Details for: 4052-E (Part 1 of 1).pdf

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

August 8, 2019
(U 338-E)
Update of Cost Estimate for Wheeler North Reef Expansion


In accordance with Decision (D.) 18-03-027 (Decision), Southern California Edison
Company (SCE) respectfully submits this Advice Letter (AL) providing an updated cost
estimate for the Wheeler North Reef (WNR) Expansion Project. Upon approval of the
AL, a revenue requirement for the project will be authorized for SCE based on the
updated estimate.
1. SONGS 2&3 Coast Development Permit and Conditions
The California Coastal Commission (CCC) issued the original coastal development
permit (CDP) for San Onofre Nuclear Generating Station (SONGS) 2&3 in 1974,
approving SCE’s construction of SONGS 2&3. The CDP provided two conditions (1)
establishing a Marine Review Committee (MRC) to evaluate the impact of SONGS 2&3
on the marine environment, and (2) authorizing the CCC to direct SCE to meet certain
requirements to address any adverse impacts to the marine environment identified by
the MRC. Based on these conditions, the CCC amended the SONGS 2&3 CDP several
times during the course of SONGS 2&3 operations, requiring SCE to implement various
marine mitigation projects to address the impact of SONGS 2&3 operations on the
southern California marine environment, as determined by the CCC.
Among several projects required by the CCC, SCE was required to construct an artificial
kelp reef to mitigate impacts on the San Onofre kelp reef near the coast off SONGS
2&3. Construction of the artificial reef, now known as the WNR, was completed in
September 2008, subject to continued monitoring and potential additional requirements
to be set by the CCC. After monitoring reef performance for several years, the CCC

