Details for: 3924-E (Part 1 of 1).pdf

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

December 21, 2018
(U 338-E)

Recovery of the 2018 Balance in the Mobilehome Park Master
Meter Balancing Account in Accordance with Decision

In accordance with California Public Utilities Commission (Commission) Decision (D.)
14-03-021 and Preliminary Statement Part MM, Mobilehome Park Master Meter
Balancing Account (MMMBA), in this advice letter, Southern California Edison Company
(SCE) provides the operation of the MMMBA for 2018. SCE will transfer the estimated
December 31, 2018 MMMBA balance of $15.3 million to the distribution sub-account of
the Base Revenue Requirement Balancing Account (BRRBA) to be collected from
customers in 2019 distribution rates.
On March 13, 2014, the Commission issued D.14-03-021, which adopted a three-year
“living pilot” program to incentivize voluntary conversions of master-metered service to
direct service at mobile home parks (MHP). The pilot program directs SCE to convert
approximately 10 percent of the spaces within its service territory over the pilot
program’s three-year term. This decision authorized the creation of a balancing account
for recording actual MHP program costs.
On July 9, 2014, SCE submitted Advice 3072-E to establish the MMMBA.1 The purpose
of this balancing is to record the incremental costs associated with the conversion of the
master-metered service. Incremental costs include the incremental revenue requirement
associated with “to-the-meter” costs capitalized and placed in service upon system
cutover to direct utility service, including incremental Operation and Maintenance (O&M)
start-up costs such as customer outreach, administrative and other ongoing costs to

Advice 3072-E was approved by letter from the Director of the Energy Division dated
August 19, 2014 and made effective August 8, 2014.

