advice letter 4197-e and 4197-e-a subject: grid safety and … · 2 days ago · p.o. box 800 8631...

STATE OF CALIFORNIA GAVIN NEWSOM, Governor

PUBLIC UTILITIES COMMISSION

505 VAN NESS AVENUE

SAN FRANCISCO, CA 94102-3298

July 9, 2020

Advice Letter 4197-E and 4197-E-A

Gary A. Stern

Director, State Regulatory Operations

Southern California Edison Company

8631 Rush Street

Rosemead, CA 91770

SUBJECT: Grid Safety and Resiliency Program Balancing Account and Revenue

Requirement Advice Letter.

Dear Mr. Stern:

Advice Letters 4197-E and 4197-E-A are effective as of May 22, 2020.

Sincerely,

Edward Randolph

Deputy Executive Director for Energy and Climate Policy/

Director, Energy Division

P.O. Box 800 8631 Rush Street Rosemead, California 91770 (626) 302-9645 Fax (626) 302-6396

Gary A. Stern, Ph.D. Managing Director, State Regulatory Operations

April 22, 2020

ADVICE 4197-E (U 338-E)

PUBLIC UTILITIES COMMISSION OF THE STATE OF CALIFORNIA ENERGY DIVISION

SUBJECT: Establishment of the Grid Safety and Resiliency Program Balancing Account, Elimination of the Grid Safety and Resiliency Program Memorandum Account, and Implementation of the 2020 Grid Safety and Resiliency Program Revenue Requirement in Accordance with Decision 20-04-013

Southern California Edison Company (SCE) hereby submits for approval by the California Public Utilities Commission (Commission) the following changes to its tariffs. The revised tariff sheets are listed on Attachment A and are attached hereto. PURPOSE Pursuant to Ordering Paragraphs (OP) 22 and 23 of Decision (D).20-04-013, the purpose of this advice letter is to establish Preliminary Statement Part SS, the Grid Safety and Resiliency Program Balancing Account (GSRPBA), eliminate Preliminary Statement Part N.50, the Grid Safety and Resiliency Program Memorandum Account (GSRPMA), and implement the 2020 Grid Safety and Resiliency Program (GSRP) revenue requirement. BACKGROUND On September 10, 2018, SCE filed an application seeking Commission approval to record and recover the costs of its GSRP. The GSRP, which includes broader and more advanced measures than those authorized in D.19-05-020 approving SCE’s 2018 General Rate Case (GRC), is designed to address California’s increasing fire risk by further hardening the electric system and enhancing utility situational awareness and operational capabilities. As the additional measures involve costs above amounts currently authorized in rates pursuant to D.19-05-020, SCE requested that the Commission authorize a 2018-2020 GSRP capital expenditure forecast of $407 million (2018 constant $) and GSRP operations and maintenance (O&M) forecast of $175 million (2018 constant $). SCE

ADVICE 4197-E (U 338-E) - 2 - April 22, 2020

proposed that the Commission approve an interim GSRP memorandum account to track GSRP costs during the pendency of the proceeding, and a two-way GSRP balancing account to recover the costs of the program from customers upon the effective date of a decision in this proceeding. Finally, SCE also proposed a “reasonableness threshold” of 115 percent of the total GSRP capital and O&M forecast of $582 million (2018 constant $), or $670 million (2018 constant $). Under SCE’s reasonableness threshold proposal, any amounts recorded up to the $670 million figure would be deemed reasonable, while any amount of the total spend recorded in excess of that amount would be subject to a reasonableness review in a future application.1 On July 31, 2019, SCE, the Public Advocates Office, Coalition of California Utility Employees, Small Business Utility Advocates, and The Utility Reform Network (Settling Parties) filed a joint motion for approval of a settlement agreement (Settlement Agreement). The Settlement Agreement authorizes, among other things:

• 2018-2020 GSRP capital forecast of $407 million (2018 constant $); • 2018-2020 GSRP O&M forecast of $119 million (2018 constant $), which

represents a $56 million reduction to the O&M forecast proposed in SCE’s application;

• 115 percent reasonableness threshold for Wildfire Covered Conductor Program (WCCP) capital and O&M expenditures; and

• Establishment of the GSRP balancing account (GSRPBA) that allows SCE to recover the revenue requirement associated with SCE’s actual GSRP costs up to the authorized amounts, including the reasonableness threshold for covered conductor,2 and allows SCE to track the revenue requirement associated with SCE’s actual GSRP costs that exceed the authorized amounts for future reasonableness review and recovery.

On April 16, 2020, the Commission approved D.20-04-013 (GSRP Decision, or Decision) that adopts the Settlement Agreement in its entirety, and requires SCE to submit a Tier 2 advice letter within 60 days to (1) establish the GSRPBA, (2) transfer the amounts previously tracked in the GSRPMA to the GSRPBA account and close the GSRPMA; and (3) set forth the updated GSRP revenue requirement (adjusted for the Assembly Bill (AB) 1054 exclusion of certain wildfire mitigation plan-related capital expenditures from equity rate base and the final depreciation and escalation rates authorized in SCE’s 2018 GRC).3

1 As part of this reasonableness threshold, SCE proposed no further reasonableness review

be required if: (1) SCE’s GSRP spending is less than or equal to the reasonableness threshold; and (2) SCE manages the cost per circuit mile for the covered conductor program up to 115 percent of the estimated amount of $428k/mile (2018 constant $).

