Details for: 4343-E (Part 1 of 1).pdf


Click on the image for full size preview

Document data

5ttt

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

November 16, 2020
ADVICE 4343-E
(U 338-E)
PUBLIC UTILITIES COMMISSION OF THE STATE OF CALIFORNIA
ENERGY DIVISION
SUBJECT:

I.

Southern California Edison Company’s Request for Approval to
Exclude Remaining Candidate Deferral Opportunities from the
2021 Distribution Investment Deferral Framework Solicitation

INTRODUCTION
1.

Purpose of Advice Letter

Pursuant to Decision (D.)18-02-004 (Decision), Southern California Edison Company
(SCE) submitted a separate Advice Letter1 seeking California Public Utilities
Commission (Commission or CPUC) approval to launch the 2021 Distribution
Investment Deferral Framework (DIDF) Request for Offers (RFO) to procure distributed
energy resources (DERs) that can defer specific traditional distribution projects.
Pursuant to the Administrative Law Judge’s Ruling Modifying the Distribution Investment
Deferral Framework -- Filing and Process Requirements, issued May 11, 2020 and
modified June 12, 2020 in Revised Attachment A, hereafter referred to as the May 2020
ruling, SCE submits this Advice Letter seeking Commission approval to exclude in the
2021 DIDF RFO process any remaining candidate deferral opportunities as put forward
in SCE’s 2020 Distribution Deferral Opportunities Report (DDOR).
Background
On February 15, 2018, the Commission issued D.18-02-004. The Decision adopted an
annual DIDF process to solicit cost-effective DERs that could defer traditional
distribution infrastructure projects. As part of that annual process, D.18-02-004 ordered
the Investor Owned Utilities (IOUs) to submit a DDOR which would be vetted by a
DPAG.2 Through this process, the IOUs identified candidate projects to include in the
competitive solicitation. Consistent with the Decision, SCE is submitting a Tier 2 Advice
Letter requesting approval of the selected distribution deferral projects to include in the
1
2

Advice 4342-E
On May 7, 2019, the Commission issued an Administrative Law Judge’s ruling addressing
party comments to improve the DIDF process that expanded the requirements of the Grids
Needs Assessment (GNA) and DDOR and made modifications to role of the DPAG and
IPE.

P.O. Box 800

8631 Rush Street

Rosemead, California 91770

(626) 302-9645

Fax (626) 302-6396





- Page 1 -

ADVICE 4343-E (U 338-E) -2- November 16, 2020 upcoming 2021 DIDF RFO.3 Reform #40 of the May 2020 ruling added a requirement that SCE file this Advice Letter seeking Commission approval to exclude in the 2021 DIDF RFO process any remaining candidate deferral opportunities from SCE’s 2020 DDOR. II. DISTRIBUTION PLANNING ADVISORY GROUP AND 2021 DIDF RFO PROJECT RECOMMENDATIONS D.18-02-004 required the formation of the DPAG to advise the Utilities on distribution deferral opportunities that would result in cost effective deferrals and successful solicitations. Each utility’s DPAG was comprised of the utility, Commission technical staff, market participants, and stakeholders including ratepayer, environmental, community, and clean technology advocates. In addition, an Independent Professional Engineer (IPE) was hired and included in all DPAG meetings as a technical consultant. The Joint IOUs hosted a virtual DPAG Primer on September 14, 2020 that provided an overview of the DIDF process, the role of the IPE, the GNA and DDOR reports, and how IOUs identify and prioritize deferral projects. On September 15, 2020, SCE hosted a virtual DPAG meeting where SCE provided an overview of its planning assumptions, a review of the grid needs reported in the GNA, and planned investments and candidate deferral opportunities reported in the DDOR. SCE further provided candidate deferral prioritization and metrics, underlying technical and operational requirements, and proposed contingency planning. At its DPAG meeting, SCE reviewed three tiers of candidate projects and recommended that three of the four Tier 1 candidate projects be selected for solicitation. The Tier 1 project not selected for solicitation is the Alberhill System Project which is a postapplication licensing project. DPAG participants did not oppose the Tier 1 candidates; however, in its DPAG Report, the IPE recommended that SCE consider the inclusion of two Tier 3 projects. Upon receiving updated information, SCE has decided to move forward with two of the original three Tier 1 candidate projects recommended for solicitation at the DPAG meeting. SCE does not recommend including the New Circuit at El Casco Substation project in the 2021 DIDF RFO. SCE’s reasons for excluding this project from the 2021 DIDF RFO are discussed further below. Per the May 7, 2019 and April 13, 2020 Rulings, DPAG participants were invited to submit questions and comments to SCE and the IPE via email or web survey by September 25, 2020. SCE received comments and questions from three parties who broadly supported SCE’s Tier 1 candidate deferral projects and did not recommend any additional projects for deferral consideration. DPAG participant input and SCE’s responses were shared with the IPE and Energy Division for further consideration in the IPE DPAG report. A DPAG follow-up webinar on October 14, 2020 was held to provide 3 Advice 4342-E (AL launching the 2021 DIDF RFO)
- Page 2 -

