to improve System Average Interruption Duration Index (SAIDI) scores and the delivery of electricity to the customers served. The Santa Barbara Service Center relocation was delayed due to the inability to locate a suitable parcel and the land purchase is forecast for 2022-2023. FERC and CPUC guidance provide for rate recovery of land acquisition and related costs when made in advance of construction of utility assets thereupon.

SCE-17, Vol. 05, pp. 3 - 24

TURN Position: TURN recommends the disallowance of all costs related to this project, irrespective of whatever attrition mechanism the Commission adopts in this case. The amounts requested through 2023 are only for land purchase and environmental studies. Based on SCE’s own forecast, the service center will not be completed during this period and therefore, cannot be considered used and useful. In addition, based on the Company’s history of not spending authorized amounts, there is not sufficient reason to believe that the Company will even complete the purchase of land and environmental studies as scheduled.

TURN-10 pp. 9 - 11


$ in Thousands

Issue Title: TURN-161 | Infrastructure Upgrade - Santa Barbara

SCE Position:

SCE-06, Vol. 5



987 | COS-00-RE-SC-SBARBA

SCE

TURN

15,123

0 0 0 0 0 0

0 0 0 1,068 14,055

TURN vs SCE 0 0 0 (1,068) (14,055) (15,123)

Infrastructure Upgrade - Santa Barbara Total:

SCE

TURN 0

0 0 0 1,068 14,055 15,123

0 0 0 0 0

TURN vs SCE 0 0 0 (1,068) (14,055) (15,123)



2021 Test Year


Exhibit:

Cost Component:

Witness:


BPE:




T&D Training Center project will consolidate the existing training schools at Alhambra, Chino and Westminster to a single location on an SCE-owned site in Rancho Vista. While the overall schedule of the project has shifted, SCE is moving forward with a lower cost solution and its detailed planning estimate fully supports the project’s forecast.

SCE-17, Vol. 05, pp. 3 - 24

TURN Position: Edison’s history of spending for this project should be considered. Despite authorization in the prior GRC of $92 million, the Company has only spent $2.132 million through 2019. The Company has not provided adequate support for the level of costs or sufficient reason to believe that the requested funds would be spent on the authorized project. TURN recommends the disallowance of the entire $45.285 million in capital for the T&D center.

TURN-10 pp. 12 - 14


$ in Thousands

Issue Title: TURN-162 | Infrastructure Upgrade - T&D Training Center

SCE Position:

SCE-06, Vol. 5



976 | COS-00-RE-BR-VM0001

SCE

TURN

532

0 0 0 0 0 0

532 0 0 0 0

TURN vs SCE (532) 0 0 0 0 (532)

990 | COS-00-RE-AD-10100

SCE

TURN

43,546

0 0 0 0 0 0

168 6,438 30,942 5,999 0

TURN vs SCE (168) (6,438) (30,942) (5,999) 0 (43,546)

991 | CIT-00-OP-NS-000154

SCE

TURN

1,026

0 0 0 0 0 0

156 0 0 870 0

TURN vs SCE (156) 0 0 (870) 0 (1,026)

Infrastructure Upgrade - T&D Training Center Total:

SCE

TURN 0

856 6,438 30,942 6,869 0 45,104

0 0 0 0 0

TURN vs SCE (856) (6,438) (30,942) (6,869) 0 (45,104)



2021 Test Year


Exhibit:

Cost Component:

Witness:


BPE:




Vehicle Maintenance Facilities program seeks to address the aged condition of existing facilities and operational needs, including electrification of SCE’s fleet. SCE’s activities on this project, benchmarking vehicle facilities with other utilities, analyzing future fleet electrification requirements (as industry standards have not been determined) and forecast future fleet specifications, supports SCE’s commitment to complete this project.

SCE-17, Vol. 05, pp. 3 - 24

TURN Position: The Commission should not re-authorize spending for these projects yet again. TURN takes issue with Edison’s record of requesting funds for projects and not spending those amounts on the authorized projects. For this project, the Commission authorized $22.646 million in the 2018 GRC which were not used for this project.

TURN-10 pp. 14 -15


$ in Thousands

Issue Title: TURN-163 | Infrastructure Upgrade - Vehicle Maintenance

SCE Position:

SCE-06, Vol. 5



980 | COS-00-RE-BR-698600

SCE

TURN

22,289

0 0 0 0 0 0

0 0 0 10,000 12,289

TURN vs SCE 0 0 0 (10,000) (12,289) (22,289)

981 | CIT-00-OP-NS-000154

SCE

TURN

357

0 0 0 0 0 0

0 0 0 232 125

TURN vs SCE 0 0 0 (232) (125) (357)

Infrastructure Upgrade - Vehicle Maintenance Total:

SCE

TURN 0

0 0 0 10,232 12,414 22,646

0 0 0 0 0

TURN vs SCE 0 0 0 (10,232) (12,414) (22,646)




226


227



228


229


Section 13 | SCE-07 Rate Base, Depreciation and Tax-Related Issues

230


2021 Test Year

Exhibit:

Cost Component:

Witness:

Issue Title:




in Thousands

PAO-93 | Fuel and Purchased Power

Working Capital

PAO Position:

SCE Position: Forecast: SCE agrees with PAO to update the Fuel and Purchased Power forecast from Spring 2019 to Fall 2019, which was available post-filing. Lag Day: SCE's Fuel and Purchased Power lead-lag study is based on the dollar-weighted average payment lag days for each transaction type in 2018 (i.e., dividing the sum of the dollar-weighted lag day by the sum of the expenses paid) and applied to the forecast 2021 test year.

SCE-18, Vol. 02C, pp. 15-18



Line

Forecast: PAO recommends updating the Fuel and Purchased Power forecast from Spring 2019 to Fall 2019, consistent with D.19-05-020. Lag Day: PAO recommends a four-year simple moving average of the weighted-average lag days results from each year to forecast the lag days for each fuel and purchased power line item to account for trends with high variability.

PAO-15C, pp. 8-10

Sarah Tran (SCE), Fidel A. Leon Diaz (PAO)

SCE-07, Vol. 02

1 133,146 72,302 (60,844)Working Capital

Total

Reflects updated forecast from Spring 2019 to Fall 2019.

133,146 72,302 (60,844)



2021 Test Year

Exhibit:

Cost Component:

Witness:

Issue Title:




in Thousands

PAO-94 | Wildfire Insurance Premiums

Working Capital

PAO Position:

SCE Position: SCE recommends -186.9 days for Wildfire Insurance Premiums lead-lag study based on all available recorded data from 2017-2019 to determine the dollar-weighted average payment lag days (i.e., dividing the sum of the dollar-weighted lag by the sum of the expenses paid), giving each transaction in each year its appropriate weight.

SCE-18, Vol. 02, pp. 18-19



Line

PAO recommends -171.7 days for Wildfire Insurance Premiums by taking a simple average of the weighted-average lag days results from each year between 2017-2019 to limit the weight given to year 2019, which consists of over half of the total recorded payments for wildfire insurance premium.

PAO-15, pp. 12-13

Sarah Tran (SCE), Fidel A. Leon Diaz (PAO)

SCE-07, Vol. 02

1 396,500 377,017 (19,483)Working Capital

Total

Working cash impacts reflect lead-lag study differences and do not reflect forecast differences.

396,500 377,017 (19,483)



2021 Test Year

Exhibit:

Cost Component:

Witness:

Issue Title:




in Thousands

TURN-95 | Goods and Services

Working Capital

TURN Position

SCE Position: SCE's Goods and Services lead-lag study used the 2018 recorded year to determine the dollar-weighted average payment lag days for PO (40.2 days) and Non-PO transactions (11.7 days). The declining trend in lag days (making payments faster) is explained by accelerated payments to small businesses to help with their cash flow, vendor discount programs, and faster processing due to suppliers switching from checks to electronic payments.

SCE-18, Vol. 02, pp. 20-23

SCEIssue Name TURN TURN vs SCE


Line

TURN proposes a target of 45 days instead of 40.2 days for PO payments to be consistent with best cash management practices.

TURN-03E, pp. 32-34

Sarah Tran (SCE), Jennifer Dowdell (TURN)

SCE-07, Vol. 02

1 34,250 18,889 (15,361)Working Capital

Total


34,250 18,889 (15,361)



2021 Test Year

Exhibit:

Cost Component:

Witness:

Issue Title:




in Thousands

TURN-96 | Depreciation Expense

Working Capital

TURN Position

SCE Position: SCE assigns zero lag days lag for Depreciation Expense because SP U-16 explicitly states that the practice is to include depreciation provisions at zero lag days. Depreciation expense and its impact on rate base occur simultaneously.

SCE-18, Vol. 02, pp. 24-27



Line

TURN recommends an increase to the depreciation expense lag days from zero to 15.2, consistent with monthly accruals. Since depreciation is accrued monthly as part of the accounting cycle, the midpoint is 15.2 days.

TURN-03E, p. 36


SCE-07, Vol. 02

1 296,934 207,785 (89,149)Working Capital

Total


296,934 207,785 (89,149)



2021 Test Year

Exhibit:

Cost Component:

Witness:

Issue Title:




in Thousands

TURN-97 | Synchronized Interest Adjustment

Working Capital

TURN Position

SCE Position: Consistent with the Commission’s Standard Practice U-16, which states that interest on debt does not qualify for inclusion in cash working capital, SCE does not include interest on debt in the lead-lag study.

SCE-18, Vol. 02, pp. 27-30



Line

TURN proposes to include interest on debt in the lead-lag study because it is a significant expense in which utilities collect revenues before interest is paid. TURN recommends an 80-day expense lag.

