2009 General Rate Case Compliance...3 1 II. 2 SUMMARY OF COMPLIANCE ACTION ITEMS 3 The tables in...

Application No.: Exhibit No.: SCE-13 Witnesses: Z. Buhler

S. DiBernardo R. Ramirez

(U 338-E)

2009 General Rate Case

Compliance

Before the

Public Utilities Commission of the State of California

Rosemead, California

November 2007

SCE-13: COMPLIANCE

Table Of Contents Section Page Witness

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I. SUMMARY.......................................................................................................1 R. Ramirez

II. SUMMARY OF COMPLIANCE ACTION ITEMS.........................................3

1. 2006 General Rate Case.............................................................3

OIIs and OIRs ..................................................................................................14

III. NON-TARIFFED PRODUCTS & SERVICES...............................................19 Z. Buhler

A. Audit Results Pertaining to Review of SCE’s Gross Revenue Sharing Mechanism ..............................................................19

IV. REIMBURSABLE EXPENSE REVIEWS .....................................................21 S. DiBernardo

A. Results Are Not Statistically Significant And Cannot Be Extrapolated To Reimbursable Expense Population – 2004, 2005, And 2006 Reviews.....................................................................21

B. Results of Statistically Significant Review - 2006 ..............................23

Appendix A Witness Qualifications

1

I. 1

SUMMARY 2

The California Public Utilities Commission’s (CPUC or Commission) “Standard Requirement 3

List Of Documentation Supporting An NOI” requires applicants to submit “all studies and information 4

required to be submitted in the rate case by the Commission in prior rate case decisions and subsequent 5

policy statement or decisions.” 6

The purpose of this exhibit is to demonstrate that Southern California Edison Company (SCE or 7

Company) has submitted all required studies and information in this application. SCE complies with all 8

relevant orders of the Commission. 9

We identified Commission compliance action items by reviewing the Ordering Paragraphs, 10

Conclusions of Law, Findings of Fact, and discussions contained in Commission decisions, resolutions, 11

and Administrative Law Judge (ALJ Rulings). We reviewed Commission directives pertaining to the 12

previous three SCE general rate cases. In addition, we reviewed Commission directives pertaining to 13

other SCE proceedings and other electric utility or generic proceedings dating back to 1992. Of all the 14

potential SCE compliance action items identified, only those that impact this general rate case are 15

addressed in this exhibit. One-time compliance items that were completed in the 2006 GRC are not 16

included in this 2009 Compliance exhibit. 17

The attached list identifies the compliance action items ordered by type of proceeding in which 18

the compliance item arose. For example, compliance items from prior general rate cases are grouped 19

together and then subgrouped chronologically. For each compliance action item, the following 20

information is provided: 21

• The CPUC proceeding which resulted in the compliance action item. For example, A.90-12-018 – 22

GRC 92 refers to SCE’s Test Year 1992 general rate case. 23

• A brief summary description of the compliance action item. 24

• Authority -- provides the reference number of the CPUC decision, resolution, or ruling containing 25

the order with which SCE is complying. 26

2

• Decision Cite -- indicates where in the CPUC directive identified by the “Authority,” Commission 1

language requiring the compliance action may be found. The Decision Cite may refer to any 2

combination of Ordering Paragraph, Conclusion of Law, Finding of Fact, or Discussion pages. 3

• Action Required -- is usually a verbatim quote of the applicable Decision Cites. In general, if the 4

Decision Cite includes an Ordering Paragraph, Action Required will quote only such Ordering 5

Paragraph. In some instances, other Decision Cites will be quoted if they are helpful in clarifying 6

the Action Required. 7

• Status -- is a brief indication of the nature of SCE’s compliance with any action item. It consists of 8

any one of the following: Complete, Pending, Ongoing, or Discontinued. 9

• Status Details -- provides a more detailed summary of the Status of any compliance action item. 10

Status Details may cite proof of completion (e.g., Advice Letter reference), or offer explanation of 11

the status of Pending or Discontinued action items. In addition, Status Details will provide a 12

reference, if applicable, to SCE's exhibits in this proceeding where compliance with a particular item 13

is addressed.14

3

II. 1

SUMMARY OF COMPLIANCE ACTION ITEMS 2

The tables in this Chapter summarize all compliance action items that impact this 2009 general rate 3

case. 4

1. 2006 General Rate Case 5

6 A04-12-014/I05-05-024 – GRC 2006 Establish a memorandum account to track change in revenue requirement adopted in this general rate case during the period between January 12, 2006 and the effective date of the final decision Authority: D06-01-020 Decision Cite: Ordering Paragraph No.1 Action Required: Southern California Edison Company is authorized to establish a memorandum account to track the change in the

revenue requirement adopted in this general rate case during the period between January 12, 2006 and the effective date of the final decision.

Status: Complete Status Detail: Filed AL 1956-E on January 17, 2006 which, pursuant to Ordering Paragraph 1 of D.06-01-020, revises Preliminary

Statement, Part N, Memorandum Accounts, to establish the General Rate Case Revenue Requirement Memorandum Account (GRC RRMA).

