Details for: 3576-E-A (Part 1 of 1).pdf


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Russell G. Worden
Managing Director, State Regulatory Operations

October 5, 2017
ADVICE 3576-E-A
(U 338-E)
PUBLIC UTILITIES COMMISSION OF THE STATE OF CALIFORNIA
ENERGY DIVISION
Supplement to Advice 3576-E, Continuation of the Mobilehome
Park Utility Upgrade Program Pursuant to Decision 14-03-021

SUBJECT:

In compliance with California Public Utilities Commission (Commission or CPUC)
Resolution E-4878 Ordering Paragraph (OP) 9, Southern California Edison Company
(SCE) hereby submits for filing the following changes to its tariffs. The revised tariff
sheets are listed on Attachment A and are attached hereto.
PURPOSE
In compliance with OP 9 of Resolution E-4878, the purpose of this supplemental advice
letter is to make changes to the tariffs originally submitted in Advice 3576-E necessary
to comply with Resolution E-4878. Specifically, SCE is revising its Preliminary
Statement Part MM, Mobilehome Park Master Meter Balancing Account (MMMBA) to:
(1) specify that the balancing account will remain open until all MHP conversion costs
and associated revenue requirements are included in its General Rate Case (GRC);
and (2) clarify how SCE will record the Mobilehome Park Utility Upgrade Program (MHP
Program) costs. In addition, SCE is revising its Rule 27, Mobilehome Park Utility
Upgrade Program, to reflect the continuation of the MHP Program through the earlier
date of December 31, 2019, or the issuance of a Commission decision on the
applications to continue of the MHP Program.
This advice filing supplements in part the original Advice 3576-E, but except as
described herein, Advice 3576-E remains unchanged.
BACKGROUND
Pursuant to D.14-03-021, the MHP Program was scheduled to conclude on December
31, 2017. SCE filed Advice 3576-E on March 17, 2017, pursuant to OP 13 of
D.14-03-021, to request approval to continue the MHP Program for an additional six
years (2018-2023) and the conversion of an additional 20 percent of MHP spaces. The
other utilities participating in the MHP Program also filed advice letters seeking to

