BEFORE THE PUBLIC UTILITIES COMMISSION OF THE
STATE OF CALIFORNIA
Joint Application of San Diego Gas & Electric
Company and Southern California Gas Company
(E-3921) for: Adoption of Their Residential Electric
and Gas Line Extension Allowance Methodologies
and its Monthly Ownership Charge Methodology.
A.05-09-019
(Filed September 14, 2005)
Application of Pacific Gas and Electric Company in
Response to Resolution E-3921, Proposing
Revisions to Line Extension Allowance and Related
Matters. (U 39M)
A.05-10-016
(Filed October 13, 2005)
Application of Southern California Edison Company
(U 338-E) Regarding Residential Line and Service
Extension Allowances.
A.05-10-019
(Filed October 14, 2005)
SOUTHERN CALIFORNIA EDISON COMPANY'S OPENING COMMENTS TO
PROPOSED DECISION OF ALJ O'DONNELL
MICHAEL D. MONTOYA
MARICRUZ PRADO
Attorneys for
SOUTHERN CALIFORNIA EDISON COMPANY
2244 Walnut Grove Avenue
Post Office Box 800
Rosemead, California 91770
Telephone:
(626) 302-6943
Facsimile:
(626) 302-6974
E-mail:
[email protected]
Dated: June 04, 2007
LAW #1367792 v1
BEFORE THE PUBLIC UTILITIES COMMISSION OF THE
STATE OF CALIFORNIA
Joint Application of San Diego Gas & Electric
Company and Southern California Gas Company
(E-3921) for: Adoption of Their Residential Electric
and Gas Line Extension Allowance Methodologies
and its Monthly Ownership Charge Methodology.
A.05-09-019
(Filed September 14, 2005)
Application of Pacific Gas and Electric Company in
Response to Resolution E-3921, Proposing
Revisions to Line Extension Allowance and Related
Matters. (U 39M)
A.05-10-016
(Filed October 13, 2005)
Application of Southern California Edison Company
(U 338-E) Regarding Residential Line and Service
Extension Allowances.
A.05-10-019
(Filed October 14, 2005)
SOUTHERN CALIFORNIA EDISON COMPANY'S OPENING COMMENTS TO
PROPOSED DECISION OF ALJ O'DONNELL
Pursuant to Rule 14.3 of the California Public Utilities Commission’s (Commission)
Rules of Practice and Procedure, Southern California Edison Company (SCE) hereby submits the
following comments on the proposed decision of ALJ O’Donnell (Proposed Decision), mailed on
May 10, 2007. On May 29, 2007, ALJ O’Donnell granted the parties to this proceeding an
extension to file comments to the Proposed Decision from May 30, 2007, to June 4, 2007, thus,
these comments are timely filed.
I.
COMMENTS
The Proposed Decision refines the calculation of line extension allowances, and the cost
of ownership (COO) charges applicable to refundable costs in excess of the line extension
-1-
allowance, for Pacific Gas and Electric Company (PG&E), SCE, San Diego Gas & Electric
Company (SDG&E), and Southern California Gas Company (SCG). SCE supports the Proposed
Decision and requests that the Commission issue the Proposed Decision with the following
technical changes:
•
Page 8, first and second line and Page 33, middle of second full paragraph: The
Proposed Decision states, respectively, “The COO charge is deducted from the
refundable amount.” and “The monthly COO charge is deducted from the amount
of refundable line extension costs.” These statements do not accurately describe
SCE’s method of collecting COO charges. SCE does not know whether such
statements accurately describe the methods used by PG&E and SDG&E to collect
COO charges. The following sentences should be added to the pages at issue:
“When SCE determines that the applicant is owed a refund
and COO charges have been assessed against the applicant,
rather than trading checks in the mail, SCE simply deducts
the COO charges from the refund due to the applicant and
sends the applicant a check for the difference. When no
refunds are owed to the applicant and COO charges have
been assessed, SCE directly bills the applicant the COO
charges due.”