P.O. Box 800

8631 Rush Street

Rosemead, California 91770

(626) 302-9645

Fax (626) 302-6396


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ADVICE 4052-E (U 338-E) -2- August 8, 2019 concluded in 2016 that the size and configuration of the original WNR is not sufficient and required SCE to complete a WNR Expansion Project. 2. Utilities’ Application for Cost Recovery for the WNR Expansion Project On December 1, 2016, SCE and San Diego Gas & Electric Company (SDG&E) (collectively the Utilities) jointly filed Application (A.) 16-12-002 requesting cost recovery for the WNR Expansion Project. In its opening and supplemental testimony, SCE identified Option 3 – a 105 acre low relief/high density reef – as the design selected for further review by the California State Lands Commission (CSLC), which is the agency that would review the project under the California Environmental Quality Act (CEQA) prior to the CCC’s issuance of a CDP. SCE made this initial selection because the low relief/high density configuration was projected to attract sufficient fish biomass to meet the CCC’s requirements for reef performance and could fit within the areas previously surveyed by SCE. SCE’s estimate for Option 3 was $33 million (100% Share, 2016$). Although SCE presented this information for the California Public Utilities Commission’s (CPUC) review, SCE noted that it planned to further engage the CCC and CSLC to develop a final design for the WNR Expansion Project that would not only maximize fish biomass and integrate with the existing WNR, but “would reduce costs to below SCE’s current [$33 million] estimate.”1 An important component of that plan was to complete surveying activities that could increase the potential area for expansion of the reef, and provide flexibility for SCE to advocate for design options with reduced costs. By the end of May 2017, SCE completed bathymetric and side scan sonar surveys of the ocean floor in the potential expansion areas. With these survey results, obtained through SCE’s efforts to preserve design options, SCE submitted an estimate for its preferred option - Option 1, a 200 acres low relief/low density reef. SCE’s preliminary cost estimate for Option 1 was $19.4 million (100% Share, 2016$), or about $13.6 million (41%) less than Option 3. After submitting the estimate, the Utilities met with intervenors California Public Advocates (Cal PA) and The Utility Reform Network (TURN) to discuss ratemaking options for the project, reaching an all-party settlement in October 2017. 3. CPUC Decision Approving Settlement 2 On March 22, 2018, the CPUC issued D.18-03-027 approving the settlement. Under the approved settlement, the CPUC authorized SCE and SDG&E to establish and maintain a memorandum account to track costs related to the WNR Expansion Project. The CPUC further directed SCE to submit a Tier 3 AL with an updated cost estimate for the project following completion of the CEQA process and issuance of other permits and authorizations. The CPUC stated that upon approval of the AL, a revenue requirement for the project would be authorized for SCE and SDG&E based on the updated estimate. SCE and SDG&E would further be authorized to collect the revenue 1 2 See A.16-12-002, Exhibit SCE-1, p. 9. See D.18-03-027, Ordering Paragraph No. 1, Appendix A.
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ADVICE 4052-E (U 338-E) -3- August 8, 2019 requirement with actual costs continuing to be recorded in their respective memorandum accounts. The CPUC ordered that if after completion of the WNR Expansion project the recorded costs are equal to or below the authorized cost forecast, the spending would be considered to be per se reasonable, and any overcollection based on the revenue requirement would be returned to customers. Conversely, if the recorded costs are greater than the authorized cost forecast, the Utilities would be required to demonstrate the incremental expenses were reasonable prior to being authorized to recover the additional costs. PROJECT REGULATORY REQUIREMENTS AND SCOPE 1. Regulatory Requirements Under Applicable Permits In 2019, SCE successfully completed the CEQA process at the CSLC, obtained a CDP for the project from the CCC, and obtained other related permits from the State Water Resources Control Board (SWRCB) and U.S. Army Corps of Engineers (USACE). With this process complete, SCE now has fully permitted the WNR Expansion Project. Below is a summary of the permits and corresponding acquisition dates:  February 4, 2019 Subsequent Environmental Impact Report (SEIR) and Lease Amendment No. 3, certified by the CSLC  March 7, 2019 California Coastal Commission Certified WNR Expansion Project CDP  April 2, 2019 State Water Resources Control Board issued 401 Water Quality Certification  April 12, 2019 Coastal Development Permit issued  May 24, 2019 USACE issued Clean Water Act Section 404 permit The following actions are to be completed under these various approved permits:  CSLC Requirements o conduct risk assessment and subsequent vessel cleaning (if required), to prevent introduction of nonindigenous aquatic species (SEIR MM BIO-2) o purchase NOX offset air emissions credits (SEIR MM AQ-1a) o prepare and seek agency approval of project mitigation and management plans; support CSLC and tribal representatives in conducting underwater dive surveys to examine effects of rock placement on unknown resources upon initial placement and upon project completion (SEIR MM CR-1a)  CCC Requirements o staff two full time marine mammal monitors on the derrick barge and a monitor on the transport vessel (CDP Special Condition 5b)