ADVICE 4343-E (U 338-E) -3- November 16, 2020 responses to outstanding questions from SCE’s DPAG and questions SCE received in the post-DPAG surveys. III. PROJECTS SCE DOES NOT RECOMMEND FOR DIDF RFO To obtain a list of Candidate Deferral projects, SCE applied technical and timing screens to the Planned Investments list in its 2020 DDOR. The screens were applied using the most recent information available from SCE’s 2020 distribution planning process. The two screens are explained below: 1. Technical Screen: This screen reviewed each Planned Investment to determine if DERs could provide the required distribution service(s): capacity (including underground cable temperature needs), voltage support (reactive power and voltage), reliability (back-tie), and resiliency (microgrid). 2. Timing Screen: This screen reviewed whether a DER solution could be evaluated, procured, deployed and begin commercial operation before the forecasted date the Planned Investment will be in service. For the 2020 DDOR, SCE determined that project operating dates in 2023 and 2024 provide the highest likelihood of successful deferral. This timeframe provides the highest likelihood of success for a DER solution to be implemented considering interconnection processes and construction timelines. This timeframe also considers the development and potential execution of a contingency alternative. A. DIDF Prioritization Metrics SCE applied three prioritization metrics to identify Candidate Deferral projects with the highest likelihood of successful deferral, consistent with D.18-02-004. Each Candidate Deferral project was assigned a score within each prioritization metric. Each prioritization metric was weighted equally. As presented at the September 15, 2020 DPAG Meeting, SCE utilized the prioritization metrics to quantitatively rank the Candidate Deferral projects to produce a tiered recommendation. The prioritization metrics are explained below: 1. Cost Effectiveness: The cost effectiveness metric evaluates Locational Net Benefit Analysis (LNBA) values in MW and in MWh. The LNBA in MW considers the capacity need to defer a Candidate Deferral project while the LNBA in MWh considers the energy need to defer a Candidate Deferral project. Projects with higher LNBA values are scored higher than projects with lower LNBA values. This metric serves as an input to the overall project prioritization and is not intended to inform the deferral value. 2. Forecast Certainty: The forecast certainty metric considers the likelihood that the load growth driving a grid need will materialize and the year in which the need first occurs. Projects with nearer term needs are scored higher than projects with longer term needs. Projects with a higher likelihood of the load growth driving the need materializing (i.e. higher Level of Certainty score) are
- Page 3 -