P.O. Box 800

8631 Rush Street

Rosemead, California 91770

(626) 302-4177

Fax (626) 302-6396





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ADVICE 3576-E-A (U 338-E) -2- October 5, 2017 continue their respective programs for varying lengths of time, and San Diego Gas & Electric Company (SDG&E) and Southern California Gas Company (SoCalGas) concurrently filed applications to seek major modifications of their respective MHP programs. On June 21, 2017, The Utility Reform Network (TURN) filed an amended protest recommending the Commission reject SCE’s and the participating utilities’ advice letters with prejudice and require the IOUs to submit formal applications. On September 29, 2017, the Commission issued Resolution E-4878. With the approval of Resolution E-4878, SCE is allowed to continue its current MHP Program. SCE can continue with the completion of all Category 1 MHP conversions and work on Category 2 and Category 3 MHPs until December 31, 2019 or the issuance of a Commission decision on the MHP Program, whichever is earlier.1 Pursuant to Resolution E-4878, SCE will not exceed the 20 percent of spaces proposed to be converted by SCE in Advice 3576-E during this timeframe. Moreover, consistent with OPs 7 and 8, SCE will not begin construction of a MHP project if the projected completion schedule, barring any unknown conditions, before the start of construction indicates that the conversion project might not be able to be completed by October 31, 2019. Any project once initiated however, will be completed unless a situation arises under which an MHP owner fails to comply with the conditions of its agreement with SCE.2 The Commission also affirmed that the utilities continue to be authorized to record actual program costs in a balancing account and to recover prudently incurred costs in the first year following cut over service and clarified the timing of the reasonableness review of costs.3 Proposed Tariff Changes SCE is modifying its MMMBA to further clarify that (1) the MMMBA will remain open until all MHP conversion costs and associated revenue requirements are included in its GRC and; (2) revenue requirements related to the MHP program costs will continue to be recorded in the MMMBA after December 31, 2019 for MHP conversions that commenced prior to December 31, 2019. SCE is also modifying its Rule 27 to remove the original reference to the three-year pilot program and 10 percent of MHP spaces and to replace with references consistent with the extension of the MHP Program approved in Resolution E-4878. Specifically, Rule 1 2 3 Resolution E-4878, OP 7. In Finding 19 of Resolution E-4878, the Commission stated the utilities may continue their MHP Programs until the “earlier of a Commission Decision on SoCalGas and SDG&E’s applications or December 31, 2019”; however, SCE believes that the ordering paragraph is controlling, particularly because SoCalGas and SDGE’s application decisions would not be binding on the other utilities. Conditions of agreement with SCE are contained within SCE’s Mobilehome Park Utility Upgrade Program Agreement, Form 14-952 as well as Rule 27. Resolution E-4878, Finding 4.
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ADVICE 3576-E-A (U 338-E) -3- October 5, 2017 27 will now reflect that the MHP Program may convert up to an additional 20 percent of MHP spaces and will conclude the earlier of either December 31, 2019, or the date issuance of a Commission decision for the continuation, expansion, or modification of the Program beyond December 31, 2019. In addition, Rule 27 is modified to include the condition that SCE will not begin construction of an MHP project if at the start of the construction facts indicate the conversion project will not be completed by October 31, 2019. TIER DESIGNATION Pursuant to OP 9 of Resolution E-4878, this Advice Letter is submitted with a Tier 1 designation. EFFECTIVE DATE This advice filing will become effective the same day filed, October 5, 2017. NOTICE Anyone wishing to protest this advice filing 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 filing. Protests should be submitted to: CPUC, Energy Division Attention: Tariff Unit 505 Van Ness Avenue San Francisco, California 94102 E-mail: EDTariffUnit@cpuc.ca.gov Copies should also be mailed to the attention of the Director, Energy Division, Room 4004 (same address above). In addition, protests and all other correspondence regarding this advice letter should also be sent by letter and transmitted via facsimile or electronically to the attention of: Russell G. Worden Managing Director, State Regulatory Operations Southern California Edison Company 8631 Rush Street Rosemead, California 91770 Telephone: (626) 302-4177 Facsimile: (626) 302-6396 E-mail: AdviceTariffManager@sce.com