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ADVICE 4052-E (U 338-E) -4- August 8, 2019 o perform an audit of the initial polygon construction (CDP Special Condition 6)  Other Requirements o conduct white abalone pre-construction surveys to ensure avoidance of the protected species (USACE Permit NO. SPL-2018-00501-RRS, Special Condition 29) SCE will also prepare and submit various post-construction surveys and reports to these agencies. 2. Project Scope and Schedule SCE selected Connolly-Pacific Company (CPCo), a marine construction company, to construct the WNR Expansion. As explained further below, the contract with CPCo includes the procurement and transportation of the quarry rocks used for the reef and the reef construction. The rocks will be sourced and transported from three separate quarries, two on Catalina Island (Pebbly Beach and Empire Landing), and one in Ensenada, Mexico. A team of surveyors and engineers will position the rocks on the ocean floor until the reef is fully constructed. Construction management and verification is an essential function of the project to ensure all building and material specifications comply with the criteria and design plan for the WNR Expansion Project, and to ensure effectiveness of the reef once constructed. Construction management will also support SCE to ensure that permit requirements are met before, during, and after reef construction. SCE’s initial project schedule estimated the CSLC’s completion of the CEQA review by June 2018, and a two-season reef-construction schedule in 2018 and 2019. In 2018, as part of the CEQA review process, CSLC performed tribal consultation with tribes affiliated with the project area. The tribal consultation and subsequent investigative surveys of the proposed project areas extended the CEQA process by approximately 6 3 months. The CLSC published the Final SEIR in January 2019 and certified the Final SEIR on February 4, 2019. This delay of the CEQA process shifted the two-season construction schedule to occur approximately between July 7, 2019 and September 30, 2019, and May 1, 2020 and September 2020. SCE anticipates the construction period to last approximately 6 months in aggregate. 3 CSLC’s Tribal consultation is presented in SEIR Section 4.5 and underwater survey report is presented in SEIR Appendix G.
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ADVICE 4052-E (U 338-E) -5- August 8, 2019 UPDATED COST ESTIMATE After completion of the CEQA process and issuance of required permits and contracts necessary to construct the WNR Expansion Project, SCE’s updated cost estimate for the WNR Expansion Project is $19.6 million (100% Share, 2016$). The updated cost estimate includes recorded costs to date, as well as going-forward estimated costs, including costs to fulfill requirements and special conditions set by the permitting agencies. Table 1: 2019 Cost Estimate (in Millions, 2016 $, 100% share) No. Description 2017 2018 2019 2020 Total 7 Materials, Transportation, and Construction Mobilization and Demobilization of Construction Equipment Environmental Studies and Document Preparation Permitting Compliance Engineering, Construction Management, Construction Contingency 8 Project Management Support 0.11 0.08 0.19 0.13 0.51 9 Total Costs 1.09 0.85 11.06 6.62 19.62 1 2 3 4 5 6 0 0.11 8.09 5.02 13.22 0 0.31 0.67 0.33 1.31 0.55 0.05 0.13 0.04 0.77 0 0 0.07 0 0.28 0.59 0.04 0.36 0.39 0.95 0.43 0.23 1.11 0.7 2.47 0 0 0 0 0 COMPARATIVE COST ANALYSIS The 2017 cost estimate for the WNR Expansion Project submitted by SCE in A.16-12-002 was $19.4 million (100% Share, 2016$). The 2019 updated cost estimate, following the completion of the environmental review and permitting phase, is $19.6 million (100% Share, 2016$), a net increase of $0.2 million (100% share, 2016$). Table 2 below compares the 2017 estimate and the 2019 updated estimate by the cost categories specified in D.18-03-027, Ordering Paragraph 7.c.
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ADVICE 4052-E (U 338-E) -6- August 8, 2019 Table 2: Comparison of 2017 Estimate and 2019 Estimate (in Millions, 2016 $, 100% share) While there were increases in several of the cost categories, contingency was utilized in the updated cost estimate and the resulting net increase was $0.23 million. SCE provides explanations for the variances in these cost categories below: Materials, Transportation, and Construction In June 2018, SCE solicited for competitive bids for the construction of the reef. The contract was awarded to CPCo selected based upon the commercial viability and technical qualifications. The competitive procurement process resulted in a lower (by $0.46 million) 2019 updated cost estimate than the 2017 original forecast for this cost category. Table 3 provides a cost per unit comparison of the costs by each subcategory.