TURN-03E, pp. 43-45


SCE-07, Vol. 02

1 0 (70,865) (70,865)Working Capital

Total 0 (70,865) (70,865)



2021 Test Year

Exhibit:

Cost Component:

Witness:

Issue Title:




in Thousands

TURN-98 | Taxes Based on Income

Working Capital

TURN Position

SCE Position: SCE proposes 61.8 lag days for Federal taxes and 55.4 lag days for State taxes based on the calendar accrual midpoint dates of July 2, 2009 and July 2, 2016, respectively. SCE disagrees with TURN’s recommendation because in D.84-05-036 the Commission concludes that it “consistently calculated income taxes for ratemaking purposes based on the cost of service developed from the adopted expenses, which excludes the various disallowed expenses.” SCE has demonstrated that it is a taxpayer based on activities covered in this GRC. Therefore, any income tax liability is required to be paid using the estimated tax rules, which are the basis for SCE and PAO’s position.

SCE-18, Vol. 02, pp. 32-37



Line

TURN recommends 365 lag days for Federal and State Income Taxes because SCE has not been a net taxpayer since before the 2018 GRC cycle and is unlikely to have any actual tax burden during the 2021 rate case cycle. If the Commission does not adopt lag days of 365 days for both Federal and State Income Taxes, TURN’s alternate recommendation is that the lag days be set at the lag calculated based on taxes due and paid from 2011-2018.

TURN-03E, pp. 37-43

Mark Childs (SCE), Jennifer Dowdell (TURN)

SCE-07, Vol. 02

1 (16,482) (282,427) (265,945)Working Capital

Total

SCE's position accepts PAO's proposal on Federal and State tax lag days.

(16,482) (282,427) (265,945)



2021 Test Year

Exhibit:

Cost Component:

Witness:

Issue Title:




in Thousands

TURN-99 | Materials and Supplies

Working Capital

TURN Position

SCE Position: SCE accepts TURN’s recommendation to use budget data and reduce the M&S inventory forecast at Palo Verde. However, SCE recommends a smaller reduction of $2,934 (a difference of $433) to account for the sales tax and unpaid inventory adjustment, which is applied to all M&S inventory.

SCE-18, Vol. 02, p. 31



Line

TURN proposes to use Palo Verde budgets instead of SCE’s recorded data with escalation to determine the forecast M&S inventory. TURN recommends a reduction of $3,367 thousand.

TURN-09, p. 14

Sarah Tran (SCE), William Marcus (TURN)

SCE-07, Vol. 02

1 237,624 237,191 (433)Working Capital

Total 237,624 237,191 (433)



2021 Test Year

Exhibit:

Cost Component:

Witness:

Issue Title:




in Thousands

PAO-TURN-100 | Customer Deposits

Working Capital

PAO Position:

SCE Position: For Customer Deposits, SCE is requesting that the Commission adopt the same conclusion in D.19-09-051, so that SCE and its customers are provided the same ratemaking treatment as SDG&E and SoCalGas and their respective customers, which adheres to the longstanding ratemaking treatment set forth in Standard Practice (SP) U-16 to exclude interest-bearing accounts from working cash.

SCE-07, Vol. 02, pp. 42-43; SCE-18, Vol. 02, pp. 37-42

SCEIssue Name PAO TURN TURN vs SCE

PAO vs SCE


Line

Consistent with prior Pacific Gas and Electric Company (PG&E) GRCs, the Public Advocates Office recommends that SCE compensate customer deposits at the long-term cost of debt, with a resulting reduction to the GRC revenue requirement. This treatment is consistent with precedent established in D.14-08-032 and continued by the Settlement terms approved in D.17-05-013.

PAO-15, pp. 14-15

TURN Position: In every GRC since 2003, the Commission has required SCE to use customer deposits to offset rate base on the grounds that the deposit balances should be treated like a source of permanent working capital. SCE’s Customer Deposits are a permanent source of low-cost capital and increasing over time. TURN recommends that SCE be required to continue to account for Customer Deposits as an adjustment to working capital and offset to rate base.

TURN-03E pp. 48-50

Jonathan Rumble (SCE), Fidel A. Leon Diaz (PAO), Jennifer Dowdell (TURN)

SCE-07, Vol. 02

1 0 (8,460) (262,082)(8,460) (262,082)Working Capital

Total

PAO's position is a reduction to revenue requirement, whereas, TURN's position is a reduction to rate base.

0 (8,460) (262,082)(8,460) (262,082)



2021 Test Year

Exhibit:

Cost Component:

Witness:

Issue Title:




TURN-101 | T&D Service Lives - Account 352 (Transmission Structures and Improvements)

Depreciation

TURN Position

SCE Position: SCE proposes to retain the authorized average service life of 55 years based on the actuarial study performed by Foster Associates. The analysis did not provide sufficient evidence to warrant adjusting the currently approved parameters, particularly when accounting for anomalous retirement data.

SCE-07, Vol. 03 pp. 66-72; SCE-07, Vol. 03, Appendix A pp. A10-A11; SCE-18, Vol. 03 pp. 14-29


Line

TURN proposes to extend the average service life from currently authorized 55 years to 58 years based on the L0.5-58 curve having a better visual and mathematical fit to the observed data. The Observed Life Table (OLT) curve for this account is well suited for Iowa curve fitting techniques due to the account’s retirement history and relatively smooth and conventional shape.

TURN-08, pp. 13-16

Ronald White (SCE), David Garrett (TURN)

SCE-07, Vol. 02

Capital-Related Depreciation

in Thousands

1 34 (544) (578)Depreciation

Total

Figures shown reflect the change from currently authorized depreciation expense based on year-end 2018 CPUC jurisdictional plant. The difference in the “TURN vs SCE” figure as calculated here and as presented in TURN’s testimony is the result of the parties using a different order of calculations; SCE first quantified the change attributable to the different ASL, and attributed other changes to net salvage differences, while TURN’s figures in its testimony first quantified the net salvage impact, and then the change attributable to the ASL recommendation. TURN has reviewed SCE’s calculations that produced the figures here, and accepts their accuracy for purposes of this JCE.

34 (544) (578)



2021 Test Year

Exhibit:

Cost Component:

Witness:

Issue Title:




TURN-102 | T&D Service Lives - Account 354 (Transmission Towers and Fixtures)

Depreciation

TURN Position

SCE Position: SCE proposes to retain the authorized average service life of 65 years based on the actuarial study performed by Foster Associates. The analysis did not provide sufficient evidence to warrant adjusting the currently approved parameters.



Line

TURN proposes to extend the average service life from currently authorized 65 years to 69 years based on the R5-69 curve having a better visual and mathematical fit to the observed data. The study of Foster Associates “deferred to SCE” in selecting the proposed service life due to “unreliable service life indications.”

TURN-08, pp. 16-20


SCE-07, Vol. 02


in Thousands


Total


43 (85) (128)



2021 Test Year

Exhibit:

Cost Component:

Witness:

Issue Title:




TURN-103 | T&D Service Lives - Account 356 (Transmission OH Conductor)

Depreciation

TURN Position




Line

TURN proposes to extend the average service life from currently authorized 61 years to 65 years based on the R3-65 curve having a better visual and mathematical fit to the observed data. There is sufficient retirement data in Account 356 such that reasonable estimates can be made through use of conventional Iowa curve fitting analysis, and such analysis indicates a longer life than that currently authorized.

TURN-08, pp. 20-23


SCE-07, Vol. 03


in Thousands


Total


205 (512) (717)



2021 Test Year

Exhibit:

Cost Component:

Witness:

Issue Title:




TURN-104 | T&D Service Lives - Account 361 (Distribution Structures and Improvements)

Depreciation

TURN Position

SCE Position: SCE proposes to extend the average service life from the currently authorized 50 years to 55 years based on the actuarial study performed by Foster Associates.



Line

TURN proposes to extend the average service life from currently authorized 50 years to 58 years based on the L0-58 curve having a better visual and mathematical fit to the observed data. The Observed Life Table (OLT) curve for this account is well suited for Iowa curve fitting techniques due to the account’s retirement history and relatively smooth and conventional shape.

TURN-08, pp. 23-27


SCE-07, Vol. 03


in Thousands

1 (1,463) (2,647) (1,184)Depreciation

Total


(1,463) (2,647) (1,184)



2021 Test Year

Exhibit:

Cost Component:

Witness:

Issue Title:




TURN-105 | T&D Service Lives - Account 362 (Distribution Station Equipment)

Depreciation

TURN Position




Line

TURN proposes to extend the average service life from currently authorized 65 years to 67 years based on the L0-67 curve having a better visual and mathematical fit to the observed data. The Observed Life Table (OLT) curve for this account is well suited for Iowa curve fitting techniques due to the account’s retirement history and relatively smooth and conventional shape.

TURN-08 pp. 27-30


SCE-07, Vol. 03


in Thousands

1 (545) (2,726) (2,181)Depreciation

Total


(545) (2,726) (2,181)



2021 Test Year

Exhibit:

Cost Component:

Witness:

Issue Title:




TURN-106 | T&D Service Lives - Account 366 (Distribution UG Conduit)

Depreciation

TURN Position




Line

TURN proposes to extend the average service life from currently authorized 59 years to 64 years based on the R2.5-64 curve having a better mathematical fit to the observed data. The Observed Life Table (OLT) curve for this account is well suited for Iowa curve fitting techniques due to the account’s retirement history.