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ADVICE 3576-E-A (U 338-E) -4- October 5, 2017 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: Karyn.Gansecki@sce.com There are no restrictions on who may file 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 General Order (GO) 96-B, SCE is serving copies of this advice filing to the interested parties shown on the attached GO 96-B and R.11-02-018 service lists. Address change requests to the GO 96-B service list should be directed by electronic mail to AdviceTariffManager@sce.com or at (626) 302-3719. For changes to all other service lists, please contact the Commission’s Process Office at (415) 703-2021 or by electronic mail at Process_Office@cpuc.ca.gov. Further, in accordance with Public Utilities Code Section 491, notice to the public is hereby given by filing and keeping the advice filing at SCE’s corporate headquarters. To view other SCE advice letters filed with the Commission, log on to SCE’s web site at https://www.sce.com/wps/portal/home/regulatory/advice-letters. For questions, please contact Darrah Morgan at (626) 302-2086 or by electronic mail at Darrah.Morgan@sce.com. Southern California Edison Company /s/ Russell G. Worden Russell G. Worden RGW:dm:cm Enclosures
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CALIFORNIA PUBLIC UTILITIES COMMISSION ADVICE LETTER FILING SUMMARY ENERGY UTILITY MUST BE COMPLETED BY UTILITY (Attach additional pages as needed) Company name/CPUC Utility No.: Southern California Edison Company (U 338-E) Utility type: Contact Person: Darrah Morgan  ELC  GAS  PLC  HEAT Phone #: (626) 302-2086  WATER E-mail: Darrah.Morgan@sce.com E-mail Disposition Notice to: AdviceTariffManager@sce.com EXPLANATION OF UTILITY TYPE ELC = Electric PLC = Pipeline GAS = Gas HEAT = Heat Advice Letter (AL) #: Subject of AL: (Date Filed/ Received Stamp by CPUC) WATER = Water 3576-E-A Tier Designation: 1 Supplemental to Advice 3576-E, Continuation of the Mobilehome Park Utility Upgrade Program Pursuant to Decision 14-03-021 Keywords (choose from CPUC listing): Compliance AL filing type:  Monthly  Quarterly  Annual  One-Time  Other If AL filed in compliance with a Commission order, indicate relevant Decision/Resolution #: Decision 14-03-021 and Resolution E-4878 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  No If 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: 10/5/17 No. of tariff sheets: -3- 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: See Attachment A Service affected and changes proposed1: Pending advice letters that revise the same tariff sheets: 1 Discuss in AL if more space is needed. None
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Protests and all other correspondence regarding this AL are due no later than 20 days after the date of this filing, unless otherwise authorized by the Commission, and shall be sent to: CPUC, Energy Division Attention: Tariff Unit 505 Van Ness Avenue San Francisco, California 94102 E-mail: EDTariffUnit@cpuc.ca.gov Russell G. Worden Managing Director, State Regulatory Operations Southern California Edison Company 8631 Rush Street Rosemead, California 91770 Telephone: (626) 302-4177 Facsimile: (626) 302-6396 E-mail: AdviceTariffManager@sce.com 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: Karyn.Gansecki@sce.com
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Public Utilities Commission 3576-E-A Cal. P.U.C. Sheet No. Title of Sheet Attachment A Cancelling Cal. P.U.C. Sheet No. Revised 61364-E Revised 61365-E Preliminary Statement Part MM Preliminary Statement Part MM Revised 55624-E Original 55094-E Revised 61366-E Rule 27 Original 55237-E 1
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Southern California Edison Rosemead, California (U 338-E) Cancelling Revised Revised PRELIMINARY STATEMENT Cal. PUC Sheet No. Cal. PUC Sheet No. 61364-E 55624-E Sheet 1 MM. Mobilehome Park Master Meter Balancing Account (MMMBA) 1. Purpose The purpose of the Mobilehome Park Master Meter Balancing Account (MMMBA) is to record actual incremental incurred costs of implementing the voluntary program to convert the electric master-meter/submeter service to direct service at Mobilehome Parks (MHP) and manufactured housing communities, pursuant to Decision (D.) 14-03-021. The costs associated with the entries in the MMMBA shall include incremental incurred expenses for both “to the meter” and “beyond the meter” capitalized costs and ongoing incremental Operation and Maintenance (O&M) expenses. Actual construction costs for each MHP conversion shall be entered into a balancing account and recovered in the year immediately following service cut over for that MHP. This account will remain open until all MHP conversion costs and associated revenue requirements are included in a GRC. 2. Operation of MMMBA Entries to the MMMBA shall be made monthly, and shall be determined as follows: a. A debit entry equal to the recorded incremental O&M expenses, including applicable payroll taxes and benefits on SCE labor; b. A debit entry equal to the incremental capital-related revenue requirement, excluding associated Franchise Fees and Uncollectibles (FF&U) expenses related to the “to the meter” capital costs incurred. The capital-related revenue requirement shall include depreciation expense, return on rate base at the currently authorized rate of return on rate base and applicable taxes, such as income and ad valorem taxes; c. A debit entry equal to the revenue requirement on the regulatory asset, excluding FF&U, related to the “beyond the meter” costs incurred. The revenue requirement shall include amortization expense, return on investment at the currently authorized rate of return on rate base, and applicable taxes, such as income and ad valorem taxes associated with the costs of installed equipment. The “beyond the meter” costs will be amortized over ten years; d. A credit entry to transfer the December 31st balance to the distribution sub-account of the Base Revenue Requirement Balancing Account. Interest shall accrue monthly to the MMMBA by applying the interest rate to the average of the beginning-of-month and end-of-month balances recorded in the MMMBA. 