2 Subject to certain average unit cost metrics specified in the Settlement Agreement. 3 OPs 22 and 23 of the GSRP Decision.

ADVICE 4197-E (U 338-E) - 3 - April 22, 2020

ESTABLISHMENT OF THE GSRPBA Pursuant to the GSRP Decision, SCE is authorized to establish the GSRPBA to record the actual revenue requirement associated with 2018-2020 GSRP capital and O&M expenditures, and to recover the revenue requirement associated with the authorized expenditures (including the 115% reasonableness threshold for WCCP) from customers. Pursuant to Public Utilities Code Section 8386.3(e), the first $1.575 billion of wildfire risk mitigation capital expenditures spent on or after August 1, 2019 and included in SCE’s approved wildfire mitigation plans must be excluded from equity rate base and may be financed through a financing order pursuant to Section 851 (capital expenditures subject to AB 1054). As such, SCE proposes to establish two sub-accounts within the GSRPBA: a “GSRP Costs Not Subject to AB 1054” sub-account to track O&M costs and the capital revenue requirements for capital expenditures that are not subject to the AB 1054 exclusion from equity rate base (because they were incurred prior to August 1, 2019), and an “AB 1054” sub-account to track the capital revenue requirements that are subject to the AB 1054 exclusion from equity rate base (because they were incurred on or after August 1, 2019).

Entries in the GSRPBA SCE will record the following in the “GSRP Costs Not Subject to AB 1054” sub-account of GSRPBA each month, as detailed in Preliminary Statement SS provided in Attachment A:

• An initial transfer of the relevant recorded activity in the GSRPMA (debit); • Capital-related revenue requirements for capital expenditures that are not subject

to the AB 1054 exclusion from equity rate base (debit), including depreciation, return on rate base, property taxes, and income taxes based on recorded capital additions and rate base;

• Recorded incremental O&M costs (debit); and • Interest based on the three-month commercial paper rate.

SCE will record the following in the “GSRP Costs Subject to AB 1054” sub-account of GSRPBA each month, as detailed in Preliminary Statement SS provided in Attachment A:

• An initial transfer of the relevant recorded activity in the GSRPMA (debit); • Capital-related revenue requirements for capital expenditures that are subject to

the AB 1054 exclusion from equity rate base (debit), including actual depreciation, applicable return,4 property taxes, and income taxes based on recorded capital additions;

4 For example, if SCE is using its existing facilities to finance the AB 1054 capital

expenditures in the interim until they are securitized, the applicable return will be based on

ADVICE 4197-E (U 338-E) - 4 - April 22, 2020

• Any applicable “Financing Costs” related to the issuing and servicing of recovery bonds or the application for a financing order, to be proposed for recovery in an application for a financing order (debit);5 and

• Interest based on the three-month commercial paper rate. Pursuant to OP 22, the GSRPBA will only record costs incurred through December 31, 2020.6 SCE will transfer the 2020 year-end balance in the GSRP Costs Not Subject to AB 1054 sub-account of the GSRPBA, subject to the authorized funding level caps described below, to the distribution subaccount of the Base Revenue Requirement Balancing Account (BRRBA) for recovery from all customers. Using this approach, any difference between the revenues collected using the forecast GSRP revenue requirements included in rate levels and the actual recorded GSRP revenue requirements will be trued up in the BRRBA, because any over- or under-collections are returned to and recovered from, respectively, customers in the subsequent year.

Authorized Level of Expenditures and Average Recorded Unit Costs Pursuant to OPs 11 and 14 of the GSRP Decision, all recorded costs in excess of the level of expenditures authorized in the Settlement Agreement (and reasonableness threshold, where applicable) are subject to additional reasonableness review prior to rate recovery from customers. The following table lists the authorized 2018-2020 GSRP capital and O&M funding levels provided for in the GSRP Final Decision. Specifically, this table provides the 2018-2020 funding levels in 2018 constant dollars (as specified in the Settlement Agreement), the 2018-2020 authorized funding levels in nominal dollars, and the final 2018-2020 authorized funding levels that include the 115% reasonableness threshold for WCCP capital and O&M.

SCE’s long-term debt rate. If SCE procures a dedicated facility to finance the AB 1054 capital expenditures in the interim until they are securitized, the applicable return will be based on the financing rate of the dedicated facility.

5 See Public Utilities Code Section 850(b)(4)(E), which lists costs related to the issuing and servicing of recovery bonds or the application for a financing order, such as: servicing fees and expenses, trustee fees and expenses, legal fees and expenses, accounting fees, administrative fees, underwriting and placement fees, financial advisor fees, original issue discount, capitalized interest, rating agency fees, and any other related costs that are approved for recovery in the financing order.

6 SCE proposed to establish the Wildfire Risk Mitigation Balancing Account and Vegetation Management Balancing Account in A.19-08-013, its 2021 GRC Application. If that proceeding remains pending as of December 31, 2020, SCE will track all 2021 wildfire mitigation costs in its Wildfire Mitigation Plan Memorandum Account (WMPMA) and Fire Risk Mitigation Memorandum Account (FRMMA), including those associated with GSRP activities, until A.19-08-013 is resolved. Pursuant to OP 22, GSRPBA will only record costs incurred through December 31, 2020.