•
SCE requests that the following clarifications be made with respect to the impact
of electric rate discounts on the electric net revenue calculation, consistent with
the discussion found on page 20 of the Proposed Decision:
o Page 3, second bullet point: The phrase “the revenue effect of the
discount shall be excluded from the calculation of average distribution
revenue per residential customer” should be revised so that the complete
bullet point reads as follows:
“If the cost of an electric distribution rate discount is not
included in residential electric distribution rates, but
recovered separately from residential customers through a
surcharge, the revenue reduction due to the discount shall
-2-
be excluded from the calculation of average distribution
revenue per residential customer.”
o Page 53, Conclusions of Law # 5: The phrase “the discount should be
excluded from the electric net revenue calculation” should be revised so
that Conclusions of Law #5 reads as follows:
“Since residential rate discounts are usually paid for by
other residential customers, if the cost of a discount is not
included in residential rates, but recovered separately from
residential customers through a surcharge, the revenue
reduction due to the discount should be excluded from the
electric net revenue calculation.”
o Page 56, Ordering Paragraph #3: The phrase “the revenue effect of the
discount shall be excluded from the calculation of average electric
distribution revenue per residential customer” should be revised so that the
complete Ordering Paragraph #3 reads as follows:
“If the cost of an electric distribution rate discount is not
included in residential electric distribution rates, but
recovered separately from residential customers through a
surcharge, the revenue reduction due to the discount shall
be excluded from the calculation of average electric
distribution revenue per residential customer.”
•
Page 19, fourth line: This line contains a typographical error. The word “that”
should be replaced with the word “than.”
•
Page 35, second sentence of second full paragraph: This sentence contains a
typographical error. The phrase “utility-financed” should be replaced with the
phrase “customer-financed.” The new sentence should read as follows:
“SCE’s COO calculation assumes the facilities will be
customer-financed with replacement at additional cost to
the customer.”
-3-
II.
CONCLUSION
For the foregoing reasons, SCE respectfully requests that the Proposed Decision be
modified to incorporate the changes requested herein.
Respectfully submitted,
MICHAEL D. MONTOYA
MARICRUZ PRADO
By:
/s/ Maricruz Prado
Maricruz Prado
Attorneys for
SOUTHERN CALIFORNIA EDISON COMPANY
2244 Walnut Grove Avenue
Post Office Box 800
Rosemead, California 91770
Telephone:
(626) 302-6943
Facsimile:
(626) 302-6974
E-mail:
[email protected]
June 04, 2007
-4-
CERTIFICATE OF SERVICE
I hereby certify that, pursuant to the Commission’s Rules of Practice and Procedure, I
have this day served a true copy of SOUTHERN CALIFORNIA EDISON COMPANY'S
OPENING COMMENTS TO PROPOSED DECISION OF ALJ O'DONNELL on all parties
identified on the attached service list(s). Service was effected by one or more means indicated
below:
Transmitting the copies via e-mail to all parties who have provided an e-mail address.
First class mail will be used if electronic service cannot be effectuated.
Executed this 4th day of June, 2007, at Rosemead, California.
__/s/__Melissa Schary_________________________
MELISSA SCHARY
PROJECT ANALYST
SOUTHERN CALIFORNIA EDISON COMPANY