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. (Continued) (To be inserted by utility) Advice 3576-E-A Decision 14-03-021 1D11 Issued by Caroline Choi Senior Vice President (To be inserted by Cal. PUC) Date Filed Oct 5, 2017 Effective Resolution E-4878 (T) (T)
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Southern California Edison Rosemead, California (U 338-E) Cancelling Revised Original Cal. PUC Sheet No. Cal. PUC Sheet No. PRELIMINARY STATEMENT 61365-E 55094-E Sheet 2 (Continued) MM. Mobilehome Park Master Meter Balancing Account (MMMBA) (Continued) 3. Disposition SCE will file an annual advice letter in December to recover the December 31st recorded balance through rates for completed conversions in the year immediately following the cut over of service. 4. Review SCE is authorized to fully recover in distribution rates the costs of the conversion program, subject to reasonableness review. Review for reasonableness of “to the meter” costs and “beyond the meter costs” will occur in the first General Rate Case (GRC) proceeding where conversion costs are included into GRC rate base for the MHPs that have had service cut over completed. Revenue requirements related to the MHP program costs will continue to be recorded in the MMMBA for MHP conversions that commenced prior to December 31, 2019. (To be inserted by utility) Advice 3576-E-A Decision 14-03-021 2D8 Issued by Caroline Choi Senior Vice President (N) (N) (To be inserted by Cal. PUC) Date Filed Oct 5, 2017 Effective Resolution E-4878
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Southern California Edison Rosemead, California (U 338-E) Cancelling Revised Original Cal. PUC Sheet No. Cal. PUC Sheet No. Rule 27 MOBILEHOME PARK UTILITY UPGRADE PROGRAM 61366-E 55237-E Sheet 1 APPLICABILITY Pursuant to California Public Utilities Commission’s (CPUC or Commission) Decision (D.) 14-03-021 and Resolution E-4878, the Mobilehome Park Utility Upgrade Program (MHP Program) is a voluntary pilot program anticipated to convert approximately 30 percent of eligible master-metered submetered Mobilehome Parks or Manufactured Housing Communities (MHP) spaces within SCE’s service territory. The MHP Program will conclude the earlier date of either December 31, 2019, or the issuance of a Commission decision for the continuation, expansion, or modification of the Program beyond December 31, 2019. Subject to the requirements set forth in this Rule, all eligible submetered spaces, and common use services within the entire MHP (including both “To-the-Meter” and “Beyond-the-Meter”) will be converted from master-metered electric distribution service to direct SCE distribution and service (Distribution System). However, SCE will not begin construction of a MHP if, at the start of the construction, the facts indicate the conversion project will not be completed by October 31, 2019. 1. The MHP Program is available to all eligible MHPs within SCE’s service territory as defined in Section 2, below. Within the eligible MHPs the only eligible Mobilehome spaces are those permitted by the California Department of Housing and Community Development (HCD) or its designated agency. Recreational vehicle parks are not eligible for the MHP Program. 2. MHPs must meet all of the following criteria to be eligible for the MHP Program. Program eligibility does not guarantee acceptance into the program, nor does it guarantee conversion to direct service from SCE. a. Receive electricity through a master-meter, own and operate the distribution system with associated sub-meters, and furnish electricity to residents. b. Take electric service under the following rate schedule: DMS-2 Domestic Service Multifamily Accommodation – Submetered c. Operate under a current and valid license from the governmental entity with relevant authority. d. If operated on leased real property, the land lease agreement must continue for a minimum of 20 years from the time that the MHP Agreement is executed by SCE. e. Not be subject to an enforceable condemnation order and/or to a pending condemnation proceeding. (Continued) (To be inserted by utility) Advice 3576-E-A Decision 14-03-021 1D13 Issued by Caroline Choi Senior Vice President (To be inserted by Cal. PUC) Date Filed Oct 5, 2017 Effective Resolution E-4878 (T) (T) (N) | (N) (N) | (N)
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