Details for: SCE's Reply to ORA Protest of Advice 3787-E.pdf

Click on the image for full size preview

Document data

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

May 14, 2018
Energy Division
Attention: Tariff Unit
California Public Utilities Commission
505 Van Ness Avenue
San Francisco, CA 94102


Reply of Southern California Edison Company to the Protest to Advice

Dear Energy Division Tariff Unit:
Pursuant to General Rule 7.4.3 of the California Public Utilities Commission’s
(Commission’s or CPUC’s) General Order 96-B, Southern California Edison Company
(SCE) hereby submits its reply comments to the Protest of the Office of Ratepayer
Advocates (ORA) regarding SCE’s Advice 3787-E, Southern California Edison
Company’s Distribution Resources Plan Grid Needs Assessment and Distribution
Deferral Opportunity Report Proposed Work Plan and Format in Compliance with
Decision 18-02-004.


On April 16, 2018, SCE filed Advice 3787-E to submit for approval its Distribution
Resources Plan (DRP) Proposed Work Plans and Reporting Formats for the Grid
Needs Assessment (GNA) Report and Distribution Deferral Opportunity Report (DDOR)
in compliance with Ordering Paragraph (OP) 2k of Decision (D.)18-02-004 (Decision).
On May 7, 2018, ORA submitted its Protest to Advice 3787-E (ORA Protest).1
SCE hereby replies to the ORA Protest.


Protest of the Office of Ratepayer Advocates to Pacific Gas and Electric Company’s Advice
Letter 5277-E, Southern California Edison Company’s Advice Letter 3787-E, and San Diego
Gas & Electric Company’s Advice Letter 3211-E Regarding the Grid Needs Assessment
and Distribution Deferral Opportunity Report Work Plans and Data Formats (“ORA

P.O. Box 800

8631 Rush Street

Rosemead, California 91770

(626) 302-9645

Fax (626) 302-6396


- Page 1 -

Energy Division California Public Utilities Commission May 14, 2018 Page 2 II. Discussion A. Response Regarding Content of SCE’s Proposed Work Plan Contrary to ORA’s assertion, SCE does not believe its work plan overemphasizes its “general distribution planning process.”2 SCE’s distribution planning process is the central foundation for the data contained in the GNA and DDOR, and establishing a plan to enable this process to support the GNA and DDOR reporting requirements is a critical aspect to achieving “the data compilation and reporting capabilities needed to complete the annual GNA and DDOR exercise.”3 The milestones presented in SCE’s work plan represent the completion of tasks in the annual distribution planning process because these tasks provide the inputs needed to compile the GNA and DDOR reports. ORA also asserts that while “SCE’s work plan appears well developed,” ORA would prefer more information concerning “the development and implementation of data compilation and reporting capabilities.”4 The compilation and formatting of SCE’s initial GNA and DDOR will consist of a largely manual process that leverages outputs of the annual planning process, combined with LNBA results, and the output of additional analysis to create forecasted profiles to quantify the frequency and magnitude of needs. While SCE will seek out opportunities to streamline the level of effort, this manual process will continue to be utilized until SCE is able to fully implement future software capabilities in its Long-term Planning Tool, specifically the forecasting, power flow and capacity analysis, project portfolio development to meet grid needs, and integrated reporting engine. The manual data compilation and reporting effort includes extracting data that describes the grid needs, planned investments, and candidate deferral projects from SCE’s planning databases as they become available as corresponding milestones in the annual planning process are completed. SCE will then manually compile, and format the fields in Microsoft Excel to publish the final reports. B. Response Regarding ORA’s request for Workshop and Format Changes ORA recommends that the Commission reject the Advice Letters, hold a workshop to establish a common format across utilities for the GNA and DDOR beginning with the 2018 DDOR and the 2019 GNA filings, and require that the Utilities clarify their work plans and milestones.5 SCE disagrees with this recommendation and requests that the Commission approve Advice 3787-E, as the Advice Letter is consistent with the directive of the Decision and the requirements laid out in Section 2 3 4 5 6 ORA Protest, at p. 3. D.18-02-004, at Ordering Paragraph No. 2.k. ORA Protest, at p. 3. Id, at p. 1. D.18-02-004, at p. 35-39.
- Page 2 -

Energy Division California Public Utilities Commission May 14, 2018 Page 3 Workshops are not necessary and may in fact create delays in achieving the September 1, 2018 DDOR deadline, especially with the many other requirements driven by the DRP for 2018 implementation.7 The Decision does not require that the utilities have consistent formatting and SCE notes that difference in the proposed formats may allow stakeholders to evaluate various options to determine the most effective format. In addition, the three IOUs have slightly different ways of referencing their distribution systems, performing analysis, and currently have varying planning software capabilities. SCE acknowledges the value of a consistent format for users of the GNA and DDOR reports; however, it is premature to establish a single, common format. Allowing the utilities to publish their 2018 DDOR reports using the proposed formats in their respective Advice Letters would allow stakeholders to compare various formats to better inform recommendations towards a common format in future iterations as deemed appropriate by the Commission. III. Conclusion SCE thanks the Commission for the opportunity to provide these reply comments to the ORA Protest of Advice 3787-E. Sincerely, /s/ Gary A. Stern, Ph. D.. Gary A. Stern, Ph. D. GAS:ag:jm cc: 7 Edward Randolph, Director, CPUC Energy Division Chloe Lukins, ORA Anne E. Simon, Chief ALJ, CPUC Gabe Petlin, CPUC Energy Division Marc Monbouquette, CPUC Energy Division Service List R.14-08-013 ICA initial system wide implementation, LNBA, system wide implementation, GNA Report, DDOR Report, identifying deferrable distribution projects, and the DPAG process.
- Page 3 -