TURN-08, pp. 30-33


SCE-07, Vol. 03


in Thousands

1 1,672 (4,301) (5,973)Depreciation

Total


1,672 (4,301) (5,973)



2021 Test Year

Exhibit:

Cost Component:

Witness:

Issue Title:




TURN-107 | T&D Service Lives - Account 369 (Services)

Depreciation

TURN Position

SCE Position: SCE proposes to retain the authorized average service life of 55 years based on the actuarial study performed by Foster Associates and industry statistics, which shows that the currently authorized 55-year service life is the longest amongst the CA IOUs and the average of the industry as a whole. The analysis did not provide sufficient evidence to warrant adjusting the currently approved parameters.



Line

TURN proposes to extend the average service life from currently authorized 55 years to 60 years based on the R1.5-60 curve having a better mathematical fit to the observed data. The selected curve also represents a balance between current indications of an average service life that is longer than the currently authorized figure, and recognition of the possibility that average service life will decline going forward.

TURN-08, pp. 33-36

David Gunn (SCE), David Garrett (TURN)

SCE-07, Vol. 03


in Thousands

1 747 (4,483) (5,230)Depreciation

Total


747 (4,483) (5,230)



2021 Test Year

Exhibit:

Cost Component:

Witness:

Issue Title:




TURN-108 | T&D Service Lives - Account 370 (Meters)

Depreciation

TURN Position

SCE Position: SCE proposes to retain the authorized average service life of 20 years based on the actuarial study performed by Foster Associates and information provided by engineering experts. At this time, there is not sufficient data to propose a change in the authorized life. Engineers provided corroborating evidence, as well as industry statistics, that support the retention of the 20-year service life. The vast majority of the assets are AMI meters, that are subject to the same harsh environmental conditions as the prior generation electro-mechanical meters. In addition, new technology in the AMI meters is likely to lead to shorter service lives (due to obsolescence) than the prior generation of meters.



Line

TURN proposes to extend the average service life from currently authorized 20 years to 30 years, noting that, while statistical data is limited, the R3-30 curve has a better mathematical fit, and 99% of the assets that have reached 30 years or older are still in service at the end of the study period.

TURN-08, pp. 36-38

David Gunn (SCE), David Garrett (TURN)

SCE-07, Vol. 03


in Thousands

1 (1,820) (29,023) (27,203)Depreciation

Total


(1,820) (29,023) (27,203)



2021 Test Year

Exhibit:

Cost Component:

Witness:

Issue Title:




TURN-111 | Escalation in Generation Decommissioning Estimates

Depreciation

TURN Position

SCE Position: SCE proposes to escalate future decommissioning estimates to the year of final retirement using Handy-Whitman (for both historical and future periods) based on guidance from Standard Practice U-4 and CPUC decisions predating the result in SCE's 2018 GRC.

SCE-07, Vol. 02 pp. 76-77; SCE-18, Vol. 03 pp. 34-38


Line

TURN proposes to forecast decommissioning by removing inflation beyond 2023 (one year before the end of the current rate case), consistent with the treatment adopted in SCE’s 2018 GRC. As an alternative, TURN proposes including inflation to the decommissioning year, but with a revised historical inflation factor (four percent per year, resulting in $27.7 million, p. 34 Table 27).

TURN-09, pp. 33-36


SCE-07, Vol. 03


in Thousands

1 33,229 26,816 (6,413)Depreciation

Total

Hydro decommissioning costs are based on SCE's probability assumptions with adjustments to isolate the escalation proposals (i.e., retirement year dollars for SCE, 2023 dollars for TURN). Financial impact reflects $31 million contribution from Army Corps of Engineers to decommission Borel hydro facility.

33,229 26,816 (6,413)



2021 Test Year

Exhibit:

Cost Component:

Witness:

Issue Title:




TURN-112 | Recovery of Perris Solar Decommissioning and Unrecovered Original Investment

Depreciation

TURN Position

SCE Position: SCE decommissioned the Perris solar rooftop generating facility seven years after it was installed (20-year life). SCE maintains that its actions were prudent and reasonable. Consistent with Standard Practice U-4, and the Commission’s treatment of this class of assets as a group in three prior GRCs, SCE proposes to collect the unrecovered cost of the investment, plus the associated return, over the 10.7-year remaining life of the overall group of solar rooftop assets.



Line

TURN argues that SCE unreasonably proposes to assign the full costs of premature retirement of the Perris facility to ratepayers. Given the uncertainty as to whether the facility rooftop was expected to last 20 years without replacement or major repair, TURN believes it was unreasonable for SCE to execute a lease that allowed the facility owner to unilaterally force SCE to bear the entire costs of early removal for this project. Consistent with past ratemaking treatment for abandoned plant, TURN proposes to collect the unrecovered costs (net book value plus decommissioning) of the Perris solar photovoltaic generating facility over six years with no rate of return. Note: In the table below, TURN proposes $2 million annual depreciation expense above SCE’s proposal because it is accelerating recovery by 4.7 years. However, what is not shown in the table below is TURN’s proposal to bar SCE from earning a return on this investment over the average life of the group.

TURN-09, pp. 37-39


SCE-07, Vol. 03


in Thousands

1 2,537 4,507 1,970Depreciation

Total

Impact based on year-end 2020 net book value for the Perris solar facility and forecast decommissioning costs of $6.5 million.

2,537 4,507 1,970



2021 Test Year

Exhibit:

Cost Component:

Witness:

Issue Title:




TURN-113 | Palo Verde Interim Retirement Rate

Depreciation

TURN Position

SCE Position: SCE proposes to increase the interim retirement net salvage rates based on a 10-year average of retirements and net salvage experience.

SCE-07, Vol. 02 pp. 77-78; SCE-18, Vol. 03 pp. 49


Line

TURN proposes to use a 7-year average for computation of interim net salvage rates for Palo Verde to remove the effects of a large project in 2010 replacing reactor vessel closure heads.

TURN-09, pp. 28-30


SCE-07, Vol. 03


in Thousands

1 19,798 18,031 (1,767)Depreciation

Total

Impact based on Year-End 2018 CPUC jurisdictional plant.

19,798 18,031 (1,767)



2021 Test Year

Exhibit:

Cost Component:

Witness:

Issue Title:




TURN-114 | Recovery of Fuel Cell Decommissioning

Depreciation

TURN Position

SCE Position: SCE proposes to initiate recovery of $3M of future decommissioning costs of fuel cell installations at California State University, San Bernardino (CSUSB) and University of California Santa Barbara (UCSB). SCE proposes to amortize this amount through the end of 2023.

SCE-07, Vol. 02 pp. 87; SCE-18, Vol. 03 pp. 50-52


Line

TURN recommends reducing SCE's contingency in the decommissioning estimates from 25% to 15%. TURN also proposes to reduce the fuel cell decommissioning costs by 50 percent due to uncertainty about the necessity of decommissioning.

TURN-09, pp. 39-41


SCE-07, Vol. 03


in Thousands

1 1,000 453 (547)Depreciation

Total 1,000 453 (547)



2021 Test Year

Exhibit:

Cost Component:

Witness:

Issue Title:




in Thousands

PAO-TURN-109 | T&D Net Salvage

Depreciation

PAO Position:

SCE Position: SCE's proposals for net salvage accruals are higher (more negative) for 11 accounts, and the same as authorized for 10 accounts. SCE performed an account-by-account net salvage analysis, and proposals were made in order to close the gap between authorized levels and the level of current removal costs, with the majority of increases being attributable to accounts 365-368.

SCE-18, Vol. 03 pp. 3-13


PAO vs SCE

Line

PAO proposes to limit net salvage increases for FERC accounts 365, 366, 367, and 368 based on the potential for economies of scale and changes in future asset mix that would possibly lead to rates decreasing. A gradualism principle was applied to each account to achieve the reductions in net salvage rates.

PAO-16, pp. 9-18

TURN Position: TURN recognizes that the data provided by SCE indicates that the net salvage rates for the 11 accounts at issue should increase, but proposes to limit net salvage increases to 25% of SCE's proposed increase, consistent with the “gradualism” approach used by the Commission in PG&E's 2014 GRC Decision.

TURN-08, pp. 39-42

David Gunn (SCE), Jerry Lin (PAO), David Garrett (TURN)

SCE-07, Vol. 03


1 199,168 60,252 50,089(138,915) (149,079)Depreciation

Total


199,168 60,252 50,089(138,915) (149,079)



2021 Test Year

Exhibit:

Cost Component:

Witness:

Issue Title:




in Thousands

PAO-TURN-110 | Hydro Decommissioning

Depreciation

PAO Position:

SCE Position: SCE agrees to offset estimated decommissioning by $31 million contribution from Army Corps of Engineers and proposes to recover $27.4 million in annual depreciation expense for the recovery of future decommissioning of small Hydro facilities. The values are adjusted for the probability of decommissioning occurring during the current license cycle.



PAO vs SCE

Line

PAO proposes to limit SCE's requested increase in hydro decommissioning accruals to only Rush Creek (Agnew, 99% probability) and Borel (90% probability). In addition, PAO recommends that Borel's estimate be reduced by 50 percent for potential cash contributions from the Army Corps of Engineers. For hydro decommissioning only, PAO also proposes accruals based on present day dollars instead of dollars inflated to the year of decommissioning.

PAO-16, pp. 19-23

TURN Position: For purposes of beginning a fund for decommissioning small hydroelectric generation plants, TURN proposes an annual recovery for plants with the highest probability of decommissioning -- Rush Creek (Agnew, 99% probability) and Borel (90% probability). In addition, TURN recommends applying $31 million of anticipated cash contributions from the Army Corps of Engineers as a reduction to the total cost of decommissioning, an adjustment with which SCE agrees. For TURN’s escalation proposal, see TURN-128 Escalation in Generation Decommissioning Estimates.