2244 Walnut Grove Avenue
Post Office Box 800
Rosemead, California 91770
A.05-10-019
Monday, June 4, 2007
A.05-10-019
GEORGETTA J. BAKER
ATTORNEY AT LAW
SAN DIEGO GAS & ELECTRIC/SOCAL GAS
101 ASH STREET, HQ 13
SAN DIEGO, CA 92101
DAN L. CARROLL
ATTORNEY AT LAW
DOWNEY BRAND LLP
555 CAPITOL MALL, 10TH FLOOR
SACRAMENTO, CA 95814
SEAN CASEY
SAN FRANCISCO PUBLIC UTILITIES
COMMISSIO
1155 MARKET STREET, 4TH FLOOR
SAN FRANCISCO, CA 94103
CASE ADMINISTRATION
SOUTHERN CALIFORNIA EDISON COMPANY
2244 WALNUT GROVE AVENUE
ROSEMEAD, CA 91770
A.05-10-019
SHEILA DEY
WESTERN MANUFACTURED HOUSING
COMMUNITIES
455 CAPITOL MALL STE 800
SACRAMENTO, CA 95814
A.05-10-019
LYNN HAUG
ELLISON, SCHNEIDER & HARRIS, LLP
2015 H STREET
SACRAMENTO, CA 95816
A.05-10-019
CHRISTOPHER J. MAYER
MODESTO IRRIGATION DISTRICT
1231 11TH STREET
MODESTO, CA 95354
A.05-10-019
JACQUELINE P. MINOR
ATTORNEY AT LAW
CITY AND COUNTY OF SAN FRANCISCO
CITY HALL, ROOM 375
SAN FRANCISCO, CA 94102
A.05-10-019
Page 1 of 2
A.05-10-019
A.05-10-019
DAN GEIS
THE DOLPHIN GROUP
925 L STREET, SUITE 800
SACRAMENTO, CA 95814
A.05-10-019
Gregory Heiden
CALIF PUBLIC UTILITIES COMMISSION
505 VAN NESS AVENUE
ROOM 5039
SAN FRANCISCO, CA 94102-3214
A.05-10-019
RICHARD MCCANN, PH.D
M.CUBED
2655 PORTAGE BAY, SUITE 3
DAVIS, CA 95616
A.05-10-019
STEPHEN A. S. MORRISON
ATTORNEY AT LAW
CITY AND COUNTY OF SAN FRANCISCO
1 DR. CARLTON B. GOODLETT PLACE, RM
234
SAN FRANCISCO, CA 94102
A.05-10-019
DANIEL M. BERMAN
CALIF PUBLIC UTILITIES COMMISSION
505 VAN NESS AVENUE
ROOM 4209
SAN FRANCISCO, CA 94102
A.05-10-019
Christopher Danforth
CALIF PUBLIC UTILITIES COMMISSION
505 VAN NESS AVENUE
ROOM 4209
SAN FRANCISCO, CA 94102-3214
A.05-10-019
HOWARD V. GOLUB
NIXON PEABODY LLP
2 EMBARCADERO CENTER, STE. 2700
SAN FRANCISCO, CA 94111
A.05-10-019
CARL C. LOWER
THE POLARIS GROUP
717 LAW STREET
SAN DIEGO, CA 92109-2436
A.05-10-019
KAREN MILLS
CALIFORNIA FARM BUREAU FEDERATION
2300 RIVER PLAZA DRIVE
SACRAMENTO, CA 95833
A.05-10-019
JUDI MOSLEY
ATTORNEY AT LAW
PACIFIC GAS AND ELECTRIC COMPANY
77 BEALE STREET, B30A
SAN FRANCISCO, CA 94105
A.05-10-019
A.05-10-019
Monday, June 4, 2007
JEFF NAHIGIAN
JBS ENERGY, INC.
311 D STREET
WEST SACRAMENTO, CA 95605
A.05-10-019
JEFFREY P. O'DONNELL
ADMINISTRATIVE LAW JUDGE
CALIF PUBLIC UTILITIES COMMISSION
505 VAN NESS AVENUE
ROOM 5111
SAN FRANCISCO, CA 94102-3214
A.05-10-019
EDWARD G. POOLE
ATTORNEY AT LAW
ANDERSON & POOLE
601 CALIFORNIA STREET, SUITE 1300
SAN FRANCISCO, CA 94108-2818
A.05-10-019
JAMES D. SQUERI
ATTORNEY AT LAW
GOODIN, MACBRIDE, SQUERI, RITCHIE &
DAY
505 SANSOME STREET, SUITE 900
SAN FRANCISCO, CA 94111
ROXANNE PICCILLO
REGULATORY ANALYSIS
PACIFIC GAS AND ELECTRIC COMPANY
77 BEALE STREET, B8R
SAN FRANCISCO, CA 94105
A.05-10-019
MARICRUZ PRADO
ATTORNEY AT LAW
SOUTHERN CALIFORNIA EDISON COMPANY
2244 WALNUT GROVE AVENUE
ROSEMEAD, CA 91770
Rashid A. Rashid
CALIF PUBLIC UTILITIES COMMISSION
505 VAN NESS AVENUE
Legal Division ROOM 4107
SAN FRANCISCO, CA 94102-3214
A.05-10-019
A.05-10-019
NINA SUETAKE
THE UTILITY REFORM NETWORK
711 VAN NESS AVE., STE 350
SAN FRANCISCO, CA 94102
ANN L. TROWBRIDGE
DAY CARTER MURPHY LLC
3620 AMERICAN RIVER DRIVE, SUITE 205
SACRAMENTO, CA 95864
A.05-10-019
A.05-10-019
A.05-10-019
JOY A. WARREN
ATTORNEY AT LAW
MODESTO IRRIGATION DISTRICT
1231 11TH STREET
MODESTO, CA 95354
A.05-10-019
Page 2 of 2
GREGGORY L. WHEATLAND
ATTORNEY AT LAW
ELLISON, SCHNEIDER & HARRIS, LLP
2015 H STREET
SACRAMENTO, CA 95814
A.05-10-019
MRW & ASSOCIATES, INC.
1814 FRANKLIN STREET, SUITE 720
OAKLAND, CA 94612
A.05-10-019