Details for: SCE Comments to Draft Resolution E-5136 (SCE Advice 4289-E).pdf

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

April 1, 2021

Energy Division
California Public Utilities Commission
505 Van Ness Avenue
San Francisco, CA 94102


Comments of Southern California Edison Company on Draft
Resolution E-5136 that Approves, with Modifications, SCE
Advice Letter 4289-E to Modify Rule 23 and Schedule
CCA-INFO to Implement Settlement Agreement to Expand
Data Sharing with Community Choice Aggregators

Dear Energy Division,
Pursuant to Rule 14.5 of the Rules of Practice and Procedure of the California Public
Utilities Commission (Commission or CPUC), Southern California Edison Company
(SCE) hereby submits its Comments on Draft Resolution E-5136 (Draft Resolution).
The Draft Resolution proposes to approve with modification SCE’s tariff revisions to
expand data sharing with Community Choice Aggregators (CCAs) in SCE’s territory.
SCE supports the Draft Resolution. SCE provides these comments to seek clarification
regarding two points raised by the Draft Resolution. First, SCE interprets the Draft
Resolution as only prohibiting the provision of Direct Access (DA) customer data in the
All-Customer List that SCE will provide after CCA implementation. Prior to CCA
implementation, during the investigation and exploration stages, SCE already provides
an eligible customer list that necessarily includes DA customer information in the
potential CCA’s service territory, because potential CCAs need that information to
explore CCA formation, understand its resource adequacy (RA) requirements, and
develop customer notice lists, among other reasons.1 To avoid any potential confusion,
absent further clarification in the resolution, SCE will continue to operate as if the Draft
Resolution does not alter the scope of the pre-implementation list.
Second, SCE requests that the Draft Resolution be modified so that the Commission
orders the required Rule 23 tariff modification be submitted as a Tier 1 supplemental

See Decision (D.)04-12-046, pp. 51-52 and Ordering Paragraph (OP) 5 (item #13) (requiring
the IOUs to provide all customer information under a non-disclosure agreement prior to CCA

P.O. Box 800

8631 Rush Street

Rosemead, California 91770

(626) 302-9645

Fax (626) 302-6396


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Energy Division Page 2 April 1, 2021 advice letter. A Tier 1 advice letter is appropriate in this circumstance pursuant to General Order (GO) 96-B, Rule 5.1.2 Specifically, SCE proposes the following modification:3 p. 8 [OP 3] Southern California Edison Company (SCE) shall submit a supplemental advice letter with a Tier 1 designation to modify SCE’s Rule 23 and Schedule CCA-INFO to indicate that the All-Customer List will exclude Direct Access customer service accounts and associated customer data. CONCLUSION SCE appreciates the opportunity to submit these comments, and respectfully requests that the Commission make the clarification and modification to the Draft Resolution as explained herein. Southern California Edison Company /s/ Gary A. Stern Gary A. Stern, Ph.D. GAS:dv:cm cc: 2 3 Edward Randolph, Director, CPUC Energy Division Dina Mackin, Supervisor, CPUC Energy Division David Oliver, Sr. Analyst, CPUC Energy Division Daniel W. Douglass, Attorney for the Direct Access Customer Coalition Service Lists R.17-06-026, R.03-10-003, R.12-02-009, R.12-06-013, R.16-02-007, and R.17-09-020, as well as contacts for current and prospective CCAs currently on record within SCE’s territory. GO 96-B Rule 5.1(1) states that a matter appropriate to a Tier 1 advice letter is: “A tariff change in compliance with specific requirements of a statute or Commission order where the wording of the changes follows directly from the statute or Commission order.” Proposed text deletions are in bold strikethrough (abcd) and proposed text additions are in bold with underline (abcd).
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