TURN-09, pp. 30-33

David Gunn (SCE), Jerry Lin (PAO), William Marcus (TURN)

SCE-07, Vol. 03


1 27,376 6,759 10,104(20,617) (17,273)Depreciation

Total 27,376 6,759 10,104(20,617) (17,273)



Section 14 | Summary Of Differences Related to Other Issues

253


2021 Test Year

Cost Component:

Issue Title:



PAO-199 | Differences related to Other Issues

O&M

The differences between SCE and Intervenors are the results of the differences in labor, non-labor, and other forecasts of other issues. The forecast differences effect the calculation of these activities.

Not Applicable


2018$ in Thousands

SCE Position:

PAO Position:

SCEBPEGRC Activity

PAO vs SCE

PAOFERCAccount

Billing & Payments

904 | Uncollectible Expenses

Other 15,907 15,402(505)

15,907Billing & Payments Total: 15,402(505)



2021 Test Year


926 | 401K Savings Plan

Other 93,577 87,811(5,765)

926 | Adjustment for Shareholder P&B - 926

Labor (9) (20)(11)

Non-Labor (23) (23)0

Other (730) (649)82

926 | Dental Plans

Other 13,103 12,266(837)

926 | Disability Management - Programs

Other 17,623 16,485(1,138)

926 | Executive Benefits (Non-Service)

Other 0 (27)(27)

926 | Executive Benefits (Service)

Other 0 (7)(7)

926 | Group Life Insurance

Other 1,349 1,263(86)

926 | Medical Programs

Other 98,954 92,635(6,319)

926 | Miscellaneous Benefit Programs

Other 6,223 5,825(397)

926 | Vision Service Plan

Other 2,766 2,590(177)

232,832Employee Benefits & Programs Total: 218,149(14,684)


927 | Franchise Fees

Other 81,840 74,574(7,265)

930 | Participant Credits and Charges - 930

Non-Labor 11,072 11,0731

9990 | Reduction in A&G For Catalina

Non-Labor (1,134) (960)174

91,778Financial Oversight & Transactional Processing Total: 84,688(7,090)



2021 Test Year

Legal

925 | Adjustment for Shareholder P&B - 925

Labor (12) (12)0

Non-Labor (183) (183)0

Other (3,562) (2,701)861

(3,757)Legal Total: (2,896)861


456 | Income Tax Component of Contribution

Other 27,583 26,938(645)

27,583Other Operating Revenue Total: 26,938(645)

Overhead Allocation

922 | Capitalized A&G Expense

Other (270,863) (192,582)78,282

926 | Capitalized P&B Expense

Labor 0 00

Other (226,938) (218,839)8,099

(497,801)Overhead Allocation Total: (411,421)86,380

(133,458) (69,141)Total Related to Other Issues: 64,317



Appendix A | Settlements

257

SCE and Conterra Settlement Agreement:

The Settling Parties (SCE and Conterra Networks) have reached an agreement that resolves all issues raised by Conterra in the 2021 GRC.

Settlement Issue

Settlement Position

1.Fees for Pole Attachments

a. SCE will set the Process and Engineering Fee at $186.78 and the Post-Inspection Fee at $215.67.

2. Pole Loading Calculations for New Attachments

a. SCE will no longer require that Conterra submit Pole Loading Calculations with its RFA applications.

3. One Time Reduction

a. SCE agrees to a one-time reduction of $80,968 for Conterra Networks.

258

SCE and SEIA/Vote Solar Settlement Agreement:

The Settling Parties (SCE and SEIA/Vote Solar) have reached an agreement that resolves all issues raised by SEIA/Vote Solar in the 2021 GRC.

Settlement Issue

Settlement Position

1.Enhancements to PV Dependability (PV Dependability Enhancement Data)

a. SCE will investigate potential data anomalies presented by SEIA/Vote Solar in its 2021 GRC prepared testimony regarding particular customer solar systems. SCE will further investigate its entire PV Dependability data set to determine if there are additional data anomalies.

b. In the 2021 Distribution Planning Process, SCE will include any corrections regarding the data anomalies, or changes to the PV Dependability Methodology, that SCE judges to be consistent with continuing to maintain and operate a safe and reliable grid.

c. When SCE makes its 2021 GNA Filing in or around August 2021, SCE will concurrently, but separately, provide to SEIA/Vote Solar an explanation of the changes to the PV Dependability Methodology used in the 2021 Distribution Planning Process compared to the PV Dependability Methodology SCE used in connection with SCE’s 2021 GRC prepared testimony exhibits.

d. When SCE makes its 2021 GNA Filing, SCE will also make available non-confidential PV customer data (appropriately anonymized) that was used by SCE in the PV Dependability Methodology in connection with the 2021 Distribution Planning Process.

e. SCE will not submit the PV Dependability Enhancement Data for inclusion in the Commission’s record concerning the GNA, and the Settling Parties agree that the PV Dependability Enhancement Data will not be provided and is not to be included as a formal part of the GNA filing record. However, SEIA/Vote Solar will not be precluded from sharing this public data with interested parties in connection with the 2021 GNA. At the time that SEIA/Vote Solar shares this data with any interested party, or within a reasonable timeframe thereafter, SEIA/Vote Solar shall provide written notice to SCE that it has shared the data with the interested party. Such written notice can be in any form chosen by SEIA/Vote Solar, including simply copying SCE on any email transmittal of the data from SEIA/Vote Solar to the interested party.

2. Analysis of Load Growth Project Cancellations (Project Cancellation Data)

a. Commencing with the 2021 Distribution Planning Process, SCE will report on certain items for PIN-based Projects that meet both of the following criteria: (1) the PIN-based Project is one for which SCE had an internal forecast cost that exceeds ten million dollars; and (2) the PIN-based project has been cancelled by SCE. For PIN-based Projects that meet both of these criteria, SCE will report on the following:

i. Change in forecast load-reducing DERs in the area when compared to the prior year’s Distribution Planning Process. ii. Change in PV dependability curve assumptions (if any) in the area from the prior year’s Distribution Planning Process. iii. Potential other relevant factors affecting the load forecast.

b. This information will be provided to SEIA/Vote Solar concurrently with the filing of the annual GNA report in a manner consistent with SCE’s production of the PV Dependability Enhancement Data described above in Settlement Issue #1 above.

c. With respect to the Project Cancellation Data and analysis associated with that data, SEIA/Vote Solar will be afforded a reasonable opportunity to submit to SCE recommendations that SEIA/Vote Solar may have regarding how to improve the Project Cancellation Data and associated analysis. SCE will take such recommendations into consideration when SCE is preparing the following year’s analysis

3. Effective Time Period for Data Requirements

a. SCE will produce to SEIA/Vote Solar both the PV Dependability Enhancement Data and the Project Cancellation Data in August of 2021, 2022, and 2023. SCE notes that its Test Year 2025 GRC forecast for Load Growth activities will likely be based on the 2022 Distribution Planning Process. SCE currently anticipates that its Test Year 2025 GRC Application will be filed on or around May 1, 2023.

259

SCE and SoCal CCAs Settlement Agreement:

The Settling Parties (SCE and SoCal CCAs) have reached an agreement that resolves all issues raised by SoCal CCAs in the 2021 GRC.

Settlement Issue

Settlement Position

1.CCA Service Fees

a. Settling Parties agree that four service fees will be revised from SCE’s rebuttal position: • Mass Enrollment – Per Service Account • CCA Termination of Service - Voluntary Termination per Event, per Service

Account • Meter and Data Management Agent (MDMA) - Meter Data Posting Fee • Standard Phase-In Service – Per Service Account • Monthly Account Maintenance Fee – Per Service Account

The result of revising these fees is a reduction of SCE’s Test Year Other Operating Revenues (OOR) forecast for Customer Interactions from $24.745 million to $23.818 million, a decrease of $0.927 million.

2. Additional Conditions Related to the Monthly Account Maintenance Fee

a. SCE shall develop and provide additional data and analysis, as reasonably requested by the SoCal CCAs, regarding the basis for the MAMF. SCE may, at its sole discretion, submit a revised MAMF proposal in a ratesetting proceeding selected by SCE.

3. Automation Efforts and Process Improvements

a. SCE agrees to work with the SoCal CCAs, and, upon request, the SoCal CCAs’ designated back-office provider, to investigate and potentially implement potential automation or other processes

b. SCE agrees to meet with the SoCal CCAs, as well as any other CCAs that indicate to SCE that they wish to participate, or the designees of such entities, on at least a quarterly basis, at a date and time mutually agreeable to the Settling Parties

c. SCE will provide to the SoCal CCAs a Final Report shall include a description of (1) the specific processes (including but not limited to automated processes), if any, that SCE has implemented or intends to implement within the 12 months following SCE’s issuance of the Final Report; and (2) actions, if any, SCE identified that would result in reducing or eliminating the EDI-VAN charge, as well as an estimate of the costs of implementing such actions.

4. Additional Data and Advanced Metering Infrastructure Data

a. SCE will provide the Additional Data to the SoCal CCAs, as well as other CCAs, on a once per calendar month basis, subject to the Commission’s approval of SCE’s Tier 2 advice letter seeking modifications to permit providing such Additional Data, as well as other conditions set forth in the settlement agreement.