ADVICE 4197-E (U 338-E) - 5 - April 22, 2020

Table 1 GSRP Authorized Expenditures7

in thousands of dollars

In addition to the total program authorized funding levels specified above, the GSRP Final Decision sets forth individual “Average Authorized Unit Cost” metrics, whereby recorded costs in excess of those Average Authorized Unit Costs are subject to reasonableness review. The Average Authorized Unit Costs are listed in OPs 15-21 and summarized in the table below:

Table 2 GSRP Average Authorized Unit Cost

Activity Average Authorized Unit Cost

(2018 Constant) Average Authorized Unit Cost (Nominal)

1. WCCP (Capital costs per Circuit Mile)

$492,200 (includes 115% reasonableness threshold) $509,091

2. Tree Removal (O&M per Tree Removed) $2,018 $2,072

3. Current Limiting Fuses (Capital per CLF) $5,962 $6,048

4. Current Limiting Fuses (O&M per CLF) $4,441 $4,557

5. High Definition Cameras (Capital per HD Camera) $25,850 $26,187

6. Weather Station (Capital per Weather Station) $16,920 $17,249

7. Remote-Control Automatic Recloser (Capital per RAR) $94,765 $98,007

7 SCE notes that Ordering Paragraph 11 of the GSRP Final Decision incorrectly lists a “Non-

WCCP O&M” total of $113,625,000 (2018 constant $). SCE clarifies that this value should be $113,265,000, as specified on Table A-2 of the Settlement Agreement. The GSRP O&M total of $119,164,000 (2018 constant $) is correctly listed in Ordering Paragraphs 5, 6, and 22.

Authorized Expenditures2018-2020 2018-2020 Nominal w/115%

Descrpition (2018$) (Nominal$) WCCP ThresholdCapitalWildfire Covered Conductor 284,842 294,617 338,809Non-WCCP Capital 122,448 124,740 124,740Total Capital 407,290 419,357 463,549O&MWildfire Covered Conductor 5,899 6,037 6,943Non-WCCP O&M 113,265 116,144 116,144Total O&M 119,164 122,181 123,087

ADVICE 4197-E (U 338-E) - 6 - April 22, 2020

Finally, OPs 12 and 13 also clarify that SCE’s recovery of recorded amounts for Tree Removal are capped at a level no higher than 125 percent of Average Authorized Unit Cost ($2,072 per Tree Removal, as specified in line 2 of the table above), and that SCE shall not have the opportunity to recover recorded amounts for Tree Removal in excess of 22,500 trees over the 2018-2020 period. These caps on the total Authorized Level of Expenditures and Average Recorded Unit Costs are specified in Preliminary Statement SS.

TRANSFER OF GSRPMA BALANCE INTO GSRPBA AND ELIMINATION OF THE GSRPMA GSRPMA was established pursuant to D.19-01-019, and was used to track the incremental costs of SCE’s GSRP during the pendency of the proceeding. Pursuant to OP 23 of the GSRP Final Decision, SCE proposes to transfer the March 31, 2020 balance in GSRPMA to the GSRPBA. Upon approval of this advice letter, SCE will close the GSRPMA, and will record all April 1, 2020 and forward GSRP costs in the GSRPBA.8 The balance in GSRPMA as of March 31, 2020 is $57.091 million. This balance includes GSRP O&M expenditures through March 31, 2020, and the revenue requirement associated with GSRP capital expenditures recorded to Plant in Service through February 29, 2020.9 As described above, the balance in the GSRPMA that is related to capital expenditures subject to AB 1054 (i.e., the revenue requirement for capital expenditures incurred on or after August 1, 2019) will be transferred to the GSRP Costs Subject to AB 1054 sub-account of the GSRPBA. The remaining balance, which is not subject to the AB 1054 exclusion from equity rate base, will be transferred to the GSRP Costs Not Subject to AB 1054 sub-account of the GSRPBA.

IMPLEMENTATION OF 2018-2020 FORECAST GSRP REVENUE REQUIREMENT Pursuant to OP 22, SCE hereby provides the updated GSRP revenue requirement based on the authorized 2018-2020 GSRP capital and O&M funding levels provided for in the GSRP Decision and updated forecast expenditures. The updated GSRP revenue requirement reflects the various rates (e.g., depreciation, capitalization, etc.) adopted in D.19-05-020 and has been adjusted to reflect the exclusion of capital expenditures

8 Accordingly, SCE proposes that the GSRPBA have an official effective date of April 1,

2020. 9 As explained on page 1 of SCE’s monthly GSRP report, the capital-related revenue

requirement in a given month reflects capital expenditures recorded to Plant in Service in the prior month. This lag is corrected in December such that the annual capital-related revenue requirement reflects the annual capital expenditures recorded to Plant-in-Service.

ADVICE 4197-E (U 338-E) - 7 - April 22, 2020

subject to AB 1054, as described in detail below. In a future advice letter, SCE will implement the updated forecast GSRP revenue requirement approved in this instant advice letter into distribution rates.