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ADVICE 4052-E (U 338-E) -7- August 8, 2019 Table 3. Materials, Transportation and Construction Cost by Sub-category (2016 $, 100% share) Mobilization and Demobilization of Construction Equipment Section 2.3.1 of the CSLC’s SEIR outlines the standards and specifications of the reef construction and quarry rock requirements. In addition to sourcing from Mexico, to meet the rock volume demands, CPCo expanded the Empire Landing quarry on Catalina, mobilized additional excavation equipment, and a stationary crane from the mainland, and installed Mining Safety and Health Administration required site safety measures. The additional mobilization effort was not included in the 2017 estimate which resulted in an increase of $0.56 million. Environmental Studies and Document Preparation Assembly Bill 52, effective July 2015, sets forth requirements for analysis of Tribal cultural resources as defined in Public Resources Code section 2074. Under these regulations, CSLC consulted with Native American Tribes regarding the project area as part of the CEQA process. During the consultation, the Acjachemen Nation raised concerns that Tribal cultural resources could remain within the project area which had been occupied prior to being inundated by rising seas levels. The consultation led to a redesign of the project to eliminate the culturally sensitive area of concern from the project and identified additional areas. This process led to a cost increase of $0.27 million not included in the 2017 estimate. Permitting The State Water Resources Control Board fee schedule changed since the 2017 estimate was prepared. The 2019 estimate reflects the actual permitting cost which caused an increase of $0.09 million.
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ADVICE 4052-E (U 338-E) -8- August 8, 2019 Compliance The permit compliance conditions resulted in increased costs of $0.55 million for this category in the 2019 cost estimate. A primary driver was the Marine Wildlife Monitoring discussed below: SEIR Mitigation Measure (MM) Bio-3: Marine Wildlife Monitoring Plan requires a single Marine Wildlife Observer to establish an exclusion zone within the rock fall area of the derrick barge. The CCC’s CDP, Special Condition 5, requires a minimum of two marine mammal observers on the main project vessel and a minimum of one marine mammal observer on the transport vessels to and from the project site. The SEIR MM Bio-3 is consistent with the level of monitoring SCE assumed for the 2017 forecast. The CDP Special Condition 5 significantly expanded the scope of the marine mammal monitoring requirement. Engineering, Construction Management, Construction Verification Cost-efficient and safe execution of the WNR Expansion Project will require precise timing of construction equipment and materials from the various ports of export to and from the construction site and timing of activities at the construction site. The use of three separate quarries to source rock to be transported to the project site increases the complexity of the construction and construction verification activities not previously anticipated. Construction management and construction verification functions are essential to execute a safe, compliant, cost-effective, and successful project adherent to design plans, and ultimately meet the requirements of the CCC in the SONGS CDP #6-81-330. Further, SCE’s safety compliance policies and standards for contractors has expanded to improve incident prevention, incorporate greater inspection and reporting frequencies, document management, and safe practice communication. Hazardous material spill prevention, heavy equipment operation, monitoring sea state are components of the environmental and safety programs to protect the public and the environment during construction. These improvements translated to increases in construction management of $0.87 million. Project Management Support An increase in cost of $0.07 million for this category is due to SCE’s efforts on this project to provide a cost-effective scope that will meet Agency requirements. Consistent with D.18-03-027 (Ordering Paragraph 7.a), SCE is responsible for minimizing the cost of the WNR Expansion Project to the Utilities’ customers. SCE fulfilled this responsibility during the permitting phase by coordinating with agency staff and submitting comments on the agencies proposed requirements, and during procurement-related activities, by conducting thorough competitive bid review processes. Below are examples of SCE’s efforts to minimize project costs.
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ADVICE 4052-E (U 338-E) -9- August 8, 2019 Mitigation Measure CR-1a: Archeological and Tribal Monitoring: Draft EIR language required full time Archeological and Tribal monitors during project activities. SCE’s position was that this measure as written did not consider the lack of visibility and the marine environment conditions of the project, and full-time monitoring would be met with little effectiveness. SCE proposed alternative monitoring in the form of dive surveys (described in Project Scoping) and the preparation of a professional paper documenting the successful consultation with interested tribes. CSLC Tribal Liaison and Project Manager agreed with SCE’s proposal and incorporated the alternative mitigation measure in the final SEIR. The result allowed SCE to avoid a requirement to have two full-time persons onboard the derrick barge during construction, thus reducing safety risk and cost of the project while affording adequate protection and consideration of Tribal interests. Mitigation Measure BIO- 2: Prevent Import of Nonindigenous Species. Draft EIR language required SCE to have underwater surfaces cleaned prior to entering southern California and immediately prior to transiting to the project site. SCE’s position was that vessel cleaning upon each trip would impose a significant schedule and cost impact on the project. SCE proposed an alternative mitigation for CSLC to conduct a risk assessment process and based on the results of the risk assessment, cleaning of vessels prior to construction may be required. CSLC concurred with the strategy and incorporated the proposed language. While vessel hull cleaning is still anticipated to be required, the cost is dramatically reduced by requiring a one-time cleaning in place of a cleaning for each of the 44 transport trips.