260


Appendix B | SCE and PAO CPUC Comparison Reports

261

SOUTHERN CALIFORNIA EDISON

2021 GENERAL RATE CASE APPLICATION (A.19-08-013)

Appendix B | Table I-1 | Results of Operations (Total Company)

2021$ in Thousands

Table I-1

Results of Operations (Total Company) 2021 Test Year

Line Description SCE Revised Difference CAL PA Revised

1. Total Revenue Requirement 8,837,009 (784,516) 8,052,494

2. Operating Expenses:

3. Production

4. Steam 8,325 (5,216) 3,109

5. Nuclear 75,123 – 75,123

6. Hydro 45,187 – 45,187

7. Other 83,320 0 83,320

8. Total Production 211,955 (5,216) 206,740

9. Transmission 187,844 (21,881) 165,963

10. Distribution 824,027 (234,670) 589,357

11. Customer Accounts 141,554 (26,836) 114,718

12. Uncollectibles (Account 904) 15,907 (526) 15,380

13. Customer Service & Information 83,712 (17,759) 65,953

14. Administrative & General (Excluding Property Insurance) 1,322,156 (204,988) 1,117,168

15. Administrative & General (Property Insurance) 20,462 (1,228) 19,234

16. Franchise Requirements (Account 927) 81,840 (7,265) 74,574

17. Revenue Credits (217,749) (340) (218,089)

18. Total O&M 2,671,708 (520,709) 2,150,998

19. Escalation 118,925 10,200 129,125

20. Depreciation 2,403,708 (201,206) 2,202,503

21. Taxes Other Than On Income

22. Property Taxes 437,995 (3,637) 434,358

23. Payroll Taxes & Misc 71,314 (4,355) 66,959

24. Taxes Based on Income 379,630 (11,457) 368,174

25. Income Taxes 888,939 (19,449) 869,490

26. Total Operating Expenses 6,083,280 (731,164) 5,352,115

27. Net Operating Income 2,753,730 (53,351) 2,700,378

28. Rate Base 35,859,589 (371,254) 35,488,335

29. Rate of Return 7.68% 7.61%

1/ SCE did not update PAO's RO model for the Cost of Capital update

2/ SCE did not incorporate updated escalation rates into PAO's RO model

262



Appendix B | Table I-2 | Results of Operations (CPUC Only)

2021$ in Thousands

Table I-2

Results of Operations (CPUC Only) 2021 Test Year

Line Description SCE Revised Difference CAL PA Revised

1. Total Revenue Requirement 7,644,374 (754,074) 6,890,301


3. Production

4. Steam 8,325 (5,216) 3,109

5. Nuclear 75,123 – 75,123

6. Hydro 45,187 – 45,187

7. Other 83,320 0 83,320


9. Transmission 106,087 (12,080) 94,008

10. Distribution 814,918 (228,544) 586,374





15. Administrative & General (Property Insurance) 16,521 (993) 15,528


17. Revenue Credits (163,238) (367) (163,606)

18. Total O&M 2,527,909 (485,231) 2,042,678

19. Escalation 110,408 10,906 121,314

20. Depreciation 2,133,369 (224,481) 1,908,887


22. Property Taxes 353,635 (2,973) 350,663

23. Payroll Taxes & Misc 66,442 (3,750) 62,693

24. Taxes Based on Income 239,040 (5,269) 233,771

25. Income Taxes 659,118 (11,992) 647,126

26. Total Operating Expenses 5,430,803 (710,799) 4,720,004

27. Net Operating Income 2,213,571 (43,275) 2,170,296

28. Rate Base 28,825,546 (303,545) 28,522,001

29. Rate of Return 7.68% 7.61%



263



Appendix B | Table I-3 | Results of Operations (CPUC Only) | SCE's Revised Results of Operations

2021$ in Thousands

Table I-3

Results of Operations (CPUC Only)

Line Description SCE Application Change SCE Rebuttal Change SCE Revised

RO Model Build: (1.1) (2.0) (3.3)

1. Total Revenue Requirement 7,625,153 (76,584) 7,548,568 95,806 7,644,374


3. Production

4. Steam 8,328 (3) 8,325 (0) 8,325

5. Nuclear 80,616 (5,492) 75,123 – 75,123

6. Hydro 45,458 (269) 45,189 (2) 45,187

7. Other 84,502 (1,182) 83,320 (0) 83,320

8. Total Production 218,904 (6,946) 211,958 (3) 211,955

9. Transmission 105,591 (1,030) 104,561 1,527 106,087

10. Distribution 724,751 (11,543) 713,208 101,710 814,918

11. Customer Accounts 139,705 1,648 141,353 201 141,554

12. Uncollectibles (Account 904) 15,403 (985) 14,418 (658) 13,760

13. Customer Service & Information 83,220 492 83,712 – 83,712

14. Administrative & General (Excluding Property Insurance) 1,233,615 (4,640) 1,228,976 2,869 1,231,845

15. Administrative & General (Property Insurance) 13,009 3,511 16,520 1 16,521

16. Franchise Requirements (Account 927) 70,617 (709) 69,907 887 70,795

17. Revenue Credits (165,614) 1,774 (163,840) 601 (163,238)

18. Total O&M 2,439,200 (18,428) 2,420,773 107,136 2,527,909

19. Escalation 152,416 (338) 152,078 (41,670) 110,408

20. Depreciation 2,181,013 (47,994) 2,133,019 350 2,133,369


22. Property Taxes 354,174 (582) 353,592 43 353,635

23. Payroll Taxes & Misc 67,727 (1,025) 66,702 (259) 66,442

24. Taxes Based on Income 222,523 8,838 231,361 7,679 239,040

25. Income Taxes 644,424 7,230 651,655 7,463 659,118

26. Total Operating Expenses 5,417,054 (59,529) 5,357,524 73,279 5,430,803

27. Net Operating Income 2,208,099 (17,055) 2,191,044 22,527 2,213,571

28. Rate Base 29,018,813 (224,144) 28,794,669 30,877 28,825,546

29. Rate of Return 7.61% 7.61% 7.68%

264



Appendix B | Table I-4 | Results of Operations (CPUC Only) | CALPA's Revised Results of Operations

2021$ in Thousands

Table I-4

Results of Operations (CPUC Only)

Line Description CALPA Application Change CALPA Update Change CALPA Revised

RO Model Build: (1.0) (2.0) (3.0)

1. Total Revenue Requirement 6,936,727 (37,226) 6,899,501 (9,201) 6,890,301


3. Production

4. Steam 8,328 (5,218) 3,110 (1) 3,109

5. Nuclear 80,616 – 80,616 (5,492) 75,123

6. Hydro 45,458 – 45,458 (271) 45,187

7. Other 84,502 – 84,502 (1,182) 83,320

8. Total Production 218,904 (5,218) 213,686 (6,946) 206,740

9. Transmission 93,757 – 93,757 251 94,008

10. Distribution 612,551 (27,051) 585,500 874 586,374

11. Customer Accounts 124,761 (9,356) 115,405 (688) 114,718

12. Uncollectibles (Account 904) 13,249 (71) 13,178 (18) 13,160

13. Customer Service & Information 65,953 – 65,953 0 65,953

14. Administrative & General (Excluding Property Insurance) 1,045,413 3,099 1,048,512 (2,520) 1,045,992

15. Administrative & General (Property Insurance) 15,521 3 15,524 4 15,528

16. Franchise Requirements (Account 927) 64,241 (345) 63,896 (85) 63,811

17. Revenue Credits (164,022) (971) (164,993) 1,387 (163,606)

18. Total O&M 2,090,328 (39,910) 2,050,418 (7,740) 2,042,678

19. Escalation 131,517 (9,508) 122,009 (696) 121,314

20. Depreciation 1,907,319 997 1,908,316 571 1,908,887


22. Property Taxes 350,262 109 350,371 292 350,663

23. Payroll Taxes & Misc 63,789 (654) 63,135 (442) 62,693

24. Taxes Based on Income 228,632 7,163 235,795 (2,024) 233,771

25. Income Taxes 642,683 6,617 649,300 (2,175) 647,126

26. Total Operating Expenses 4,771,847 (41,804) 4,730,043 (10,039) 4,720,004

27. Net Operating Income 2,164,879 4,578 2,169,458 839 2,170,296

28. Rate Base 28,450,812 60,169 28,510,981 11,020 28,522,001

29. Rate of Return 7.61% 7.61% 7.61%



265



Appendix B | Table I-5 | Total Operations & Maintenance Expenses and OOR (Total Company)

2021$ in Thousands

Table I-5

Operations & Maintenance Expenses and OOR (Total Company) 2021 Test Year

Line Description SCE Revised Difference CALPA Revised


2. Production

3. Steam 8,325 (5,216) 3,109

4. Nuclear 75,123 – 75,123

5. Hydro 45,187 – 45,187

6. Other 83,320 0 83,320


8. Transmission 187,844 (21,881) 165,963

9. Distribution 824,027 (234,670) 589,357





14. Administrative & General (Property Insurance) 20,462 (1,228) 19,234


16. Revenue Credits (217,749) (340) (218,089)

17. Total O&M and OOR (Constant 2018$) 2,671,708 (520,709) 2,150,998

18. Escalation 118,925 10,200 129,125

19. Total O&M and OOR (Nominal 2021$) 2,790,632 (510,510) 2,280,123

20. Less: Franchise Fees and Uncollectibles (FF&U) (97,746) 7,792 (89,954)

21. Total O&M and OOR - Excluding FF&U (Nominal 2021$) 2,888,379 (518,301) 2,370,077

22. Labor, Non-labor, and Other Expense Detail (Constant 2018$)

23. Labor 986,599 (182,711) 803,888

24. Non-Labor 1,214,432 (224,524) 989,908

25. Other 688,426 (113,135) 575,291

26. Total O&M and OOR (Constant 2018$) 2,889,457 (520,369) 2,369,087

27. Revenue Credits (217,749) (340) (218,089)

28. Escalation

29. Labor 92,737 (17,865) 74,872

30. Non-Labor 25,197 29,056 54,253

31. Other 991 (991) –

32. Total Escalation 118,925 10,200 129,125

33. Total O&M and OOR (Nominal 2021$) 2,790,632 (510,510) 2,280,123

34. Less: Franchise Fees and Uncollectibles (FF&U) (97,746) 7,792 (89,954)

35. Total O&M and OOR - Excluding FF&U (Nominal 2021$) 2,888,379 (518,301) 2,370,077


266



Appendix B | Table I-6 | Total Operations & Maintenance Expenses (Total Company) | Generation Summary