Exclusion of Capital Expenditures Subject to AB 1054 From the 2018-2020 GSRP Revenue Requirement Pursuant to Public Utilities Code Section 8386.3(e), the first $1.575 billion of wildfire risk mitigation capital expenditures included in SCE’s approved wildfire mitigation plans must be excluded from equity rate base and may be financed through a financing order pursuant to Section 851 (capital expenditures subject to AB 1054). Accordingly, and consistent with the cost recovery proposed in Tracks 1 and 2 of A.19-08-013, SCE’s 2021 GRC, SCE has excluded from its 2018-2020 GSRP revenue requirement all capital expenditures incurred on or after August 1, 2019. As shown in Table 1 above, the GSRP Decision authorizes $463.549 million in 2018-2020 GSRP capital expenditures (nominal $, including reasonableness threshold for WCCP). As of July 31, 2019, SCE had spent $171.838 million in direct capital expenditures, which is less than the capital expenditures authorized in the GSRP Decision. As such, that $171.838 million in direct capital expenditures is considered per se reasonable by the GSRP Decision and thus included in the rate base used to determine the 2018-2020 GSRP revenue requirement. The remaining $291.711 million that is also considered per se reasonable by the GSRP Decision has been, or will be, spent after August 1, and is thus subject to the AB 1054 exclusion from equity rate base. As such, that $291.711 million in direct capital expenditures is not included in SCE’s 2018-2020 GSRP revenue requirement, and will instead be recovered through a separate future application for a financing order as required by Public Utilities Code Section 8386(e).

Determination and Implementation of SCE’s 2018-2020 GSRP Revenue Requirement SCE’s 2018-2020 GSRP Revenue Requirement includes the following elements:

• 2019 recorded year-end balance (excluding the revenue requirement associated with capital expenditures subject to the AB 1054 exclusion) in the GSRPMA;

• Forecast of the 2020 GSRP revenue requirement, including: o Forecast of 2020 capital revenue requirement (depreciation, taxes, and

return) for the $172 million of direct capital expenditures that are not subject to the AB 1054 exclusion; and

o Forecast of 2020 O&M expenditures, subject to the authorized funding level caps shown in Table 1 (nominal $).

ADVICE 4197-E (U 338-E) - 8 - April 22, 2020

Table 3 below sets forth the 2018-2020 GSRP Revenue Requirement:

Table 3 2018-2020 GSRP Revenue Requirement

in Thousands of Dollars

SCE will implement $158.641 million revenue requirement, which includes Franchise Fees and Uncollectibles, in distribution rates as soon as practicable upon receiving Energy Division approval of this advice letter. The actual 2018-2020 revenue requirement will record in the GSRPBA and be reviewed in SCE’s 2020 Energy Resource Recovery Account (ERRA) Review proceeding. TIER DESIGNATION Pursuant to General Order (GO) 96-B, Energy Industry Rule 5.2, this advice letter is submitted with a Tier 2 designation. EFFECTIVE DATE SCE requests that this advice letter become effective May 22, 2020, which is 30 days from the date submitted. NOTICE Anyone wishing to protest this advice letter may do so by letter via U.S. Mail, facsimile, or electronically, any of which must be received no later than 20 days after the date of this advice letter. Protests should be submitted to:

CPUC, Energy Division Attention: Tariff Unit 505 Van Ness Avenue, 4th Floor San Francisco, California 94102 Facsimile: (415) 703-2200 E-mail: [email protected]

Copies of protests should also be mailed to the attention of the Director, Energy Division, Room 4004, at the address shown above.

Total Grid Resiliency | Thousands of Nominal DollarsLine Description 2018 2019 2020 Total

1 O&M – 33,917 82,228 $116,1452 Franchise Fees & Uncollectibles 20 522 1,243 $1,7853 Depreciation 1,123 5,559 8,872 $15,5544 Taxes (1,171) (2,073) 5,010 $1,7675 Return 1,785 8,490 13,115 $23,3896 Total Revenue Requirement $1,756 $46,416 $110,468 $158,641

ADVICE 4197-E (U 338-E) - 9 - April 22, 2020

The protest and all other correspondence regarding this advice letter should also be sent by letter and transmitted via facsimile or electronically to the attention of:

Gary A. Stern, Ph.D. Managing Director, State Regulatory Operations Southern California Edison Company 8631 Rush Street Rosemead, California 91770

Telephone: (626) 302-9645 Facsimile: (626) 302-6396 E-mail: [email protected] Laura Genao Managing Director, State Regulatory Affairs c/o Karyn Gansecki Southern California Edison Company 601 Van Ness Avenue, Suite 2030 San Francisco, California 94102 Facsimile: (415) 929-5544 E-mail: [email protected]

There are no restrictions on who may submit a protest, but the protest shall set forth specifically the grounds upon which it is based and must be received by the deadline shown above. In accordance with General Rule 4 of GO 96-B, SCE is serving copies of this advice letter to the interested parties shown on the attached GO 96-B and A.18-09-002 service lists. Address change requests to the GO 96-B service list should be directed by electronic mail to [email protected] or at (626) 302-3719. For changes to all other service lists, please contact the CPUC’s Process Office at (415) 703-2021 or by electronic mail at [email protected]. Further, in accordance with Public Utilities Code Section 491, notice to the public is hereby given by submitting and keeping the advice letter at SCE’s corporate headquarters. To view other SCE advice letters submitted with the CPUC, log on to SCE’s web site at https://www.sce.com/wps/portal/home/regulatory/advice-letters.

ADVICE 4197-E (U 338-E) - 10 - April 22, 2020

For questions, please contact Desiree Wong at (626)302-1421 or by electronic mail at [email protected].

Southern California Edison Company

/s/ Gary A. Stern /s/ Gary A. Stern Gary A. Stern, Ph.D.