P.O. Box 800

8631 Rush Street

Rosemead, California 91770

(626) 302-9645

Fax (626) 302-6396


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ADVICE 3924-E (U 338-E) -2- December 21, 2018 implement the three-year pilot program. The MMMBA also records the incremental revenue requirement for the regulatory asset associated with “beyond-the-meter” costs incurred. The regulatory asset is amortized over a ten-year period earning a rate of return at SCE’s currently authorized rate of return. In D.14-03-021, the Commission stated that the actual construction costs for each MHP conversion recorded in the balancing account should be recovered via advice letter in the year immediately following service cut over for that MHP.2 SCE is authorized to fully recover in distribution rates the costs of the conversion program, subject to reasonableness review. Review for reasonableness of both “to-the-meter” and “beyondthe-meter” costs will occur in the first General Rate Case (GRC) proceeding where conversion costs are included in the GRC rate base for the MHPs that have had service cutover completed. SCE submitted Advice 3576-E on March 17, 2017, pursuant to Ordering Paragraph (OP) 13 of D.14-03-021, to request approval to continue the MHP pilot program for an additional six years (2018-2023) and the conversion of an additional 20 percent of MHP spaces. On September 29, 2017, the Commission issued Resolution E-4878, which allows SCE to continue its current MHP pilot 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 in the MHP Order Instituting Rulemaking (OIR), whichever is earlier.3 The Commission also affirmed that the utilities are to continue to record actual program costs in a balancing account and to recover prudently incurred costs in the first year following cutover to service. The Commission also clarified the timing of the reasonableness review of costs. 2018 OPERATION OF THE MMMBA SCE submits this advice letter to recover the December 31, 2018 balance in the MMMBA in 2019 rate levels. The following table presents a summary of the 2018 operation of the MMMBA including recorded activity through November 30, 2018, and estimated December 2018 activity. Attachment A to this advice letter contains the workpapers in support of the detailed operation of the MMMBA in 2018. 2 3 D.14-03-021 at page 50. Consistent with OPs 7 and 8 of D.14-03-021, 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.
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ADVICE 3924-E (U 338-E) -3- December 21, 2018 Mobilehome Park Master Meter Balancing Account 2018 Line No. Description ($000) 1. Beginning Balance - 2. 3. Capital Adjustment Adjusted Beginning Balance 226 226 4. 5. 6. 7. Operating Expenses Labor Non-Labor Total Operating Expenses 304 304 8. 9. 10. 11. 12. 13. Capital-Related Revenue Requirement - Depreciation - Income Taxes - Property Taxes - Return Total Capital-Related Revenue Requirement 7,307 1,099 185 6,068 14,659 14. (Over)/Under Collection (Line 7 + Line 13) 14,963 15. Interest 16. Ending Balance (Line 3 + Line 14 + Line 15) 150 15,339 SCE will transfer the actual December 31, 2018 year-end MMMBA balance to the distribution sub-account of the BRRBA in December 2018 to be collected from customers in distribution rates in 2019. Review for reasonableness of both “to-the-meter” and “beyond-the-meter” costs will occur in the first GRC proceeding where conversion costs are included in the GRC rate base for the MHPs that have had service cutover completed. This advice letter will not cause the withdrawal of service, or conflict with any other schedule or rule. TIER DESIGNATION Pursuant to General Order (GO) 96-B, Energy Industry Rule 5.1, this advice letter is submitted with a Tier 1 designation.
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ADVICE 3924-E (U 338-E) -4- December 21, 2018 EFFECTIVE DATE This advice letter will become effective on the date filed, December 21, 2018. 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: Copies of protests should also be mailed to the attention of the Director, Energy Division, Room 4004, at the address shown above. 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: 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: 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.
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ADVICE 3924-E (U 338-E) -5- December 21, 2018 In accordance with General Rule 4 of General Order (GO) 96-B, SCE is serving copies of this advice letter to the interested parties shown on the attached GO 96-B, R.11-02-018 and R.18-04-018 service lists. Address change requests to the GO 96-B service list should be directed by electronic mail to or at (626) 302-4039. For changes to all other service lists, please contact the CPUC’s Process Office at (415) 703-2021 or by electronic mail at 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 For questions, please contact Kimwuana Blebu at (626) 302-2403 or by electronic mail at Southern California Edison Company /s/ Gary A. Stern /s/ Gary A. Stern, Ph.D. Gary A. Stern, Ph.D. GAS:kb:jm Enclosure
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ADVICE LETTER 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: ELC GAS PLC HEAT ELC = Electric PLC = Pipeline WATER Contact Person: Darrah Morgan Phone #: (626) 302-2086 E-mail: E-mail Disposition Notice to: EXPLANATION OF UTILITY TYPE GAS = Gas WATER = Water HEAT = Heat (Date Submitted / Received Stamp by CPUC) Tier Designation: 1 Advice Letter (AL) #: 3924-E Subject of AL: Recovery of the 2018 Balance in the Mobilehome Park Master Meter Balancing Account in Accordance with Decision 14-03-021 Keywords (choose from CPUC listing): Compliance, Balancing Account, Metering AL Type: Monthly Quarterly Annual One-Time Other: If AL submitted in compliance with a Commission order, indicate relevant Decision/Resolution #: Decision 14-03-021 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: 12/21/18 No. of tariff sheets: 0 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: None Service affected and changes proposed1: Pending advice letters that revise the same tariff sheets: None 1 Discuss in AL if more space is needed. Clear Form
