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


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Russell G. Worden
Managing Director, State Regulatory Operations

January 9, 2018
ADVICE 3576-E-B
(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 and pursuant to comments provided in
SCE’s Amended Reply to Protest of the Office of Ratepayer Advocates (ORA) to Advice
3576-E-A filed on November, 3, 2017, the purpose of this supplemental advice letter is
to make changes to SCE’s Preliminary Statement Part MM, Mobilehome Park Master
Meter Balancing Account (MMMBA) to clarify Mobilehome Park conversion costs will
continue to be recorded in the MMMBA consistent with OP 7 of Resolution E-4878.1
This advice filing supplements in part the original Advice 3576-E, but except as
described herein, Advice 3576-E remains unchanged.
BACKGROUND
SCE filed Advice 3576-E-A on October 5, 2017 in compliance with Resolution E-4878.
Specifically, SCE proposed to revise its 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 proposed to revise its Rule 27, Mobilehome Park Utility Upgrade
1

OP 7 of Resolution E-4878 states in pertinent part that “a utility shall not begin construction
of a utility upgrade project of a MHP if, at the start of the construction project, facts indicate
that this conversion project would not be completed by October 31, 2019.”

P.O. Box 800

8631 Rush Street

Rosemead, California 91770

(626) 302-4177

Fax (626) 302-6396





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ADVICE 3576-E-B (U 338-E) -2- January 9, 2018 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. ORA protested SCE’s Advice 3576-E-A and stated that SCE erred by including language in its MMMBA tariff revisions that would permit it to include revenue requirements related to the MHP Program for MHP conversion projects that are “commenced prior to December 31. 2019.” ORA submits that this language is inconsistent with OP 7 of the Resolution, which prohibits the commencement of any MHP conversion project that will not be completed by October 31, 2019. SCE agreed with ORA, and agrees to modify its MMMBA language consistent with language provided within OP 7 as set forth below. Proposed Tariff Changes Consistent with its Amended Reply to Protest of ORA, SCE is modifying its MMMBA with the underlined, clarifying language. 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, provided that the facts at the start of the construction project indicated that the conversion project will 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, which is the same Tier designation as Advice 3576-E-A. EFFECTIVE DATE This advice filing will become effective on the same day as Advice 3576-E-A, which is October 5, 2017. PROTESTS SCE asks that the Commission, pursuant to General Order (GO) 96-B, General Rules 7.5.1, maintain the original protest and comment period designated in Advice 3576-E-A and not reopen the protest period. The modifications included within this supplemental advice letter are consistent with changes proposed by ORA; thus are changes that should not affect the overall evaluation of the filing.
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ADVICE 3576-E-B (U 338-E) -3- January 9, 2018 NOTICE In accordance with General Rule 4 of 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) 302-4039. 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. Wordenn Russell G. Worden RGW:dm:jm 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-B 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: -1- 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: Preliminary Statement Part MM Service affected and changes proposed1: Pending advice letters that revise the same tariff sheets: 1 Discuss in AL if more space is needed. 3676-E and 3576-E-A
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All correspondence regarding this AL 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 Cal. P.U.C. Sheet No. Revised 61365-E 3576-E-B Title of Sheet Preliminary Statement Part MM 1 Attachment A Cancelling Cal. P.U.C. Sheet No. Original 55094-E
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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 after December 31, 2019, for MHP conversions that commenced prior to December 31, 2019, provided that the facts at the start of the construction project indicated that the conversion project will be completed by October 31, 2019. (To be inserted by utility) Advice 3576-E-B Decision 14-03-021 2P8 Issued by Caroline Choi Senior Vice President (N) | | (N) (To be inserted by Cal. PUC) Date Filed Jan 9, 2018 Effective Resolution E-4878
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