GAS:dw:cm

ADVICE LETTER S U M M A R YENERGY UTILITY

Company name/CPUC Utility No.:

Utility type:Phone #:

EXPLANATION OF UTILITY TYPE

ELC GAS

PLC HEAT

MUST BE COMPLETED BY UTILITY (Attach additional pages as needed)

Advice Letter (AL) #:

WATERE-mail: E-mail Disposition Notice to:

Contact Person:

ELC = ElectricPLC = Pipeline

GAS = GasHEAT = Heat WATER = Water

(Date Submitted / Received Stamp by CPUC)

Subject of AL:

Tier Designation:

Keywords (choose from CPUC listing):AL Type: Monthly Quarterly Annual One-Time Other:If AL submitted in compliance with a Commission order, indicate relevant Decision/Resolution #:

Does AL replace a withdrawn or rejected AL? If so, identify the prior AL:

Summarize differences between the AL and the prior withdrawn or rejected AL:

Confidential treatment requested? Yes NoIf yes, specification of confidential information:Confidential information will be made available to appropriate parties who execute a nondisclosure agreement. Name and contact information to request nondisclosure agreement/access to confidential information:

Resolution required? Yes No

Requested effective date: No. of tariff sheets:

Estimated system annual revenue effect (%):

Estimated system average rate effect (%):

When rates are affected by AL, include attachment in AL showing average rate effects on customer classes (residential, small commercial, large C/I, agricultural, lighting).

Tariff schedules affected:

Service affected and changes proposed1:

Pending advice letters that revise the same tariff sheets:

1Discuss in AL if more space is needed.

CPUC, Energy DivisionAttention: Tariff Unit505 Van Ness AvenueSan Francisco, CA 94102 Email: [email protected]

Protests and all other correspondence regarding this AL are due no later than 20 days after the date of this submittal, unless otherwise authorized by the Commission, and shall be sent to:

Name:Title:Utility Name:Address:City:State:Telephone (xxx) xxx-xxxx:Facsimile (xxx) xxx-xxxx:Email:

Name:Title:Utility Name:Address:City:State:Telephone (xxx) xxx-xxxx: Facsimile (xxx) xxx-xxxx:Email:

Zip:

Zip:

mailto:EDTariffUnit%40cpuc.ca.gov?subject=

ENERGY Advice Letter Keywords

Affiliate Direct Access Preliminary StatementAgreements Disconnect Service ProcurementAgriculture ECAC / Energy Cost Adjustment Qualifying FacilityAvoided Cost EOR / Enhanced Oil Recovery RebatesBalancing Account Energy Charge RefundsBaseline Energy Efficiency ReliabilityBilingual Establish Service Re-MAT/Bio-MATBillings Expand Service Area Revenue AllocationBioenergy Forms Rule 21Brokerage Fees Franchise Fee / User Tax RulesCARE G.O. 131-D Section 851CPUC Reimbursement Fee GRC / General Rate Case Self GenerationCapacity Hazardous Waste Service Area MapCogeneration Increase Rates Service OutageCompliance Interruptible Service SolarConditions of Service Interutility Transportation Standby ServiceConnection LIEE / Low-Income Energy Efficiency StorageConservation LIRA / Low-Income Ratepayer Assistance Street LightsConsolidate Tariffs Late Payment Charge SurchargesContracts Line Extensions TariffsCore Memorandum Account TaxesCredit Metered Energy Efficiency Text ChangesCurtailable Service Metering TransformerCustomer Charge Mobile Home Parks Transition CostCustomer Owned Generation Name Change Transmission LinesDecrease Rates Non-Core Transportation ElectrificationDemand Charge Non-firm Service Contracts Transportation RatesDemand Side Fund Nuclear UndergroundingDemand Side Management Oil Pipelines Voltage DiscountDemand Side Response PBR / Performance Based Ratemaking Wind PowerDeposits Portfolio Withdrawal of ServiceDepreciation Power Lines

Public Utilities Commission 4197-E Attachment A

Cal. P.U.C. Sheet No. Title of Sheet

Cancelling Cal. P.U.C. Sheet No.

1

Revised 68989-E Preliminary Statements N Revised 68173-ERevised 68990-E Preliminary Statements N Revised 65917-E Original 68991-E Preliminary Statements SS Original 68992-E Preliminary Statements SS Original 68993-E Preliminary Statements SS Original 68994-E Preliminary Statements SS Original 68995-E Preliminary Statements SS Revised 68996-E Table of Contents Revised 68768-ERevised 68997-E Table of Contents Revised 68486-E

Southern California Edison Revised Cal. PUC Sheet No. 68989-E Rosemead, California (U 338-E) Cancelling Revised Cal. PUC Sheet No. 68173-E

PRELIMINARY STATEMENT Sheet 3

(Continued)

(Continued) (To be inserted by utility) Issued by (To be inserted by Cal. PUC) Advice 4197-E Carla Peterman Date Submitted Apr 22, 2020 Decision 20-04-013 Senior Vice President Effective May 22, 2020 3H8 Resolution