ADVICE 4343-E (U 338-E) -4- November 16, 2020 scored higher than projects with lower likelihood of the load growth materializing. 3. Market Assessment: The market assessment metric evaluates the duration of a grid need and the amount of resources a DER developer would need to procure in a given geographical area. The amount of resources a DER developer would need to procure is approximated by the average amount of DERs required per circuit. Projects with a shorter duration of grid needs are scored higher than projects with longer duration of grid needs. Projects with smaller grid needs per circuit are scored higher than projects with larger grid needs per circuit. A large amount of grid need per circuit presents more of a challenge for DER developers to enroll sufficient numbers of customers in programs or find suitable interconnection points. B. Tier 2 Projects (Not Selected for Solicitation) The table below presents the classification of Candidate Deferral projects into three tiers based on the three prioritization metrics with additional practical considerations that each prioritization metric may not capture. Table 1 Tiered candidate deferral projects. Tier Project Alberhill System Project New Circuit at Elizabeth Lake Substation 1 New Circuit at El Casco Substation New Circuit at Sun City Substation Saugus-Colossus-Lockheed-Pitchgen Subtransmission Line Reconductor 2 Saugus-E Lake-MWD Foothill Subtransmission Line Reconductor Slate Circuit Line Reconductor New Circuit at Garnet Substation New Circuit at Farrell Substation New Circuit at Saugus Substation 3 Capacitor Addition at Edwards Substation Kramer - Holgate / Edwards - Holgate - Southbase Subtransmission Line Reconductor Del Valle 66/16kV Substation Project Kramer-Edwards Subtransmission Line Project CostEffectiveness Forecast Certainty Market Assessment
- Page 4 -

ADVICE 4343-E (U 338-E) -5- November 16, 2020 SCE does not recommend the following candidate deferral projects for solicitation. • The Alberhill System Project (ASP) scores highest relative to the other candidate deferral projects in the cost effectiveness and market assessment metrics but has a third quartile forecast certainty score. Although the cost effectiveness and market assessment scores for this project are high, these scores do not accurately quantify or capture the full scope of this project. Qualitative assessments must be taken into consideration in evaluating this project’s suitability for deferral. This project’s cost effectiveness score is calculated using the total project cost (inclusive of both the capacity and reliability/resiliency aspects of the project’s scope), but the needs included within SCEs prioritization calculations only consider the capacity component of the ASP need, as the reliability/resiliency needs cannot be quantified. As a result, the large LNBA values driving the high cost effectiveness score for this project are inflated. Similarly, this project’s market assessment score only captures its capacity component when assessing the duration and geographic area. DERs cannot defer the reliability/resiliency needs addressed by the Alberhill System Project and, therefore, those reliability/resiliency needs are unable to be quantified in SCE’s prioritization analysis. As stated in SCE’s 2020 GNA/DDOR narrative,4 the ASP is a comprehensive solution to address both the capacity need and reliability need of the Valley South System Electrical Needs Area. There are few (if any) scope elements that can be characterized as serving either only the capacity or only the reliability/resiliency portion of the project. Any DER procured through the DIDF process cannot defer the reliability and resiliency needs of the ASP. In addition, since the ASP is a post-application project, it is subject to alternative review within its own proceeding. Lastly, within its GNA/DDOR narrative, SCE proposed a DIDF modification regarding treatment of pre-application and post application projects within the DIDF considering they are subject to their own separate procedural processes.5 SCE recommends that all projects that require a Certificate of Public Convenience and Necessity (CPCN) or are already a postapplication project be exempt from the DIDF RFO process and be included in the GNA/DDOR for information only. All pre-application projects that do not require a CPCN should be subject to the DIDF process and be considered as DER deferral 4 5 SCE’s 2020 GNA and DDOR Narrative, at 66. SCE’s 2020 GNA and DDOR Narrative, at 10.
- Page 5 -