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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: CPUC, Energy Division Attention: Tariff Unit 505 Van Ness Avenue San Francisco, CA 94102 Email: Name: Gary A. Stern, Ph.D. Title: Managing Director, State Regulatory Operations Utility Name: Southern California Edison Company Address: 8631 Rush Street City: Rosemead Zip: 91770 State: California Telephone (xxx) xxx-xxxx: (626) 302-9645 Facsimile (xxx) xxx-xxxx: (626) 302-6396 Email: Name: Laura Genao c/o Karyn Gansecki Title: Managing Director, State Regulatory Affairs Utility Name: Southern California Edison Company Address: 601 Van Ness Avenue, Suite 2030 City: San Francisco State: California Zip: 94102 Telephone (xxx) xxx-xxxx: (415) 929-5515 Facsimile (xxx) xxx-xxxx: (415) 929-5544 Email: Clear Form
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ENERGY Advice Letter Keywords Affiliate Direct Access Preliminary Statement Agreements Disconnect Service Procurement Agriculture ECAC / Energy Cost Adjustment Qualifying Facility Avoided Cost EOR / Enhanced Oil Recovery Rebates Balancing Account Energy Charge Refunds Baseline Energy Efficiency Reliability Bilingual Establish Service Re-MAT/Bio-MAT Billings Expand Service Area Revenue Allocation Bioenergy Forms Rule 21 Brokerage Fees Franchise Fee / User Tax Rules CARE G.O. 131-D Section 851 CPUC Reimbursement Fee GRC / General Rate Case Self Generation Capacity Hazardous Waste Service Area Map Cogeneration Increase Rates Service Outage Compliance Interruptible Service Solar Conditions of Service Interutility Transportation Standby Service Connection LIEE / Low-Income Energy Efficiency Storage Conservation LIRA / Low-Income Ratepayer Assistance Street Lights Consolidate Tariffs Late Payment Charge Surcharges Contracts Line Extensions Tariffs Core Memorandum Account Taxes Credit Metered Energy Efficiency Text Changes Curtailable Service Metering Transformer Customer Charge Customer Owned Generation Mobile Home Parks Name Change Transition Cost Transmission Lines Decrease Rates Non-Core Transportation Electrification Demand Charge Non-firm Service Contracts Transportation Rates Demand Side Fund Nuclear Undergrounding Demand Side Management Oil Pipelines Voltage Discount Demand Side Response PBR / Performance Based Ratemaking Wind Power Deposits Portfolio Withdrawal of Service Depreciation Power Lines Clear Form
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Attachment A
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5. 17. Interest Rate 16. Ending Balance 15. Interest 1.43% 924,276.78 550.39 923,726.39 1.59% 1,961,182.08 1,910.35 1,034,994.95 1.69% 2,956,023.68 3,460.10 991,381.50 - 38,601.97 38,601.97 14. Monthly (Over)/Under Collection - 21,587.00 21,587.00 1,961,182.08 1,961,182.08 - Recorded March 504,551.51 70,797.38 14,413.00 363,017.65 952,779.53 - 36,645.58 36,645.58 924,276.78 924,276.78 - Recorded February 8. Capital-Related Revenue Requirements: BTM & TTM 9. Depreciation 489,675.09 503,858.16 10. Income Taxes 136,502.85 34,670.99 11. Property Taxes 13,838.97 13,838.97 12. Return 247,063.90 461,039.83 13. Total Capital Costs 887,080.81 1,013,407.95 Labor Loaders O&M Costs: Labor Non-Labor Total O&M Costs - Adjusted Beginning Balance 4. Recorded January Beginning Balance Rev Req 2016-17 Provision Adj Doc 1001694113 Rev Req 2016-17 Interest Adj Doc 1001694113 - Item 1. 2. 3. Line No. P9157 - Mobilehome Park Master Meter Balancing Account - 2018 GL: 1412855 / 2412855/ 1451142/ 1471297 1.90% 3,852,842.38 5,386.09 891,432.61 516,117.47 (16,714.03) 14,030.31 365,811.61 879,245.36 - 12,187.25 12,187.25 2,956,023.68 2,956,023.68 - Recorded April 2.00% 5,222,079.63 7,743.97 1,135,909.33 825,183.91 (137,324.83) (51,018.67) 461,841.40 1,098,681.82 - 37,227.51 37,227.51 4,078,426.33 3,852,842.38 224,435.60 1,148.35 Recorded May 2.03% 6,714,913.23 10,088.17 1,482,745.43 611,148.32 289,345.21 8,072.45 565,358.69 1,473,924.67 - 8,820.76 8,820.76 5,222,079.63 5,222,079.63 - Recorded June 2.08% 8,037,896.21 12,774.70 1,310,208.28 635,506.88 43,471.79 28,594.84 588,132.86 1,295,706.37 - 14,501.91 14,501.91 6,714,913.23 6,714,913.23 - Recorded July 2.12% 9,491,605.46 15,470.73 1,438,238.52 639,317.16 130,998.61 28,594.84 602,179.41 1,401,090.02 - 37,148.50 37,148.50 8,037,896.21 8,037,896.21 - Recorded August 2.12% 10,957,033.61 18,047.02 1,447,381.13 637,670.34 153,426.01 28,594.84 603,052.76 1,422,743.94 - 24,637.19 24,637.19 9,491,605.46 9,491,605.46 - Recorded September 2.19% 12,412,741.08 21,305.48 1,434,401.99 642,168.99 135,604.12 28,594.84 601,494.27 1,407,862.22 - 26,539.77 26,539.77 10,957,033.61 10,957,033.61 - Recorded October 2.31% 13,871,889.30 25,274.63 1,433,873.59 656,398.02 121,522.95 28,594.84 605,476.03 1,411,991.84 - 21,881.75 21,881.75 12,412,741.08 12,412,741.08 - Recorded November 2.31% 15,338,529.52 28,087.99 1,438,552.24 645,412.45 136,851.03 28,594.84 603,341.02 1,414,199.33 - 24,352.90 24,352.90 13,871,889.30 13,871,889.30 - Forecast December 15,338,529.52 150,099.62 14,962,845.94 7,307,008.29 1,099,152.07 184,744.06 6,067,809.43 14,658,713.85 - 304,132.09 304,132.09 225,583.95 224,435.60 1,148.35 Annual Summary
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