Details for: SCE's Comments Response to Draft Resolution E-4979 (3901e).pdf


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

April 10, 2019
Energy Division
California Public Utilities Commission
505 Van Ness Avenue
San Francisco, CA 94102
Re:

Comments of Southern California Edison Company
on Draft Resolution E-4979

Dear Energy Division:
Pursuant to Rule 14.5 of the California Public Utilities Commission’s (Commission’s)
Rules of Practice and Procedure, Southern California Edison Company (SCE)
appreciates the opportunity to submit these comments on Draft Resolution E-4979.
I. Discussion
SCE appreciates the Commission’s approval of $11,038,265 Efficiency Savings and
Performance Incentive (ESPI) award. SCE accepts this outcome and has no comment
on the approved award.
SCE’s comments are limited to only one substantive issue that requires clarification as
noted below.
Ordering Paragraph (OP) 4 states that “The [investor-owned utilities] IOUs shall raise all
concerns with the Utility, Audit, Finance and Compliance Branch reports during the audit
stakeholder review process that results in the final reports. Concerns will not be
investigated within the ESPI Resolution.”1 SCE agrees that the IOUs should continue to
work with the Utility, Audit, Finance and Compliance Branch (UAFCB) to resolve all
issues.
However, SCE seeks clarification that OP4 is not intended to curb the Commission’s
independent authority to address and resolve all legal and policy issues, including ESPIrelated disagreements between the UAFCB and the IOUs. While SCE does not believe
this is the Commission’s intent, the wording of OP 4 is not clear, especially because the
IOUs already raise all factual concerns with the UAFCB.2
1
2

Draft Resolution E-4979, p. 32
In this Draft Resolution E-4979, for example, the Commission raised an issue at p. 24
regarding the recovery of certain expenditures that was denied by the UAFCB, and the
Commission adjusted SCE’s award to reflect SCE’s position.

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 April 10, 2019 Page 2 Given this potential ambiguity, SCE recommends that OP 4 be removed. Should the Commission decide to keep OP 4, then SCE recommends that it be clarified to make clear that it only applies to factual issues, and that the Commission will resolve all disputes between the UAFCB and IOUs through the ESPI Resolution. SCE suggests OP 4 be modified to read in its entirety: “The IOUs shall work with the Utility, Audit, Finance and Compliance Branch during the audit stakeholder review process to resolve all factual issues in the final reports.” II. Conclusion SCE appreciates the opportunity to offer these comments. Southern California Edison Company /s/ Gary A. Stern, Ph.D. Gary A. Stern, Ph.D. GAS:jf:jm cc: Edward Randolph, Director, CPUC Erica Petrofsky, CPUC Energy Division Manisha Lakhanpal, CPUC Energy Division Pete Skala, CPUC Energy Division Jennifer Kalafut, CPUC Energy Division Service List R.13-11-005 Service List for Draft Resolution E-4979
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