ADVICE 4343-E (U 338-E) -6- November 16, 2020 candidates. • • The Saugus-Colossus-Lockheed-Pitchgen 66 kV Subtransmission Line Reconductor Project is a Tier 2 project and was included in the 2020 DIDF RFO; SCE has executed a contract to defer this project. • The Saugus-E Lake-MWD Foothill Subtransmission Line Reconductor Project is a Tier 2 project and was included in the 2020 DIDF RFO; SCE has executed a contract to defer this project. • 6 The New Circuit at El Casco Substation Project had first quartile cost effectiveness and market assessment scores and a second quartile forecast certainty score, as of SCE’s August 17, 2020 DDOR and Joint Prioritization Metrics Workbook Template filing. However, updates provided by planning engineers to the cost of traditional mitigation for this project significantly lowered its total cost from approximately $4M to approximately $350K.6 This significant decrease in total cost will reduce the cost cap to a point that a DER provider’s bid is highly unlikely to be more cost effective than the proposed traditional mitigation. SCE does not recommend including a project within its DIDF RFO that has a high likelihood of being unsuccessful. Therefore, SCE does not recommend this project for solicitation in the 2021 DIDF RFO. The Slate Circuit Line Reconductor Project has a second quartile cost effectiveness score, a fourth quartile forecast certainty score, and a first quartile market assessment score. The high market assessment score for this project is primarily driven by its low duration of needs (4 hours) due to residential load growth in the area and a small amount of need forecasted per circuit (0.87MW/Circuit). This small amount of need per circuit represents more opportunity for DER developers to enroll sufficient numbers of customers in programs or find suitable interconnection points in the need area. The IPE recommended in its report that this project should be considered for inclusion in the 2021 DIDF RFO due to its borderline forecast certainty score, which is similar to the forecast certainty scores of the Tier 2 projects. However, this project has an overall very low cost of traditional mitigation of approximately $500K. Accordingly, it is readily apparent to SCE that, regardless of the likelihood of the project needs materializing or how large the DER market may be, a bid is highly unlikely to be more cost effective than the proposed traditional mitigation. SCE refreshed costs for its recommended Tier 1 Candidate Deferral projects to represent the most accurate cost information possible. However, SCE did not refresh its prioritization metrics based on the updated cost information.
- Page 6 -

ADVICE 4343-E (U 338-E) -7- November 16, 2020 Therefore, SCE does not recommend this project for solicitation in the 2021 DIDF RFO. • The New Circuit at Garnet Substation Project has a fourth quartile cost effectiveness score, a first quartile forecast certainty score, and a third quartile market assessment score. The Tier 3 ranking for this project is driven by its low cost effectiveness score which is a result of the project’s low LNBA values, due to the project’s large needs. In addition, the low market assessment score for this project is driven by a relatively long duration of needs (15 hours) due to the demand consumption profile of cultivation projects driving the grid needs and a large amount of need forecasted per circuit(9.30MW/Circuit). This large amount of need per circuit indicates that it would be more challenging for DER developers to enroll sufficient numbers of customers in programs or find suitable interconnection points in the need area. This large and sustained level of need would be extremely difficult to mitigate with a DER. • The New Circuit at Farrell Substation Project has a first quartile cost effectiveness score, the lowest forecast certainty score relative to the other ranked candidate deferral projects, and a low second quartile market assessment score. The high cost effectiveness score for this project is primarily driven by its high LNBA values, which are a function of the low capacity needs forecasted for this project. The IPE recommended in its report that this project be promoted to Tier 1 and included in the 2021 DIDF RFO on a conditional basis due to its high cost effectiveness score, contingent on the project’s updated forecast certainty score supporting its inclusion. The IPE added that the project should be reevaluated for inclusion in the DIDF RFO, after the Level of Certainty (LOC) matrix is updated with the most recent load forecast information in January 2021. However, in accordance with previous DIDF cycles, all capacity planning information must be complete prior to determining if the needs for this project still exist, which SCE anticipates completing in March 2021, rather than January 2021, several months after RFO launch. Regardless, in SCE’s view, updating the load forecast information alone is not sufficient to promote a project to Tier 1 and include it in the 2021 DIDF RFO solicitation. Load growth information alone is not an appropriate determination if a need still exists on the system. In addition, it would be inappropriate to use a 2021 forecast certainty score while using 2020 cost effectiveness and market assessment scores. The prioritization metrics must be utilized together with consistent planning information to determine if a project is a good candidate for DER deferral. Finally, the interconnection queue application period will close prior to SCE finishing its capacity planning process required to properly inform this
- Page 7 -