2021$ in Thousands

Table I-6

Operations & Maintenance Expenses - Generation 2021 Test Year



2. Production

3. Steam 8,325 (5,216) 3,109

4. Nuclear 75,123 – 75,123

5. Hydro 45,187 – 45,187

6. Other 83,320 0 83,320

7. Total Production (Constant 2018$) 211,955 (5,216) 206,740

8. Escalation 7,762 5,533 13,294

9. Total Production (Nominal 2021$) 219,717 317 220,034

10. Labor, Non-labor, and Other Expense Detail:

11. Labor 76,283 (5,216) 71,067

12. Non-Labor 132,374 – 132,374

13. Other 3,299 – 3,299

14. Total Production (Constant 2018$) 211,955 (5,216) 206,740

15. Escalation:

16. Labor 7,170 (551) 6,619

17. Non-Labor 567 6,109 6,675

18. Other 25 (25) –


20. Total Production (Nominal 2021$) 219,717 317 220,034


267

Southern California Edison


Appendix B | Table I-7 | Total Operations & Maintenance Expenses (Total Company) | Generation - Steam

$ in Thousands

Operations & Maintenance Expenses - Steam 2021 Test Year

SCE Revised Difference CALPA Revised

Line FERC Description

1. 500 Operation Supervision and Engineering 8,025 (5,216) 2,8092. 501 Fuel – – –3. 502 Steam Expenses – – –4. 505 Electric Expenses – – –5. 506 Miscellaneous Steam Power Expenses 300 – 3006. 507 Rents – – –7. 509 Allowances – – –8. Total Operation 8,325 (5,216) 3,109

9. 510 Maintenance Supervision and Engineering – – –10. 511 Maintenance of Structures – – –11. 512 Maintenance of Boiler Plant – – –12. 513 Maintenance of Electric Plant – – –13. 514 Maintenance of Miscellaneous Steam Plant – – –14. Total Maintenance – – –

15. Total Steam (Constant 2018$) 8,325 (5,216) 3,109

16. Escalation 757 (480) 277

17. Total Steam (Nominal 2021$) 9,082 (5,696) 3,386

18. Labor, Non-labor, and Other Expense Detail:19. Labor 8,025 (5,216) 2,80920. Non-Labor 300 – 30021. Other – – –22. Total O&M (Constant 2018$) 8,325 (5,216) 3,109

23. Escalation:24. Labor 754 (493) 26225. Non-Labor 3 13 1626. Other – – –27. Total Escalation 757 (480) 277

28. Total O&M (Nominal 2021$) 9,082 (5,696) 3,386


268

Southern California Edison2021 GENERAL RATE CASE APPLICATION (A.19-08-013)Appendix B | Table I-8 | Total Operations & Maintenance Expenses (Total Company) | Generation - Nuclear

$ in Thousands

Operations & Maintenance Expenses - Nuclear 2021 Test Year



1. 517 Operation Supervision and Engineering 16,741 – 16,741

2. 518 Nuclear Fuel Expense – – –

3. 519 Coolants and Water 7,183 – 7,183

4. 520 Steam Expenses 4,891 – 4,891

5. 523 Electric Expenses 5,936 – 5,936

6. 524 Miscellaneous Nuclear Power Expenses 21,196 – 21,196

7. 525 Rents – – –

8. Total Operation 55,947 – 55,947

9. 528 Maintenance Supervision and Engineering 3,055 – 3,055

10. 529 Maintenance of Structures 972 – 972

11. 530 Maintenance of Reactor Plant Equipment 10,513 – 10,513

12. 531 Maintenance of Electric Plant 3,589 – 3,589

13. 532 Maintenance of Miscellaneous Nuclear Plant 1,047 – 1,047

14. Total Maintenance 19,177 – 19,177

15. Total Nuclear (Constant 2018$) 75,123 – 75,123

16. Escalation 593 3,287 3,880

17. Total Nuclear (Nominal 2021$) 75,717 3,287 79,003


19. Labor 268 – 268

20. Non-Labor 74,856 – 74,856

21. Other – – –

22. Total O&M (Constant 2018$) 75,123 – 75,123

23. Escalation:

24. Labor 25 (0) 25

25. Non-Labor 568 3,287 3,855

26. Other – – –

27. Total Escalation 593 3,287 3,880

28. Total O&M (Nominal 2021$) 75,717 3,287 79,003


269



Appendix B | Table I-9 | Total Operations & Maintenance Expenses (Total Company) | Generation - Hydro

$ in Thousands

Operations & Maintenance Expenses - Hydro 2021 Test Year



1. 535 Operation Supervision and Engineering 158 – 158

2. 536 Water for Power 5,071 – 5,071

3. 537 Hydraulic Expenses 769 – 769

4. 538 Electric Expenses – – –

5. 539 Miscellaneous Hydraulic Power Generation Expenses 26,143 – 26,143

6. 540 Rents – – –

– –

7. Total Operation 32,140 – 32,140

8. 541 Maintenance Supervision and Engineering – – –

9. 542 Maintenance of Structures – – –

10. 543 Maintenance of Reactor Plant Equipment 269 – 269

11. 544 Maintenance of Electric Plant – – –

12. 545 Maintenance of Miscellaneous Nuclear Plant 12,778 – 12,778


14. Total Hydro (Constant 2018$) 45,187 – 45,187

15. Escalation 2,038 1,175 3,214

16. Total Hydro (Nominal 2021$) 47,226 1,175 48,401


18. Labor 24,704 – 24,704

19. Non-Labor 20,483 – 20,483

20. Other – – –

21. Total O&M (Constant 2018$) 45,187 – 45,187

22. Escalation:

23. Labor 2,322 (21) 2,301

24. Non-Labor (284) 1,197 913

25. Other – – –


27. Total O&M (Nominal 2021$) 47,226 1,175 48,401


270



Appendix B | Table I-10 | Total Operations & Maintenance Expenses (Total Company) | Generation - Other

$ in Thousands

Operations & Maintenance Expenses - Generation Other 2021 Test Year



1. 546 Operation Supervision and Engineering 255 0 255

2. 547 Fuel – – –

3. 548 Generation Expenses – – –

4. 549 Miscellaneous Other Power Generation Expenses 19,778 – 19,778

5. 550 Rents 4,138 – 4,138

6. Total Operation 24,170 0 24,170

7. 551 Maintenance Supervision and Engineering – – –

8. 552 Maintenance of Structures – – –

9. 553 Maintenance of Generating and Electric Plant 1,251 – 1,251

10. 554 Maintenance of Miscellaneous Other Power Generation Plant 25,492 – 25,492

11. 555 Purchased Power – – –

12. 556 System Control and Load Dispatching 1,062 – 1,062

13. 557 Other Expenses 31,345 – 31,345


15. Total Other Production (Constant 2018$) 83,320 0 83,320

16. Escalation 4,373 1,551 5,923

17. Total Other Production (Nominal 2021$) 87,693 1,551 89,244


19. Labor 43,286 0 43,287

20. Non-Labor 36,735 – 36,735

21. Other 3,299 – 3,299

22. Total O&M (Constant 2018$) 83,320 0 83,320

23. Escalation:

24. Labor 4,069 (37) 4,032

25. Non-Labor 279 1,613 1,892

26. Other 25 (25) –


28. Total O&M (Nominal 2021$) 87,693 1,551 89,244


271


2021 GENERAL RATE CASE APPLICATION (A.19-08-013)Appendix B | Table I-11 | Total Operations & Maintenance Expenses (Total Company) | Transmission

$ in Thousands

Operations & Maintenance Expenses - Transmission 2021 Test Year



1. 560 Operation Supervision and Engineering 7,350 – 7,350

2. 561 Load Dispatching 16,260 (726) 15,534

3. 562 Station Expenses 20,857 – 20,857

4. 563 Overhead Line Expenses 13,240 (1,893) 11,347

5. 564 Underground Line Expenses 1,943 – 1,943

6. 565 Transmission of Electricity by Others 615 – 615

7. 566 Miscellaneous Transmission Expenses 41,053 – 41,053

8. 567 Rents 17,748 – 17,748

9. Total Operation 119,067 (2,619) 116,448


11. 569 Maintenance of Structures 2,375 – 2,375

12. 570 Maintenance of Station Equipment 11,001 – 11,001

13. 571 Maintenance of Overhead Lines 47,377 (19,261) 28,116

14. 572 Maintenance of Underground Lines 3,234 – 3,234

15. 573 Maintenance of Miscellaneous Transmission Plant 2,029 – 2,029

16. Total Maintenance 68,777 (19,261) 49,516

17. Total O&M (Constant 2015$) 187,844 (21,881) 165,963

18. Escalation 9,283 570 9,853

19. Total O&M (Nominal 2018$) 197,127 (21,311) 175,816

Labor, Non-labor, and Other Expense Detail:

20. Labor 88,098 (8,848) 79,250

21. Non-Labor 82,272 (13,032) 69,239

22. Other 17,475 – 17,475


Escalation:

24. Labor 8,281 (900) 7,381

25. Non-Labor 1,002 1,470 2,472

26. Other – – –

27. Total Escalation 9,283 570 9,853

28. Total O&M (Nominal 2018$) 197,127 (21,311) 175,816


272



Appendix B | Table I-12 | Total Operations & Maintenance Expenses (Total Company) | Distribution

$ in Thousands

Operations & Maintenance Expenses - Distribution 2021 Test Year



1. 580 Operation Supervision and Engineering 15,242 (372) 14,870

2. 582 Station Expenses 36,562 – 36,562

3. 583 Overhead Line Expenses 73,253 (16,787) 56,466

4. 584 Underground Line Expenses 6,960 – 6,960

5. 585 Street Lighting and Signal System Expenses 64 – 64

6. 586 Meter Expenses 22,454 – 22,454

7. 587 Customer Installations Expenses 19,888 (205) 19,683

8. 588 Miscellaneous Distribution Expenses 156,537 (55,424) 101,114

9. 589 Rents 2,863 – 2,863

10. Total Operation 333,823 (72,788) 261,035


12. 591 Maintenance of Structures 58 – 58

13. 592 Maintenance of Station Equipment 10,497 187 10,684

14. 593 Maintenance of Overhead Lines 377,128 (154,952) 222,177

15. 594 Maintenance of Underground Lines 70,049 (7,168) 62,881

16. 595 Maintenance of Line Transformers 4,670 34 4,704

17. 596 Maintenance of Street Lighting and Signal Systems 5,483 – 5,483

18. 597 Maintenance of Meters 2,600 – 2,600

19. 598 Maintenance of Miscellaneous Distribution Plant 17,166 16 17,181

20. Total Maintenance 490,204 (161,883) 328,322


22. Escalation 31,376 7,718 39,093

23. Total O&M (Nominal 2021$) 855,403 (226,953) 628,450


24. Labor 317,602 (66,828) 250,773

25. Non-Labor 503,562 (167,842) 335,720

26. Other 2,863 – 2,863


Escalation:

28. Labor 29,853 (6,497) 23,356

29. Non-Labor 1,522 14,215 15,737

30. Other – – –


32. Total O&M (Nominal 2021$) 855,403 (226,953) 628,450


273



Appendix B | Table I-13 | Total Operations & Maintenance Expenses (Total Company) | Customer Accounts

$ in Thousands

Operations & Maintenance Expenses - Customer Accounts 2021 Test Year



1. 901 Supervision 13,488 – 13,488

2. 902 Meter Reading Expenses 3,135 – 3,135

3. 903 Customer Records and Collection Expenses 105,394 (5,081) 100,313

4. 904 Uncollectible Accounts 15,907 (526) 15,380

5. 905 Miscellaneous Customer Accounts Expenses 19,537 (13,295) 6,242

6. 9991 Interest Offset on Customer Deposits – (8,460) (8,460)

7. Total Customer Accounts (Constant 2018$) 157,461 (27,362) 130,098

8. Escalation 10,273 (1,159) 9,115

9. Total Customer Accounts (Nominal 2021$) 167,734 (28,521) 139,213

10. Less: Account 904 (Uncollectible Accounts) (15,907) 526 (15,380)

11. Total Customer Accounts (Nominal 2021$ - Less Account 904) 151,827 (27,995) 123,833


12. Labor 97,809 (18,015) 79,794

13. Non-Labor 30,115 (139) 29,977

14. Other 29,536 (9,208) 20,327


Escalation:

16. Labor 9,194 (1,762) 7,432

17. Non-Labor 1,080 603 1,683

18. Other – – –

19. Total Escalation 10,273 (1,159) 9,115

20. Total Customer Accounts (Nominal 2021$) 167,734 (28,521) 139,213

21. Less: Account 904 (Uncollectible Accounts) (15,907) 526 (15,380)

22. Total O&M (Nominal 2021$ - Less Account 904) 151,827 (27,995) 123,833


274

Southern California Edison2021 GENERAL RATE CASE APPLICATION (A.19-08-013)Appendix B | Table I-14 | Total Operations & Maintenance Expenses (Total Company) | Customer Service & Information and Sales Expenses

$ in Thousands

Operations & Maintenance Expenses - CS&I 2021 Test Year



1. 907 Supervision 2,155 – 2,155

2. 908 Customer Assistance Expenses 54,534 (12,559) 41,975

3. 909 Informational and Instructional Advertising Expenses 19,686 (5,200) 14,486

4. 910 Miscellaneous Customer Service and Informational Expenses – – –

5. 912 Demonstrating and Selling Expenses 7,338 – 7,338

6. 913 Advertising Expenses – – –

7. Total Customer Service & Information 83,712 (17,759) 65,953

8. 916 Miscellaneous Sales Expenses – – –

9. Total Customer Service & Information (Constant 2018$) 83,712 (17,759) 65,953

10. Escalation 5,048 (328) 4,720

11. Total Customer Service & Information (Nominal 2021$) 88,760 (18,086) 70,674

Labor, Non-labor, and Other Expense Detail:12. Labor 46,272 (10,383) 35,889

13. Non-Labor 37,441 (7,376) 30,065

14. Other – – –


Escalation:16. Labor 4,349 (1,007) 3,343

17. Non-Labor 699 679 1,378

18. Other – – –

19. Total Escalation 5,048 (328) 4,720

20. Total O&M (Nominal 2021$) 88,760 (18,086) 70,674


275



Appendix B | Table I-15 | Total Operations & Maintenance Expenses (Total Company) | Administrative & General

$ in Thousands

Operations & Maintenance Expenses - A&G 2021 Test Year



1. 920 Administrative and General Salaries 351,138 (73,591) 277,547

2. 921 Office Supplies and Expenses 311,701 (32,330) 279,371

3. 922 Administrative Expenses Transferred - Credit (270,863) 78,282 (192,582)

4. 923 Outside Services Employed 51,623 (1,767) 49,856

5. 924 Property Insurance 20,462 (1,228) 19,234

6. 924 Claims - Administration 51 – 51

7. 925 Injuries and Damages 692,020 (158,675) 533,345

8. 926 Employee Pensions and Benefits 140,447 (12,984) 127,463

9. 927 Franchise Requirements 81,840 (7,265) 74,574

10. 928 Regulatory Commission Expenses 42 – 42

11. 930 General Advertising Expenses-Miscellaneous General Expenses 13,798 (1,668) 12,130

12. 931 Rents 13,190 26 13,216

13. 9990 Reduction for A&G Credit for Catalina Utilities (1,134) 174 (960)

14. Total Operation 1,404,314 (211,026) 1,193,287

15. 935 Maintenance of General Plant 20,144 (2,455) 17,689

16. Total O&M (Constant 2018$) 1,424,458 (213,481) 1,210,976

17. Escalation 55,183 (2,134) 53,049

18. Total O&M (Nominal 2021$) 1,479,641 (215,616) 1,264,025

19. Less: Account 927 (Franchise Requirements) (81,840) 7,265 (74,574)

20. Total O&M (Nominal 2021$ - Less Account 927) 1,397,802 (208,350) 1,189,451


21. Labor 360,536 (73,420) 287,116

22. Non-Labor 428,668 (36,135) 392,534

23. Other 635,253 (103,926) 531,327

24. Total O&M (Constant 2018$) 1,424,458 (213,481) 1,210,976

Escalation:

25. Labor 33,889 (7,148) 26,741

26. Non-Labor 20,328 5,980 26,308

27. Other 966 (966) –

28. Total Escalation 55,183 (2,134) 53,049

29. Total O&M (Nominal 2021$) 1,479,641 (215,616) 1,264,025

30. Less: Account 927 (Franchise Requirements) (81,840) 7,265 (74,574)

31. Total O&M (Nominal 2021$ - Less Account 927) 1,397,802 (208,350) 1,189,451


276



Appendix B | Table I-16 | Other Operating Revenue Total Operations & Maintenance Expenses

$ in Thousands

Other Operating Revenue 2021 Test Year


Line Description

1. 450.000 - Forfeited Discounts

2. Customer Service Operations OOR 11,430 – 11,430

3. 451.000 - Miscellaneouse Service Revenues

4. Customer Service Operations OOR 9,294 985 10,279

5. Transmission & Distribution OOR 586 – 586

6. Total 451.000 9,880 985 10,865

7. 453.000 - Sales of Water & Water Power

8. Financial and Other Miscellaneous Revenues – –

9. 454.000 - Rent from Electric Property

10. Transmission & Distribution OOR 63,169 – 63,169

11. Financial and Other Miscellaneous Revenues – – –

12. Total 454.000 63,169 – 63,169

13. 456.000 - Other Electric Revenue

14. Customer Service Operations OOR 3 – 3

15. CS&I Tariffed Products and Services OOR 4,018 – 4,018

16. Transmission & Distribution OOR 81,855 – 81,855

17. Financial and Other Miscellaneous Revenues 29,688 (645) 29,043

18. Total 456.000 115,564 (645) 114,919

19. Gains/Losses on Sale of Property 1,034 – 1,034

20. Gross Revenue Sharing Mechanism Authorized Threshold 16,672 – 16,672

21. Escalation –

22. Total OOR 217,749 340 218,089

277



Appendix B | Table I-17 | Rate Base (Total Company)

2021$ in Thousands

Table I-17

Rate Base (Total Company) 2021 Test Year


1. Net Plant In Service

2. Gross Plant 56,146,933 (297,878) 55,849,055

3. Accumulated Depreciation Reserve (15,804,443) 34,403 (15,770,040)

4. Total Net Plant In Service 40,342,490 (263,475) 40,079,015

5. Cash Working Capital

6. Customer Deposits – – –

7. Customer Advance for Construction (62,365) – (62,365)

8. Material & Supplies 237,624 2,903 240,527

9. Mountainview Emission Credits 4,354 – 4,354

10. Unfunded Pension Reserve (52,828) 2,609 (50,219)

11. Working Cash 808,855 (116,016) 692,839

12. Total Cash Working Capital 935,641 (110,504) 825,137

13. Accumulated Deferred Taxes

14. Accum. Def. Taxes - Plant (5,493,648) 4,396 (5,489,251)

15. Accum. Def. Taxes - CIAC 66,126 (1,671) 64,455

16. Accum. Def. Taxes - Vacation Accrual 8,980 – 8,980

17. Total Accumulated Deferred Taxes (5,418,542) 2,725 (5,415,817)

18. Total Rate Base (Unadjusted) 35,859,589 (371,254) 35,488,335

19. Rate Base Adjustment (172,553) 13,461 (159,092)

20. Total Rate Base (Adjusted) 35,687,035 (357,793) 35,329,243

21. Depreciation and Amortization 2,403,708 (201,206) 2,202,503

1/ The difference between SCE and ORA is the result of the differences in capital expenditures, overheads, and depreciation expense.