N. MEMORANDUM ACCOUNTS (Continued) 2. Definitions. (Continued) d. Specified Project (Continued) Section Interest Bearing No. Specified Project Memorandum Account* (34) Community Choice Audit Memorandum Account Yes (35) Aliso Canyon Energy Savings Assistance Program Memorandum Account Yes (36) Wireless Fidelity Costs Memorandum Account Yes (37) Residential Service Disconnection Memorandum Account (RSDMA) Yes (38) Tax Accounting Memorandum Account (TAMA) Yes (39) Renewables Portfolio Standard Costs Memorandum Account Yes (40) Greenhouse Gas (GHG) Customer Outreach and Education Yes Memorandum Account (GHGCO&EMA) (41) BioMass Memorandum Account Yes (42) Department of Energy Litigation Memorandum Account Yes (43) Bio RAM Memoramdum Account (BioRAMMA) Yes (44) Project Development Division Memorandum Account (PDDMA) Yes (45) Fire Risk Mitigation Memorandum Account Yes (46) Mohave SO2 Allowance Revolving Fund Memorandum Account (MSARFMA) Yes (47) Energy Division Director’s Peer Review Group Memorandum Account Yes (PRGMA) (48) Greenhouse Gas (GHG) Administrative Costs Memorandum Yes Account (GHGACMA) (49) Net Energy Metering Automation (NEM-A) Billing Automation Costs Memorandum Account (NEMABACMA) Yes (50) Not in Use (51) Long-Term Procurement Plan Technical Assistance Yes Memorandum Account (LTAMA) (52) Wildfire Expense Memorandum Account (WEMA) Yes (53) Fire Hazard Prevention Memorandum Account (FHPMA) Yes (54) Service Center Modernization Projects Memorandum Account (SCMPMA) Yes (55) San Onofre Nuclear Generating Station Memorandum Account (SONGSMA) Yes (56) Customer Service Re-Platform Memorandum Account (CSRPMA) Yes (57) Energy Matinee Tariff Program Pilot Memorandum Account (EMTPPMA) Yes (58) Green Tariff Shared Renewables Administrative Costs Yes Memorandum Account (59) Green Tariff Marketing, Education & Outreach Memorandum Account Yes (60) Enhanced Community Renewables Marketing, Education & Outreach Yes Memorandum Account (61) Residential Rate Implementation Memorandum Account (RRIMA) Yes (62) Rule 21 Cost Envelope Option Memorandum Account (CEOMA) Yes (63) Tax Accounting Memorandum Account 2018 (TAMA 2018) Yes (64) California Consumer Privacy Act Memorandum Account (CCPAMA) Yes (65) Distributed Generation Statistics Contractor Memorandum Account (DGSCMA) Yes * Interest shall accrue monthly to interest-bearing Memorandum Accounts by applying the Interest Rate

to the average of the beginning and ending balance.

(T)



(Continued)

(Continued) (To be inserted by utility) Issued by (To be inserted by Cal. PUC) Advice 4197-E Carla Peterman Date Submitted Apr 22, 2020 Decision 20-04-013 Senior Vice President Effective May 22, 2020 61C9 Resolution

N. MEMORANDUM ACCOUNTS (Continued) 50. Not in Use

(D)

Southern California Edison Original Cal. PUC Sheet No. 68991-E Rosemead, California (U 338-E) Cancelling Cal. PUC Sheet No.



SS. Grid Safety and Resiliency Program Balancing Account (GSRPBA)

1. Purpose

The purpose of the Grid Safety and Resiliency Program Balancing Account (GSRPBA) is to record the actual Operations and Maintenance (O&M) expenses and capital-related revenue requirements (i.e. depreciation, return on rate base, and applicable taxes) associated with the approved Grid Safety and Resiliency Program. Pursuant to D.20-04-013, SCE is authorized to recover the revenue requirement associated with the authorized expenditures, including the 115% reasonableness threshold for the Wildfire Covered Conductor Program (WCCP), as outlined herein (Authorized Level of Expenditures). Recorded expenditures above the Authorized Funding Level are subject to additional reasonableness review prior to recovery from customers.

Pursuant to Public Utilities Code Section 8386.3(e), the first $1.575 billion of wildfire risk mitigation capital expenditures spent after August 1, 2019 and included in SCE’s approved wildfire mitigation plans must be excluded from equity rate base and financed through a financing order pursuant to Section 851 (capital expenditures subject to AB 1054). As such, the GSRPBA contains two sub-accounts: a “GSRP Costs Not Subject to AB 1054” sub-account to track O&M costs and the capital revenue requirements for capital expenditures that are not subject to the AB 1054 exclusion from equity rate base, and an “GSRP Costs Subject to AB 1054” sub-account to track the capital revenue requirements that are subject to the AB 1054 exclusion from equity rate base.

Only incremental costs above and beyond those that are authorized for recovery in SCE’s GRC and other authorized wildfire risk mitigation ratemaking accounts will be recorded in the GSRPBA. The GSRPBA will only record costs through December 31, 2020.



(Continued)

(Continued) (To be inserted by utility) Issued by (To be inserted by Cal. PUC) Advice 4197-E Carla Peterman Date Submitted Apr 22, 2020 Decision 20-04-013 Senior Vice President Effective May 22, 2020 2S19 Resolution

SS. Grid Safety and Resiliency Program Balancing Account (GSRPBA) (Continued)

2. Definitions

a) The Authorized Level of Expenditures pursuant to D.20-04-013, including the 115% reasonableness threshold for WCCP capital and O&M, is as follows:

SCE’s Authorized Level of Expenditures

(in thousands, excludes overheads and FF&U)

Pursuant to Ordering Paragraphs 11 and 14 of D.20-04-013, all recorded costs in excess of the Authorized Level of Expenditures are subject to additional reasonableness review prior to rate recovery from customers.