ADVICE 4343-E (U 338-E) -8- November 16, 2020 project’s ability to be deferred by DER. Accordingly, SCE believes this project should remain in Tier 3 for the 2020 DIDF cycle and be considered as a candidate for deferral in the 2021 GNA/DDOR, representing updated prioritization metrics. A good candidate deferral project requires balanced scores across all three prioritization metrics. • The New Circuit at Saugus Substation Project has low third quartile cost effectiveness and market assessment scores and a fourth quartile forecast certainty score. The low cost effectiveness score for this project is driven by its low LNBA values, which are partly a function of the project’s high needs. The low market assessment scores for this project are driven by its long duration of needs (18 hours) due to residential load growth and a large amount of need forecasted per circuit (8.08MW/Circuit). This large amount of need per circuit indicates that it would be more challenging for DER developers to enroll sufficient numbers of customers in programs or find suitable interconnection points in the need area. Finally, the project’s low forecast certainty score is a result of its below average LOC score, which represents a low likelihood of load growth. The large and sustained level of needs for this project, combined with the uncertainty associated with the project needs materializing, make this project a weak candidate for deferral by DER. • The Capacitor Addition at Edwards Substation Project has the lowest cost effectiveness score of the candidate deferral projects, a third quartile forecast certainty score, and a low third quartile market assessment score. The low cost effectiveness score for this project is driven by its low LNBA values, which are a function of the relatively large needs and low cost of traditional mitigation for this project. The low forecast certainty score is driven by the project’s below average LOC, which represents a low likelihood of load growth. Finally, the low market assessment score for this project is due to its long duration of needs (24 hours) driven by cultivation demand profiles and a large amount of need forecasted per circuit (45.70MW/Circuit). This large amount of need per circuit indicates that it would be more challenging for DER developers to enroll sufficient numbers of customers in programs or find suitable interconnection points in the need area. The large and sustained level of needs for this project, combined with its low cost of traditional mitigation, indicate a highly unlikely probability that a DER solution will be cost effective compared to the proposed traditional mitigation. • The Kramer-Holgate / Edwards-Holgate-Southbase Subtransmission Line Reconductor Project has fourth quartile cost effectiveness and market assessment scores and a third quartile forecast certainty score. The driver for the low cost effectiveness score is the large capacity needs for this project which
- Page 8 -

ADVICE 4343-E (U 338-E) -9- November 16, 2020 result in a low LNBA score. The low market assessment score is a result of the long duration large energy needs (24 hours) driven by cultivation demand profiles and a large amount of need forecasted per circuit (56.10MW/Circuit). This large amount of need per circuit indicates that it would be more challenging for DER developers to enroll sufficient numbers of customers in programs or find suitable interconnection points in the need area. Finally, the low forecast certainty score for this project is due to its below average LOC score. The large and sustained level of needs for this project, combined with the uncertainty associated with the project needs materializing, make this project a weak candidate for deferral by DER. • The Del Valle 66/16 kV Substation Project has a low second quartile cost effectiveness score and a third quartile market assessment score. The low cost effectiveness score for this project is driven by the large capacity needs for this project which result in a low LNBA score. The low market assessment score is due to the long duration energy needs (24 hours) driven by residential and commercial load growth and a large amount of need forecasted per circuit (48.56 MW/Circuit). This large amount of need per circuit indicates that it would be more challenging for DER developers to enroll sufficient numbers of customers in programs or find suitable interconnection points in the need area. The forecast certainty score for this project is required to be excluded in its prioritization score per the May 11, 2020 Ruling. The large capacity and sustained level of energy needs for this project make it a weak candidate for deferral by DER. • The Kramer-Edwards Subtransmission Line Project has a second quartile cost effectiveness score and the lowest market assessment score of all the candidate deferral projects. The low cost effectiveness score for this project is driven by its large capacity needs which results in a low LNBA score. The low market assessment score is due to the long duration energy needs (24 hours) driven by cultivation demand consumption and a large amount of need forecasted per circuit (68.09 MW/Circuit). This large amount of need per circuit indicates that it would be more challenging for DER developers to enroll sufficient numbers of customers in programs or find suitable interconnection points in the need area. The forecast certainty score for this project was requested to be excluded in its prioritization per the May 11, 2020 Ruling. The large and sustained level of needs for this project make it a weak candidate for deferral by DER.
- Page 9 -

