Redline Edits Draft SCE Motion to Implement TO

UNITED STATES OF AMERICA
BEFORE THE
FEDERAL ENERGY REGULATORY COMMISSION
Southern California Edison Company
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Docket Nos. ER11-3697-000
ER11-3697-001
ER11-3697-003
UNOPPOSED MOTION FOR
IMPLEMENTATION OF INTERIM SETTLEMENT RATES AND
WAIVER OF TARIFF PROVISIONS AND
REQUEST FOR EXPEDITED CONSIDERATION AND
SHORTENED ANSWER PERIOD ON BEHALF OF
SOUTHERN CALIFORNIA EDISON COMPANY
To:
The Honorable Curtis L. Wagner, Jr.
Chief Administrative Law Judge
Pursuant to Rule 212 of the Rules of Practice and Procedure of the Federal Energy
Regulatory Commission (“FERC” or “Commission”), 18 C.F.R. § 385.212 (2013), and
Rule 307(a)(1)(iv) of the Commission’s Revised General Rules, 18 C.F.R.
§ 375.307(a)(1)(iv), Southern California Edison Company (“SCE”) submits this
Unopposed Motion for Implementation of Interim Settlement Rates and Waiver of Tariff
Provisions and Request for Expedited Consideration and Shortened Answer Period
(“Motion”). This Motion is required pursuant to Section 5.1 of the Offer of Settlement
that has been filed today in the proceedings referenced above. 1 As discussed in greater
detail below, SCE seeks an expedited ruling on this Motion by September 6, 2013. SCE
1
Offer of Settlement, S. Cal. Edison Co., Docket No. ER11-3697-000, et al. (filed Aug. 26,
2013) (the “Settlement”).
is authorized to state that all parties to this proceeding either support or do not oppose this
Motion 2 and the FERC Trial Staff does not oppose it.
I.
BACKGROUND
On June 3, 2011, SCE submitted a filing in Docket No. ER11-3697-000, in which
SCE proposed comprehensive revisions to its FERC Electric Tariff, Third Revised
Volume No. 6 (the “TO Tariff”) to implement a formula rate to calculate its Base
Transmission Revenue Requirement (“Base TRR”) and associated transmission rates
under its TO Tariff. 3 On August 2, 2011, the Commission issued an order conditionally
accepting the TO-6 Filing, suspending it for five months to be effective January 1, 2012,
subject to refund, and establishing hearing and settlement judge procedures. S. Cal.
Edison Co., 136 FERC ¶ 61,074 (2011) (“August 2 Order”). On August 10, 2011, the
Chief Administrative Law Judge appointed The Honorable H. Peter Young as the
Settlement Judge in this proceeding.
The Settlement filed today resolves all disputed issues among the parties to this
proceeding and represents the culmination of nearly two years of settlement discussions
2
The parties to this proceeding are: SCE; Pacific Gas and Electric Co.; Golden State Water Co.;
Arizona Electric Power Cooperative, Inc., and Southwest Transmission Cooperative, Inc.; San
Diego Gas & Electric Co.; Energy Producers and Users Coalition; Atlantic Path 15, LLC; Public
Utilities Commission of the State of California; California Department of Water Resources State
Water Project; the City of Los Angeles Department of Water and Power; M-S-R Public Power
Agency; the Northern California Power Agency; the State Water Contractors; the Cities of
Anaheim, Azusa, Banning, Colton, Pasadena and Riverside, California; the Cities of Santa Clara
and Redding, California; Modesto Irrigation District; and Transmission Agency of Northern
California.
3
Transmission Owner Tariff Rate Filing, S. Cal. Edison Co., Docket No. ER11-3697-000 (filed
June 3, 2011) (the “TO-6 Filing”).
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in Docket No. ER11-3697-000. It also resolves all issues regarding SCE’s September 1,
2011 compliance filing in Docket No. ER11-3697-001 4 and SCE’s September 14, 2012
Annual Update in Docket No. ER11-3697-003. 5 As such, the parties to this proceeding
desire to have the procedures and reduced rates specified in the Settlement implemented
as soon as possible.
SCE’s formula rate, both as originally filed and as modified through the
Settlement, is comprised of two principal components that are both set forth in Appendix
IX to SCE’s TO Tariff. The first component of the formula rate is the Formula Rate
Protocols. The Formula Rate Protocols provide the rules applicable to SCE’s formula,
including, among other provisions, the deadline for SCE to file its annual formula rate
update with the Commission and the date upon which SCE’s annual update filing and the
new Base TRR and associated transmission rates become effective. In SCE’s original
filing in this proceeding, the Formula Rate Protocols were not named as such, but
Appendix IX to SCE’s TO Tariff included provisions outlining the applicable rules.