(Continued)

(Continued) (To be inserted by utility) Issued by (To be inserted by Cal. PUC) Advice 4197-E Carla Peterman Date Submitted Apr 22, 2020 Decision 20-04-013 Senior Vice President Effective May 22, 2020 3S19 Resolution


2. Definitions (Continued)

b) The Average Authorized Unit Costs set forth in D.20-04-013 are as follows:

SCE’s Average Authorized Unit Costs

(excludes overheads and FF&U)

Activity Average Authorized Unit Cost (2018 Constant)

Average Authorized Unit Cost (Nominal)

1. WCCP (Capital costs per Circuit Mile)

$492,200 (includes 115% reasonableness threshold) $509,091

2. Tree Removal (O&M per Tree Removed) $2,018 $2,072

3. Current Limiting Fuses (Capital per CLF) $5,962 $6,048

4. Current Limiting Fuses (O&M per CLF) $4,441 $4,557

5. High Definition Cameras (Capital per HD Camera) $25,850 $26,187

6. Weather Station (Capital per Weather Station)

$16,920 $17,249

7. Remote-Control Automatic Recloser (Capital per RAR)

$94,765 $98,007



(Continued)



2. Definitions (Continued)

Pursuant to Ordering Paragraphs 15-21 of D.20-04-013, all recorded costs in excess of the Average Authorized Unit Costs are subject to reasonableness review prior to rate recovery from customers.

Additionally, pursuant to Ordering Paragraphs 12 and 13 of D.20-04-013, SCE’s recovery of recorded amounts for Tree Removal are capped at a level no higher than 125 percent of the Average Authorized Unit Cost of $2,072 per Tree Removal, and SCE shall not have the opportunity to recover recorded amounts for Tree Removal in excess of 22,500 trees over the 2018-2020 period.

c) Interest Rate

The Interest Rate shall be one-twelfth of the Federal Reserve three-

month Commercial Paper Rate – Non-Financial, from Federal Reserve Statistical Release H.15 (expressed as an annual rate). If in any month a non-financial Rate is not published, SCE shall use the Federal Reserve three-month Commercial Paper Rate – Financial.

3. Operation of the GSRPBA

On a monthly basis, entries to the GSRPBA shall be determined as follows:

a) GSRP Costs Not Subject to AB 1054 Subaccount

i. A debit entry to reflect the one-time transfer of the balance in the Grid Safety and Resiliency Program Memorandum Account (GSRPMA) that is not subject to the AB 1054 exclusion from equity rate base to the GSRPBA;

ii. A debit entry equal to the capital-related revenue requirements for capital expenditures that are not subject to the AB 1054 exclusion from equity rate base, including depreciation, return on rate base, property taxes, and income taxes based on recorded capital additions and rate base; and

iii. A debt entry equal to the recorded incremental O&M expenses.



(Continued)



Operation of the GSRPBA (Continued)

b) GSRP Costs Subject to AB 1054 Subaccount

i. A debit entry to reflect the one-time transfer of the balance in the GSRPMA that is subject to AB 1054 exclusion from equity rate base to the GSRPBA;

ii. A debit entry equal to the capital-related revenue requirements for

capital expenditures that are subject to the AB 1054 exclusion from equity rate base, including depreciation, applicable return, property taxes, and income taxes based on recorded capital additions; and

iii. A debit entry equal to the applicable financing costs related to

issuing and servicing of recovery bonds or the application for a financing order.

When recording the costs in the GSRPBA, SCE will include provisions for overhead loadings as applicable based on authorized GRC rates. However, Pensions, Post-Employment Benefits Other Than Pensions (PBOPs), and medical, dental and vision labor loadings will not be recorded in the GSRPBA since these costs are recovered through other stand-alone balancing accounts. Interest shall accrue monthly to each sub-account of the GSRPBA by applying the Interest Rate to the average of the beginning-of-month and end-of-month balance in the sub-account.

3. Disposition and Review Procedures

The December 31, 2020 balance in the GSRP Costs Not Subject to AB 1054 subaccount shall be transferred to the distribution subaccount of the BRRBA, subject to the authorized funding level caps described in Section 2a, above. SCE is authorized to fully recover in distribution rates the revenue requirements associated with the GSRP up to the authorized funding levels.

Pursuant to D.20-04-013, GSRP costs incurred up to the authorized level will be considered per se reasonable, and GSRP costs incurred in excess of the authorized level will be reviewed for reasonableness in Track 3 of A.19-08-013, SCE’s 2021 GRC, prior to rate recovery from customers. The entries recorded in the GSRPBA will be reviewed in SCE’s annual ERRA Review proceeding to ensure the entries are properly recorded and consistent with Commission decisions


TABLE OF CONTENTS Sheet 1


Cal. P.U.C. Sheet No.

TITLE PAGE ............................................................................................................................. 11431-E TABLE OF CONTENTS - RATE SCHEDULES .... 68996-68500-68997-68769-68770-68771-68771-E ........................................................................................................... 68773-68014-68774-E TABLE OF CONTENTS - LIST OF CONTRACTS AND DEVIATIONS ................................... 68779-E TABLE OF CONTENTS - RULES ................................................................................. 68373-64043-E TABLE OF CONTENTS-INDEX OF COMMUNITIES, MAPS, BOUNDARY DESCRIPTIONS 62213-E TABLE OF CONTENTS - SAMPLE FORMS.. .................. 62213-68473-61576-67878-67879-61631-E

........................................................................................................... 67880-67881-63296-E

PRELIMINARY STATEMENT:

A. Territory Served ......................................................................................................... 22909-E B. Description of Service ................................................................................................ 22909-E C. Procedure to Obtain Service ..................................................................................... 22909-E D. Establishment of Credit and Deposits ....................................................................... 22909-E E. General .......................................................................... 45178-45179-45180-53818-45182-E F. Symbols ..................................................................................................................... 45182-E G. Gross Revenue Sharing Mechanism ....... 26584-26585-26586-26587-27195-27196-54092-E

.................................................................................................. 51717-53819-27200-27201-E H. Baseline Service ........................................................... 52027-52028-52029-52030-52031-E I. Charge Ready Program Balancing Account ........................................ 68156-68157-68158-E J. Pole Loading and Deteriorated Pole Program Balancing Account ....... 68384-67495-68385-E ......................................................................................................................... 68386-67498-E K. Nuclear Decommissioning Adjustment Mechanism ........................................ 36582-57779-E L. Purchase Agreement Administrative Costs Balancing Account ........... 55207-51922-55208-E M. Income Tax Component of Contributions ....................................................... 58419-58420-E N. Memorandum Accounts .... 21344-67638-68989-58221-49492-61165-61166-61167-53821-E

........ 50418-42841-61168-64869-64870-44950-44951-44952-44953-42849-42850-42851-E ........ 65677-65678-55623-61171-42856-61172-61173-52033-50419-55048-61174-42863-E ........ 42864-67639-67640-51235-45920-51236-61175-50209-42872-42873-50421-46539-E ........ 42876-42877-42878-42879-42880-42881-42882-54534-53371-56253-44959-42887-E ........ 53321-53322-61176-68990-52552-49928-56235-56236-56237-55144-55145-44029-E

........ 53016-57156-57157-51163-51164-51165-51166-67414-51168-51169-51170-51171-E ................................ 51244-55806-56393-56394-56395-56396-56397-56398-56399-58978E O. California Alternate Rates for Energy (CARE) Adjustment Clause ................. 34705-41902-E .................................................................................................. 36472-38847-56788-68625-E P. Tree Mortality Non-Bypassable Charge Balancing Account………...65929-65930-65931-E

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TABLE OF CONTENTS Sheet 3

(Continued)


Cal. P.U.C. Sheet No.

PRELIMINARY STATEMENT: (Continued) RR. New System Generation Balancing Account ................................ 68389-57976-64244-64245-E SS. Grid Safety and Resiliency Program Balancing Account(GSRPBA))…….68991-68992-68993-E ……………………………………………………………………………………………68994-68995-E TT. Not In Use .................................................................................................................................. -E UU. Not In Use .................................................................................................................................. -E VV. Medical Programs Balancing Account ....................................................... 60662-57978-44979-E WW. Portfolio Allocation Balancing Account…………….65241-65242-67029-68390-65245-67030-E …………………………………………………………………………………………65247-65248-65249-E XX. Low Carbon Fuel Standard Revenue Balancing Account .................................... 56447-56448-E YY. Base Revenue Requirement Balancing Account .......................... 68391-65251-54112-51724-E .................................... 65252-65253-65254-65255-66067-68159-68160-57984-58088-57986-E ZZ. Energy Resource Recovery Account .......... 65259-65260-65261-65262-66628-65264-65265-E ................................................................................. 68600-68072-68484-55221-56259-55223-E AAA. Post Test Year Ratemaking Mechanism. ................................................ 57988-60665-57990-E BBB. Not In Use ................................................................................................................................ -E CCC. Cost of Capital Mechanism ...................................................................... 68392-68393-62453-E DDD. 2010-2012 On Bill Financing Balancing Account .......................................................... 55859-E EEE Not in Use ................................................................................................................................ -E FFF Electric Program Investment Charge Balancing Account-California Energy Commission .......... ............................................................................................................................ 50176-50177-E GGG Electric Program Investment Charge Balancing Account-Southern California Edison ............... ............................................................................................................................ 50178-50179-E HHH Electric Program Investment Charge Balancing Account-California Public Utilities Commission ....................................................................................................................................... 50180-E III New Solar Homes Partnership(NSHP) Program Balancing Account (NSHPPBA)……..59581-E JJJ Aliso Canyon Demand Response Program Balancing Account (ACDRPBA)…..59847-59848-E ……………………………………………………………………………………...…...59849-59850-E RRR Integrated Distributed Energy Resources Shareholder Incentive Award Balancing Account (iDERSIABA)……………………………………………………………………………...……61284-E LLL Integrated Distributed Energy Resources Contract Costs Balancing Account (iDERCCBA)…… ……………………………………………………………………………………….………….61285-E MMM Distributed Resources Plan Demonstration Balancing Account (DRPDBA)……61982-61983-E NNN Transportation Electrification Portfolio Balancing Account (TEPBA)…….64055-64056-64057-E ………………………………………………………………………………………….64058-64059-E OOO Aliso Canyon Energy Storage Balancing Account (ACESBA)…………………....64073-64074-E PPP Disadvantaged Communities-Green Tariff Balancing Account (DACGTBA)……64152-64153-E VVV Community Solar Green Tariff Balancing Account (CSGTBA)……………………64154-64155-E WWW Disadvantaged Communities - Single-family Solar Homes Balancing Account (DACSASHBA) …………………………………………………………………………………………..64733-64734-E XXX Statewide Energy Efficiency Balancing Account (SWEEBA)……………………………..68438-E ZZZ Net Energy Metering Measurement and Evaluation Balancing Account (NEMMEBA)…65128-E

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advice letter 4197-e and 4197-e-a subject: grid safety and … · 2 days ago · p.o. box 800 8631...

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