ADVICE 4343-E (U 338-E) IV. - 10 - November 16, 2020 REQUEST FOR COMMISSION APPROVAL SCE requests that the Commission approve this Advice Letter through an Energy Division disposition within 30 days of the submission of this Advice Letter, including the adoption of the following findings:7 1. V. Approval for SCE to not launch its DIDF RFO for remaining candidate deferral projects as described in this Advice Letter. TIER DESIGNATION Pursuant to GO 96-B, Energy Industry Rule 5.2 and D.18-02-004 this Advice Letter is submitted with a Tier 2 designation. VI. EFFECTIVE DATE This Advice Letter will be effective upon December 16, 2020, the 30th day after the date submitted. VII. NOTICE (Reg Affairs) 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 in accordance with the Energy Division’s schedule. Protests should be submitted to: CPUC, Energy Division Attention: Tariff Unit 505 Van Ness Avenue San Francisco, California 94102 E-mail: EDTariffUnit@cpuc.ca.gov Copies should also be mailed to the attention of the Director, Energy Division, Room 4004 (same address above). In addition, protests 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 7 SCE requests that any summary disposition by Energy Division approving the content of this Advice Letter be deemed to have adopted the requested findings.
- Page 10 -

ADVICE 4343-E (U 338-E) - 11 - November 16, 2020 Facsimile: (626) 302-6396 E-mail: AdviceTariffManager@sce.com Tara S. Kaushik Managing Director, Regulatory Relations c/o Karyn Gansecki Southern California Edison Company 601 Van Ness Avenue, Suite 2030 San Francisco, California 94102 Facsimile: (415) 929-5544 E-mail: Karyn.Gansecki@sce.com 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. In accordance with General Rule 4 of GO 96-B, SCE is serving copies of this advice letter to the interested parties shown on the attached GO 96-B, R.14-10-003, and R.14-08-013 et al service lists. Address change requests to the GO 96-B service list should be directed by electronic mail to AdviceTariffManager@sce.com or at (626) 3024039. For changes to all other service lists, please contact the Commission’s Process Office at (415) 7032021 or by electronic mail at Process_Office@cpuc.ca.gov. 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 Commission, log on to SCE’s web site at https://www.sce.com/wps/portal/home/regulatory/advice-letters. For questions, please contact Eli Asher at (626) 302-7755 or by electronic mail at Eli.Asher@sce.com. Southern California Edison Company /s/ Gary A. Stern, Ph.D. Gary A. Stern, Ph. D GS:ea:jm Enclosures
- Page 11 -

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: AdviceTariffManager@sce.com E-mail Disposition Notice to: AdviceTariffManager@sce.com EXPLANATION OF UTILITY TYPE GAS = Gas WATER = Water HEAT = Heat (Date Submitted / Received Stamp by CPUC) Tier Designation: Advice Letter (AL) #: Subject of AL: 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 #: 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
- Page 12 -

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: EDTariffUnit@cpuc.ca.gov 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: advicetariffmanager@sce.com Name: Title: Utility Name: Southern California Edison Company Address: 601 Van Ness Avenue, Suite 2030 City: San Francisco State: California Zip: 94102 Telephone (xxx) xxx-xxxx: Facsimile (xxx) xxx-xxxx: (415) 929-5544 Email: karyn.gansecki@sce.com Clear Form
- Page 13 -

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
- Page 14 -