Under the Settlement, these rules have been revised and, going forward, are referred to as
the Formula Rate Protocols and are attached to Appendix IX to SCE’s TO Tariff as
“Attachment 1.”
The second component of SCE’s formula rate is the Formula Rate Spreadsheet.
The Formula Rate Spreadsheet consists of thirty-five Schedules that SCE uses to
4
Compliance Filing, S. Cal. Edison Co., Docket No. ER11-3697-001 (filed Sept. 1, 2011).
5
Formula Transmission Rate Informational Filing, S. Cal. Edison Co., Docket No. ER11-3697003 (filed Sept. 14, 2012).
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calculate the Base TRR and associated transmission rates produced by the formula. As
with the Formula Rate Protocols, the Formula Rate Spreadsheet, in an unpopulated form,
is part of SCE’s TO Tariff. SCE originally filed the Formula Rate Spreadsheet as
Attachment 1 to Appendix IX to SCE’s TO Tariff. Under the Settlement, the Formula
Rate Spreadsheet has been redesignated as Attachment 2 to Appendix IX to the TO
Tariff. The Formula Rate Protocols and the Formula Rate Spreadsheet collectively
comprise the “Formula Rate.”
II.
MOTION FOR IMPLEMENTATION OF INTERIM SETTLEMENT
RATES AND WAIVER OF TARIFF PROVISIONS
This Motion is being filed as required under the Settlement that SCE filed today in
the above-captioned proceedings. The Settlement results in reduced Base TRRs and
associated transmission rates applicable under the TO Tariff, with different Base TRRs
and rates applicable for various periods beginning January 1, 2012. This Motion seeks to
implement on an interim basis effective October 1, 2013, certain Base TRRs and
associated transmission rates included in the Settlement (referred to as the “Interim
Settlement Rates”). The Interim Settlement Rates are set forth in Attachment A to this
Motion. This Motion also seeks a waiver of certain provisions of SCE’s currentlyeffective formula rate.
Good cause exists for granting this Motion. First, allowing the Interim Settlement
Rates to be placed into effect on October 1, 2013, will permit earlier enjoyment by SCE’s
customers of the reduced rates resulting from the Settlement. Second, it will minimize
the administrative and economic burden that would result from continued overcollection
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by SCE of amounts that exceed the Base TRRs and rates specified under the Settlement
that would eventually need to be returned to customers through refunds (with interest at
Commission-approved rates). Third, implementation of settlement rates on an interim
basis is consistent with established precedent and has been approved in numerous
proceedings. See, e.g, PJM Interconnection, L.L.C., “Order of Chief Judge Granting
Motion for Interim Rate Relief,” Docket No. ER13-488 (July 16, 2013); Pacific Gas &
Electric, “Order of Chief Judge Granting Motion for Interim Rate Relief,” Docket No.
ER08-1318 (May 11, 2009); ANR Pipeline Co., 120 FERC ¶ 63,013 (2007); Entergy
Serv., Inc., 116 FERC ¶ 63,042 (2006). Granting this Motion will not prejudice the
interests of any party to this proceeding. The relief sought in this Motion is, moreover, in
the public interest as it permits the specified Base TRRs and associated transmission rates
to be placed in effect pending Commission consideration of the unopposed Settlement.
If this Motion is granted, these Base TRRs and rates would be implemented for
billing purposes on October 1, 2013. The parties have selected October 1, 2013 as the
date for implementing the Interim Settlement Rates because that is the date that, absent
this Motion, SCE would implement revised Base TRRs and rates under the procedures
specified in SCE’s currently-effective formula rate. Appendix IX to SCE’s TO Tariff
requires SCE to file updated Base TRRs and associated transmission rates with the
Commission as an informational filing by September 15, 2013, and for such Base TRRs
and associated transmission rates to be made effective as of October 1, 2013. The
September 15th informational filing would become unnecessary if this Motion is granted,
because the Interim Settlement Rates would become effective October 1, 2013 instead.
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Accordingly, in order to implement the lower Base TRR and rates, SCE requests a waiver
of the obligation under its currently-effective TO Tariff to submit its September 15th
annual informational filing.
SCE also requests waiver of any other applicable requirements, including waiver
of the sixty (60)-day notice and filing requirement, necessary to permit the Interim
Settlement Rates to go into effect as of October 1, 2013, as described above. Again, all
parties, including FERC Trial Staff, support or do not oppose the waiver of the
September 15th informational filing and the waiver of the sixty (60)-day notice and filing
requirements as set forth herein.
