Details for: SCE Reply to Protest to Advice 4053-E.pdf


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

September 10, 2019
Energy Division
Attention: Tariff Unit
California Public Utilities Commission
505 Van Ness Avenue
San Francisco, CA 94102
SUBJECT:

Reply of Southern California Edison Company to the Public
Advocates Office Protest of Advice 4053-E, Proposed Energy
Savings Assistance Bridge Funding for January 1, 2021 through
June 30, 2021

Dear Energy Tariff Division Unit:
Pursuant to General Rule 7.4.3 of the California Public Utilities Commission’s
(Commission or CPUC) General Order (GO) 96-B, Southern California Edison
Company (SCE) hereby submits its reply to the protest of the Public Advocates Office at
the California Public Utilities Commission (Cal Advocates) to SCE’s Advice Letter (AL)
4053-E (Protest).
Background
On June 28, 2019, the Commission issued Decision (D.)19-06-022, Issuing Guidance to
Investor-Owned Utilities for California Alternate Rates for Energy (CARE)/Energy
Savings Assistance (ESA) Program Applications for 2021-2026 and Denying Petition for
Modification (the Decision), which authorizes bridge funding for ESA program activity
from January 1, 2021 through June 30, 2021, if the Commission has not approved
program and budget applications for 2021 and beyond by November 16, 2020.1
Ordering Paragraph (OP) 3 of the Decision directed the four large Investor-Owned
Utilities (IOUs) to submit a Tier 1 AL within 45 days after issuance of the Decision with
calculations of their ESA bridge funding amount, source for bridge amounts and
retreatment goal for the January 1, 2021 - June 30, 2021 bridge period.2

1
2

SCE’s ESA program provides energy conservation assistance to SCE’s income-qualified
customers through the installation of energy efficient measures.
The large investor-owned utilities are SCE, Pacific Gas and Electric Company, San Diego
Gas & Electric Company and Southern California Gas Company.

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 September 10, 2019 Page 2 Consistent with OP 3, SCE submitted AL 4053-E on August 12, 2019. On September 3, 2019, Cal Advocates submitted its Protest to AL 4053-E. SCE hereby replies to the Protest. SCE’s Bridge Funding Proposal for Workforce Education and Training (WE&T) is a Prudent Request Intended to Avoid Interruption of Program Activities In its Protest, Cal Advocates states that “the Commission should not consider SCE’s WE&T plan and proposed budget through the advice letter process.”3 SCE did not propose a detailed WE&T plan or submit a request for new funding in its advice letter. Rather, because SCE was required to submit its bridge funding proposal prior to the advice letter of its 2021-2026 application, SCE needed to include the portion of WE&T budget necessary to cover the potential bridge period assuming that SCE’s proposal in its application would be adopted. This proposal for the transition of WE&T from Energy Efficiency to Income Qualified Programs (IQP) will be included in SCE’s 2021-2026 IQP application.4 SCE is not requesting the Commission to rule on the merits of its WE&T proposal through the AL process, but rather to provide bridge funding for WE&T activities, assuming the Commission does not issue a Decision by November 16, 2020. As stated previously, SCE’s full proposal for WE&T transition will be included in its forthcoming 2021-2026 IQP application, and the Commission and all parties will have the opportunity to consider the merits of the program transition as a part of that proceeding. If the Commission does not adopt SCE’s proposal as part of that proceeding, no bridge funding for the WE&T program will be necessary for SCE’s IQP. As such, SCE’s proposal to include WE&T funds in a potential bridge period should be adopted. 3 4 Cal Advocates Protest, p. 3. Advice 4053-E, p. 5.
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Energy Division California Public Utilities Commission September 10, 2019 Page 3 Conclusion SCE appreciates the opportunity to submit this reply to Cal Advocates’ Protest. Sincerely, /s/ Gary A. Stern Gary A. Stern, Ph.D. cc: Edward Randolph, Director, CPUC Energy Division Franz Cheng, CPUC Energy Division Michael Campbell, Public Advocates Office Karl Stellrecht, Public Advocates Office Service List for A.14-11-007
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