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ADVICE 4052-E (U 338-E) - 10 - August 8, 2019 RECORDED COSTS TO DATE Table 4 provides a breakdown by category of the recorded costs between April 2017 and April 2019. Table 4: Recorded Expense April 2017 to April 2019 (in Millions, 2016 $, 100% share) No. 7 Description Materials, Transportation, and Construction Mobilization and Demobilization of Construction Equipment Environmental Studies and Document Preparation Permitting Compliance Engineering, Construction Management, Construction Verification Contingency 8 Project Management Support 0.11 0.08 0.03 0 0.22 9 Total Costs 1.09 0.86 1.3 0 3.25 1 2 3 4 5 6 2017 2018 2019 2020 Total 0 0.11 0.55 0 0.66 0 0.31 0.3 0 0.61 0.55 0.05 0.06 0 0.66 0 0 0.07 0 0.17 0 0 0 0.24 0 0.43 0.24 0.19 0 0.86 0 0 0 0 0 Recap of 2019 Cost Estimate 100% share, 2016 $ 100% share, nominal SCE share4, nominal $ SCE share with FF&U $19.62 million $21.01 million $16.43 million $16.62 million COST RECOVERY SCE requests the approval of this Tier 3 AL presenting the updated cost estimate for the WNR Expansion Project. Upon CPUC’s approval of this AL, SCE will include a WNREP revenue requirement, including Franchise Fees & Uncollectibles (FF&U), of 4 SCE share for SONGS 2&3 Marine Mitigation projects is 78.21%.
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ADVICE 4052-E (U 338-E) - 11 - August 8, 2019 $16.62 million5 in January 1, 2020 rate levels though its year-end consolidated revenue requirement and rate change advice letter.6 As directed in D.18-03-027, SCE will submit a Tier 2 Advice Letter to report that the final recorded costs came in at or below the updated estimate and, if there is an overcollection, how it will be returned to customers. The decision provides that if at the completion of the Wheeler North Reef Expansion Project the recorded costs for the project are greater than the authorized cost forecast, SCE will submit testimony in its 2021 GRC to demonstrate these incremental expenses are reasonable for cost recovery.7 CONCLUSION SCE requests the approval of this Tier 3 Advice Letter presenting the updated cost estimate for the Wheeler North Reef Expansion Project (Option 1), pursuant to D.18-03-027, Ordering Paragraphs 7.c and 7.d. Upon approval of this Tier 3 Advice Letter, SCE requests authorization of a revenue requirement for Southern California Edison based upon the updated cost estimate. TIER DESIGNATION Pursuant to D.18-03-027, this advice letter is submitted with a Tier 3 designation. EFFECTIVE DATE This advice filing will become effective upon CPUC approval. 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 August 28, 2019, which is 20 days after the date of this advice letter. Protests should be mailed to: 5 6 7 $16.43 million in costs plus $0.19 million in FF&U expense based on the 2018 GRC D.1905-020 authorized FF&U rate. SCE will transfer the balance in the WNREP Memorandum Account (WNREPMA) to its Base Revenue Requirement Balancing Account (which will include interest accrued to date in the WNREPMA) with the authorized revenue requirement collected in base rates. SCE will continue tracking actual costs in the WNREP memorandum account in order to determine overspend (excluding interest), if any, above the authorized amount. Given that the WNR Expansion Project is forecast to be completed in late 2020 (after SCE will submit its 2021 GRC application in 2019), SCE proposes submitting this testimony, if required, in its ERRA Review or other application designated by the Commission.
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ADVICE 4052-E (U 338-E) - 12 - August 8, 2019 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 Facsimile: (626) 302-6396 Telephone: (626) 302-9645 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: With a copy to: Jose L. Perez Principal Manager, Nuclear CPUC Regulatory Affairs and Compliance Southern California Edison Company 2244 Walnut Grove Avenue Rosemead, California 91770 Telephone: (949) 368-9133 E-mail: There are no restrictions on who may file 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 4052-E (U 338-E) - 13 - August 8, 2019 In accordance with General Rule 4 of GO 96-B, SCE is serving copies of this advice filing to the interested parties shown on the attached GO 96-B, A.12-12-012 et al, I.12-10-013, A.14-12-007, A.15-01-014, A.16-03-004, and A.16-12-002 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 filing and keeping the advice filing at SCE’s corporate headquarters. To view other SCE advice letters filed with the CPUC, log on to SCE’s web site at For questions, please contact Jose Perez by telephone at (949) 368-9133 or by electronic mail at Southern California Edison Company /s/ Gary A. Stern, Ph.D. Gary A. Stern, Ph.D. GAS:wam:jm
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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: 3 Advice Letter (AL) #: 4052-E Subject of AL: Update of Cost Estimate for Wheeler North Reef Expansion Project Keywords (choose from CPUC listing): Compliance AL Type: Monthly Quarterly Annual One-Time Other: If AL submitted in compliance with a Commission order, indicate relevant Decision/Resolution #: Decision 18-03-027 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: 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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