III.
REQUEST FOR EXPEDITED CONSIDERATION AND FOR
SHORTENED ANSWER PERIOD
As noted above, if the Commission does not grant this Motion, SCE will need to
prepare its next Annual Update and file it with the Commission by September 15, 2013.
Thus, SCE requires a ruling on this Motion sufficiently in advance of that September 15,
2013 deadline so that it will know whether it needs to prepare that filing. Accordingly,
SCE respectfully requests a ruling on this Motion by September 6, 2013. This is the
latest date that will still accommodate the preparation of that filing should it become
necessary. In the event the Motion is not ruled upon by that time, the timing set forth
above will not function properly, so the Motion should be deemed withdrawn if not
granted in full by September 6, 2013.
In order to facilitate the Commission’s review of this Motion, SCE requests that
the fifteen-day answer period prescribed by Rule 213(d) be shortened to two days,
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making such responses due on August 28, 2013. SCE does not anticipate any opposition
to this Motion, and, as stated previously, is authorized to represent that none of the
participants in this proceeding oppose the request for a shortened answer period.
Respectfully submitted,
/s/Anna J. Valdberg
Anna J. Valdberg
Southern California Edison Company
2244 Walnut Grove Avenue
Post Office Box 800
Rosemead, CA 91770
Gary A. Morgans
Steptoe & Johnson LLP
1330 Connecticut Avenue, NW
Washington, DC 20036
Attorneys for Southern California Edison Co.
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Attachment A
Page 1 of 2
Effective Period:
Beginning October 1, 2013
1) Retail Base Transmission Revenue Requirements
Retail Base TRR:
$789,284,765
2) Retail Base Transmission Rates
Rate Group
Domestic
GS-1
TC-1
GS-2
TOU-GS-3
TOU-8-SEC
TOU-8-PRI
TOU-8-SUB
TOU-8-Standby-SEC
TOU-8-Standby-PRI
TOU-8-Standby-SUB
TOU-PA-2
TOU-PA-3
Street Lighting
Energy Charge
($/kWh)
$0.01064
$0.01068
$0.00637
--------------------$0.00423
Contracted
Contracted
Supplemental
standby kW
Supplemental
standby kW
Demand Charge - demand Charge - Demand Charge - demand Charge $/kW-month
$/kW-month
$/HP-month
$/HP-month
-----
---
$1.97
$2.83
$3.14
$3.29
$3.14
$3.26
$3.19
$3.98
$3.03
$0.94
$2.03
-----------
---
$1.82
$1.82
$1.82
$1.82
$1.39
$0.57
$0.94
$1.82
---------------------------
$0.70
---------------------------
$0.70
Page 2 of 2
3) Wholesale Transmission Revenue Requirements and Associated Rates
TOTAL
High
Voltage
Wholesale Base TRR:
$783,403,305
$738,637,100
$46,564,160
Wholesale TRBAA:
-$46,698,411
-$46,211,511
-$486,900
Less Standby Transmission Revenues:
-$8,164,310
-$7,697,775
-$485,273
Wholesale Transmission Revenue Requirement:
$728,540,583
$684,727,814
$45,591,987
Low Voltage Access Charge:
Low Voltage Wheeling Access Charge:
High Voltage Utility Specific Rate:
High Voltage Existing Contracts Access Charge:
Low Voltage Existing Contracts Access Charge:
Rate
$0.00050
$0.00050
$0.0075634
$3.79
$0.25
Gross Load:
90,531,472
per kWh
per kWh
per kWh
per kW
per kW
4) Gross Load
MWh
Low
Voltage
CERTIFICATE OF SERVICE
I hereby certify that I have this day served the foregoing “UNOPPOSED MOTION
FOR IMPLEMENTATION OF INTERIM SETTLEMENT RATES AND WAIVER OF
TARIFF PROVISIONS AND REQUEST FOR EXPEDITED CONSIDERATION AND
SHORTENED ANSWER PERIOD ON BEHALF OF SOUTHERN CALIFORNIA
EDISON COMPANY” upon each person designated on the official service list compiled by the
Secretary in this proceeding.
Dated at Rosemead, California, this 26th day of August, 2013.
/s/vicki.carr-donerson
Vicki Carr-Donerson, Project/Case Analyst
SOUTHERN CALIFORNIA EDISON COMPANY
2244 Walnut Grove Avenue
Post Office Box 800
Rosemead, California 91770
Telephone: (626) 302-6846