Details for: SCE's Reply to Protests to Advice 3781-E.pdf

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

May 8, 2018

Energy Division
Attention: Tariff Unit
California Public Utilities Commission
505 Van Ness Avenue
San Francisco, CA 94102


Reply to Protests of California Choice Energy Authority and
Community Choice Partners, Inc. and Joint Protest of Clean
Power Alliance of Southern California and Western Riverside
Council of Governments to Advice 3781-E

Dear Energy Division Tariff Unit:
Pursuant to General Rule 7.4.3 of the California Public Utilities Commission’s
(Commission’s) General Order (GO) 96-B, Southern California Edison Company (SCE)
hereby acknowledges the protests of Clean Power Alliance of Southern California
(CPASC) and the Western Riverside Council of Governments (WRCOG) (collectively,
the Joint CCAs), California Choice Energy Authority (CCEA), and Community Choice
Partners, Inc. (CCPartners) to SCE’s Advice 3781-E, Modification to Various Electric
Tariffs.1 As discussed below, however, because SCE is withdrawing Advice 3781-E,
these protests are moot and SCE is not addressing their substance herein.


SCE filed Advice 3781-E on April 11, 2018, to modify various tariffs. The requested
modifications include adding clarifying details and language to avoid unintended
ambiguity, including cross references from other previously-approved tariffs, correcting
citations or references, removing obsolete information, and withdrawing tariffs that are
no longer necessary. SCE submits several advice letters of this type each year to
combine numerous tariff changes in one periodic advice letter to minimize the
administrative burden and inefficiency of filing numerous advice letters throughout the


Advice 3781-E can be found at

P.O. Box 800

8631 Rush Street

Rosemead, California 91770

(626) 302-9645 FAX (626) 302-6396


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Energy Division Tariff Unit Page 2 May 8, 2018 On May 1, 2018, Joint CCAs, CCEA, and CCPartners each submitted a protest pursuant to Sections 3.11 and 7.4 of GO 96-B, questioning the appropriateness of certain changes proposed in the advice filing, specifically focusing on SCE’s proposed changes to its Rule 23, Community Choice Aggregation; Schedule CCA-INFO, Community Choice Aggregation - Information Fees; and Form 14-769, Community Choice Aggregator Non-Disclosure Agreement. II. Response to the Protest In its Protest, CCEA correctly notes that SCE, due to an oversight, inadvertently failed to include all prospective and current CCAs in its service list for Advice 3781-E. In order to correct this oversight and to make other corrections and minor changes to its filing, SCE has concurrently filed a withdrawal of Advice 3781-E and intends to file a new advice letter. SCE commits to serve all parties on the R.03-10-003, R.16-02-007, and R.17-09-020 service lists, so that all potentially-interested parties have an opportunity to review the advice letter. SCE will also serve all entities that have submitted an executed Form 14-770, Community Choice Aggregator Service Declaration to SCE. III. Conclusion SCE appreciates the comments provided by Joint CCAs, CCEA, and CCPartners, but respectfully maintains that they do not need to be addressed at this time because SCE is withdrawing the underlying advice letter. Any remaining concerns with SCE’s proposed tariff changes will be appropriately addressed when SCE files a new advice letter. As such, SCE requests that the Commission deny as moot the protests filed by Joint CCAs, CCEA, and CCPartners. Sincerely, /s/ Gary A. Stern, Ph.D. /s/ Gary A. Stern, Ph.D. Gary A. Stern, Ph.D. GAS:al:jm cc: Edward Randolph, Director, CPUC Energy Division Cathy DeFalco, CCEA Ryan M. F. Baron, Joint CCAs Samuel Golding, President, CCPartners Dru Dunton, CPUC Energy Division 2
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Energy Division Tariff Unit Page 3 May 8, 2018 Suzanne Casazza, CPUC Energy Division Dorothy Duda, CPUC Energy Division Service lists R.03-10-003, R.16-02-007, and R.17-09-020 3
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