2/ The difference between SCE and ORA is the result of specific issues in the working cash and depreciation expense areas, plus differences related to

changes in O&M, capital expenditures, and overheads.

278



Appendix B | Table I-18 | Summary of Weighted Average Plant (Total company)

2021$ in Thousands

Table I-18

Summary of Weighted Average Plant (Total Company) 2021 Test Year


1. Generation

2. Palo Verde 2,114,921 103 2,115,024

3. Hydro 1,325,968 6,718 1,332,686

4. Mountainview 831,323 (2,050) 829,273

5. Pebbly Beach 96,193 (3,496) 92,697

6. Peakers 418,411 56 418,467

7. Solar PV 374,837 (3,988) 370,850

8. Fuel Cell 13,422 – 13,422

9. Energy Storage 65,323 – 65,323

10. Other Production 210 – 210

11. Total Generation 5,240,608 (2,657) 5,237,950

12. Transmission

13. Transmission Land 381,305 636 381,941

14. Transmission Substations 8,410,136 (38,224) 8,371,912

15. Transmission Lines 8,055,662 22,372 8,078,033

16. Total Transmission 16,847,102 (15,215) 16,831,887

17. Distribution

18. Transmission Land 162,024 (4,682) 157,342

19. Transmission Substations 3,947,527 19,904 3,967,431

20. Transmission Lines 24,827,236 (239,112) 24,588,124

21. Total Distribution 28,936,788 (223,890) 28,712,898

22. General

23. General 3,451,516 (1,809) 3,449,707

24. General Other 83,263 (1,150) 82,112

25. Total General 3,534,779 (2,959) 3,531,819

26. Intangible Plant

27. Capitalized Software 1,327,049 (51,045) 1,276,003

28. Hydro Relicensing 196,623 (2,111) 194,513

29. Radio Frequency 18,723 – 18,723

30. Miscellaneous Intangibles 611 – 611

31. Mountainview Intangibles 44,650 – 44,650

32. Total Intangible Plant 1,587,656 (53,156) 1,534,500

33. Total Weighted Average Plant 56,146,933 (297,878) 55,849,055

1/ Changes in accumulated depreciation and amortization are the result of the differences in plant forecasts and depreciation rates.

279



Appendix B | Table I-19 | Summary of Weighted Average Reserve (Total company)

2021$ in Thousands

Table I-19

Summary of Weighted Average Reserve (Total Company) 2021 Test Year


1. Generation

2. Palo Verde 1,590,195 40 1,590,236

3. Hydro 577,664 (42,094) 535,570

4. Mountainview 339,309 (92) 339,217

5. Pebbly Beach 41,227 176 41,404

6. Peakers 167,257 4 167,261

7. Solar PV 205,499 (471) 205,028

8. Fuel Cell 11,424 (200) 11,224

9. Energy Storage 26,416 – 26,416

10. Other Production 10 – 10

11. Total Generation 2,959,002 (42,636) 2,916,366

12. Transmission


14. Transmission Substations 1,348,501 6,238 1,354,740


16. Total Transmission 3,199,348 2,980 3,202,328

17. Distribution


19. Transmission Substations 717,086 (1,187) 715,899

20. Transmission Lines 7,022,420 15,042 7,037,462

21. Total Distribution 7,752,063 13,916 7,765,979

22. General

23. General 1,251,039 950 1,251,989

24. General Other 45,817 (201) 45,616

25. Total General 1,296,856 749 1,297,605


27. Capitalized Software 506,974 (9,348) 497,626

28. Hydro Relicensing 54,948 (65) 54,883

29. Radio Frequency 12,263 – 12,263



32. Total Intangible Plant 597,175 (9,413) 587,762

33. Total Weighted Average Reserve 15,804,443 (34,403) 15,770,040

280



Appendix B | Table I-20 | Depreciation Expense (Total Company)

2021$ in Thousands

Table I-20

Depreciation Expense (Total Company) 2021 Test Year


1. Generation

2. Palo Verde 22,840 5 22,845

3. Hydro 57,140 (20,466) 36,674

4. Mountainview 26,502 (102) 26,400

5. Pebbly Beach 2,451 (151) 2,300

6. Peakers 12,425 2 12,427

7. Solar PV 24,676 (346) 24,330

8. Fuel Cell 2,152 (400) 1,752

9. Energy Storage 3,266 – 3,266

10. Other Production – – –

11. Total Generation 151,451 (21,457) 129,994

12. Transmission


14. Transmission Substations 211,048 (954) 210,094

15. Transmission Lines 221,924 773 222,697

16. Total Transmission 436,543 (170) 436,373

17. Distribution


19. Transmission Substations 86,543 448 86,991


21. Total Distribution 1,279,539 (168,972) 1,110,567

22. General

23. General 265,839 (733) 265,106

24. General Other – – –

25. Total General 265,839 (733) 265,106


27. Capitalized Software 264,673 (9,831) 254,842

28. Hydro Relicensing 4,036 (43) 3,993

29. Radio Frequency 468 – 468



32. Total Intangible Plant 270,337 (9,874) 260,462

33. Total Depreciation 2,403,708 (201,206) 2,202,503

281



Appendix B | Table I-21 | Other Taxes (Total Company)

2021$ in Thousands

Table I-21

Other Taxes (Total Company) 2021 Test Year


1. Ad Valorem (Property) Taxes

2. Total Ad Valorem Taxes 437,995 (3,637) 434,358

3. Payroll Taxes

4. Federal Insurance Contribution Act (FICA) 64,339 (4,139) 60,200

5. Federal Unemployment Tax Act (FUTA) 305 (20) 285

6. State Unemployment Tax Act (SUTA) 3,196 (204) 2,992

7. Total Payroll Taxes 67,840 (4,363) 63,477

8. Miscellaneous Taxes

9. ITC Amortization on CTC Property 3,923 8 3,931

10. ARAM Expense on CTC Property (449) – (449)

11. Total Miscellaneous Taxes 3,474 8 3,482

12. Total Taxes Other Than Income 509,308 (7,992) 501,316

282



Appendix B | Table I-22 | State and Federal Income Taxes (Total Company)

2021$ in Thousands

Table I-22

State and Federal Income Taxes (Total Company) 2021 Test Year


1. California Corporate Franchise Tax

2. California Corporation Franchise Tax

3. Operating Revenues 8,837,009 (784,516) 8,052,494

4. Operating Expenses 2,790,632 (510,510) 2,280,123

5. Taxes Other Than Income 509,308 (7,992) 501,316

6. Total Expenses 3,299,941 (518,502) 2,781,439

7. Income Tax Adjustments (Schedule M) 4,200,983 (226,540) 3,974,442

8. California Taxable Income 1,336,086 (39,474) 1,296,612

9. California Corporation Franchise Tax Rate 8.84% – 8.84%

10. California Corporation Franchise Tax 118,110 (3,489) 114,621

11. Total State Income Taxes 118,110 (3,489) 114,621

12. Federal Income Tax

13. Federal Income Tax

14. Operating Revenues 8,837,009 (784,516) 8,052,494

15. Operating Expenses 2,790,632 (510,510) 2,280,123

16. Taxes Other Than On Income 509,308 (7,992) 501,316

17. State Income Taxes 118,110 (3,489) 114,621

18. Less: California Tax Expense (Current Year) (118,110) 3,489 (114,621)

19. Plus: California Tax Expense (Prior Year) 102,736 (5,514) 97,222

20. Total Expenses 3,402,677 (524,016) 2,878,661

21. Income Tax Adjustments 4,024,951 (225,756) 3,799,194

22. Federal Taxable Income 1,409,382 (34,744) 1,374,638

23. Federal Income Tax Rate 21.00% – 21.00%

24. Federal Tax Expense 295,970 (7,296) 288,674

25. Deferred Taxes (Plant) 10,359 (4,689) 5,670

26. Deferred Tax Expense (AFUDC Debt) – – –

27. Deferred Tax Expense (Capitalized Interest) – – –

28. Contributions in Aid of Construction (CIAC) (33,568) 3,819 (29,749)

29. ITCC Deferred Tax Expense/(Benefit) (5,487) 198 (5,289)

30. Investment Tax Credit Amortization (5,556) – (5,556)

31. Wildfire Reserve Deferred Tax Expense/(Benefit) – – –

32. Accrued Vacation (198) – (198)

33. Total Federal Income Taxes 261,521 (7,968) 253,553

34. Total State and Federal Income Taxes 379,631 (11,457) 368,173

283

table of contents list of issue, by party, by witness 6 table i-2 | summary of operations and...

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