Details for: SCE's Comments on Draft Resolution M-4839.pdf

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

January 7, 2019
Ms. Alice Stebbins, Executive Director
California Public Utilities Commission
505 Van Ness Avenue
San Francisco, CA 94102

Comments of Southern California Edison Company
on Draft Resolution M-4839

Dear Executive Director Stebbins:
In accordance with Rule 14.5 of the California Public Utilities Commission’s
(Commission’s) Rules of Practice and Procedure, Southern California Edison Company
(SCE) respectfully submits these Comments on Draft Resolution M-4839 (the Draft
Resolution). The Draft Resolution establishes the annual Public Utilities Commission
Utilities Reimbursement Account Users Fees (PUCURA Users Fees) for 2019, to be
effective April 1, 2019. SCE’s Comments request a minor deviation to implement the
2019 PUCURA Users Fees in customer rates one month early, on March 1, 2019. If the
Commission adopts this simple request it will have two principal beneficial effects: (1) it
will allow the Commission to recover more PUCURA revenue from SCE’s customers in
2019 than would otherwise be the case under the Draft Resolution’s contemplated
timeline; and (2) it will ensure accuracy and administrative efficiency from an SCE billingsystem perspective, as SCE will already be implementing various consolidated rate
changes on March 1, 2019 for both its system-wide electric and Catalina Gas and Water
California Public Utilities Code Section 431 requires the Commission to annually
determine a fee to be paid by every electrical, gas, water (and other) utilities’ customers,
known as the PUCURA Users Fee. This fee is established by the Governor’s annual
budget based on authorized expenditures therein. The total PUCURA budget for 2018
across all regulated California utilities was approximately $172.8 million. The Draft
Resolution concludes that for 2019 the PUCURA Users Fees will need to be materially
increased, in order to avoid a deficit. The electric sector’s customers’ proportional
responsibility for the PUCURA Users Fees is approximately 58 percent. To avoid
deficits, the Draft Resolution would impose a 26 percent increase on this PUCURA
kilowatt-per-hour (kWh) charge for electric customers in 2019 as compared to 2018. The
electric utilities’ share of the PUCURA Users Fees is calculated on a kWh basis, based
on customers’ electricity usage. For SCE, the rate and revenue requirements for the
P.O. Box 800

8631 Rush Street

Rosemead, California 91770

(626) 302-9645

Fax (626) 302-6396


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Energy Division California Public Utilities Commission January 7, 2019 Page 2 PUCURA Users Fees customer charge is based on an annual budget based on estimated annual sales. SCE Request for Earlier Implementation of PUCURA Rate Change The Draft Resolution moves the effective date of the 2019 PUCURA User Fee from January 1, 2019 to April 1, 2019. In changing the effective date of the PUCURA User Fee, the Resolution does not appear to adjust kWh sales to account for the shortened recovery period. SCE respectfully requests that it be authorized to implement the new 2019 PUCURA Users Fees rates in customer bills one month earlier, on March 1, 2019. Implementing one month earlier will allow the Commission to appropriately collect additional PUCURA revenues from SCE’s customers. Because, as discussed above, SCE’s PUCURA Users Fees rates are set on an annual basis based on annual forecast sales, implementation on April 1 will only collect 75 percent of SCE’s customers’ pro-rata responsibility for the incremental increase to the 2019 PUCURA budget (i.e., 9 out of 12 months in 2019). By contrast, approving SCE’s proposal will allow the Commission to collect more than 83 percent of SCE’s customers’ pro-rata responsibility for the incremental increase to the 2019 PUCURA budget (i.e., 10 out of 12 months in 2019). In addition to this clear benefit to the Commission, adoption of SCE’s proposal to put the 2019 PUCURA rates into effect one month early will also help ensure that SCE is able to accurately implement the Commission’s directives. SCE has a long-planned, complicated rate change on March 1, 2019, which is anticipated to implement rate changes resulting from SCE’s 2016 RDW (D.18-07-006), 2018 GRC Phase 2 (D.18-11-027), 2019 ERRA Forecast (A.18-05-003),1 2019 ERRA Trigger (A.18-11-009),2 other CPUC-jurisdictional balancing account and funding rate changes,3 and the Catalina Gas commodity charge.4 Acceptance of SCE’s proposal will not only be administratively efficient, it will also reduce the risk of customer confusion from multiple serial rate changes, will reduce postage costs, and will reduce the risk of inaccuracy from attempting to implement multiple “pro-rations” of billing factor changes. In addition, if SCE’s proposal is not accepted, SCE will not be able to implement the Draft Resolution’s rate changes until April 4, 2019 (i.e., three days late), as SCE’s billing systems cannot accommodate multiple rate changes within 34 days of each other. 1 2 3 4 See December 10, 2018 pending Proposed Decision of Administrative Law Judge (ALJ) Kline (on the Commission’s voting agenda on January 10, 2019). See ALJ Kline email dated December 20, 2018 granting SCE’s motion to modify the procedural schedule accepting stipulation of parties (with contemplation of a March 1, 2019 implementation date). See Advice 3896-E for the balancing account and other funding rate changes, which SCE will update in its advice letter to implement a March 1, 2019 consolidated rate change to be submitted by March 1, 2019. In D.82-04-010, Ordering Paragraph 2, the Commission authorized SCE to submit Gas Cost Adjustment Clause filings by advice letter for every 6-month period, with March 1 and September 1 as the regularly-scheduled revision dates.
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Energy Division California Public Utilities Commission January 7, 2019 Page 3 CONCLUSION SCE appreciates the Commission’s consideration of SCE’s request for a one-month acceleration to implement the Draft Resolution’s rate changes (i.e., by March 1, 2019). Southern California Edison Company /s/ Gary A. Stern /s/ Gary A. Stern, Ph.D. Gary A. Stern, Ph.D. GAS:ra:jm
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