7 A04-12-014/I05-05-024 – GRC 2006 Transfer General Rate Case Revenue Requirement Memorandum Account balance Authority: D06-05-016 Decision Cite: Ordering Paragraph No.2 Action Required: SCE shall transfer the General Rate Case Revenue Requirement Memorandum Account balance, as of the effective

date of this decision, to its Base Revenue Requirement Balancing Account. Status: Complete Status Detail: Filed AL 2019-E on July 26, 2006.

8 A04-12-014/I05-05-024 – GRC 2006 File revised tariff sheets to implement the revenue requirements, accounting procedures, and charges authorized in this Order Authority: D06-05-016 Decision Cite: Ordering Paragraph No.3 Action Required: Within 10 days of the effective date of this order, SCE shall file revised tariff sheets to implement the revenue

requirements, accounting procedures, and charges authorized in this Order and to incorporate the relevant findings and conclusions of this decision. The revised tariff sheets shall become effective on filing, subject to a finding of compliance by the Energy Division, and shall comply with General Order 96-A. The revised tariff sheets shall apply to service rendered on or after their effective date.

Status: Complete Status Detail: Filed AL 2003-E on May 22, 2006.

4

1 A04-12-014/I05-05-024 – GRC 2006 File revised tariff sheets to implement the revenue requirements, accounting procedures, and charges authorized in this Order Authority: D06-05-016 Decision Cite: Ordering Paragraph No.7 Action Required: SCE is authorized to implement its proposed revenue balancing account to adjust for sales variations and its proposed

Post-Test Year Ratemaking (PTYR) mechanism for both 2004 and 2005 to the extent consistent with the foregoing discussion, findings of fact, and conclusions of law.

Status: Complete Status Detail: Filed AL 2054-E on November 1, 2006.

Filed AL 2054-E-A on December 15, 2006.

2 A04-12-014/I05-05-024 – GRC 2006 Establish a two way balancing to record the ongoing expenses and capital related costs associated with the Mohave Generating Station (Mohave). Authority: D06-05-016 Decision Cite: Ordering Paragraph No.8 Action Required: SCE shall establish a two way balancing to record the ongoing expenses and capital related costs associated with the

Mohave Generating Station (Mohave). Status: Complete Status Detail: May 22, 2006, SCE filed AL 2003-E, which, among other things, established the Mohave two-way balancing account.

3 A04-12-014/I05-05-024 – GRC 2006 SCE shall not disburse funds from the Mohave Sulfur Credit Sub-Account without specific Commission authorization to do so. Authority: D06-05-016 Decision Cite: Ordering Paragraph No.12 Action Required: SCE shall not disburse funds from the Mohave Sulfur Credit Sub-Account without specific Commission authorization

to do so. Status: Complete Status Detail: December 20, 2006, SCE filed its Application regarding distribution of SO2 Allowance Sale Proceeds related to the

suspended operation of Mohave Generating Station.

5

1 A04-12-014/I05-05-024 – GRC 2006 Establish and implement appropriate procedures to satisfy our requirements as specified above in the conclusions of law related to the proposed Project Development Division. Authority: D06-05-016 Decision Cite: Ordering Paragraph No.16

Conclusion of Law No. 2 Action Required: SCE shall establish and implement appropriate procedures to satisfy our requirements as specified above in the

conclusions of law related to the proposed Project Development Division. CL. 2 For this GRC, SCE’s request of $4,950,000 in expenses to fund its proposed PDD should be excluded from rates. However, SCE should be allowed rate recovery of costs that support new generation and that are not associated with proposed projects. SCE should track such supportive project development costs in a memorandum account. Such costs can then be recovered in future rates to the extent that they are incurred, to the extent that SCE can justify their supportive nature, and to the extent that the total recorded PDD costs do not exceed SCE’s forecasted amount.

Status: Complete Status Detail: 2009 GRC -- NOI - SCE-02, Vol 12/Generation (Other) – Project Development Division (PDD)

2 A04-12-014/I05-05-024 – GRC 2006

Track authorized and recorded Results Sharing costs in a memorandum account. Authority: D06-05-016 Decision Cite: Ordering Paragraph No. 21 Action Required: SCE shall track the authorized and recorded Results Sharing costs in a memorandum account. When the actual Results

Sharing payouts for 2006, 2007 or 2008 are determined, any shortfall in the payment to employees when compared to the authorized amount for that particular year shall then be credited to the Base Revenue Requirement Balancing Account

Status: Complete Status Detail: 2009 GRC -- NOI - SCE-06, Vol 2/HR - Total Compensation

3 A04-12-014/I05-05-024 – GRC 2006 Establish a two-way balancing account for pension costs, beginning with the 2006-2008 forecast period Authority: D06-05-016 Decision Cite: Ordering Paragraph No. 22 Action Required: SCE shall establish a two-way balancing account for pension costs, beginning with the 2006-2008 forecast period. The

balancing account shall record the difference between actual and forecast costs and should be amortized beginning in 2009. Any accumulated balance shall receive interest at the commercial paper rate, consistent with treatment of interest accruals for other SCE balancing accounts.

Status: Complete Status Detail: AL 2019-E, filed July 27, 2006, Implementation of the Test Year 2006 General Rate Case (GRC) Revenue

Requirement Authorized in D.06-05-016, the Revenue Requirement Allocation Authorized in D.06-06-067, the Transmission Settlement Rates Authorized by the Federal Energy Regulatory Commission (FERC) in Docket No. ER06-186-000 and ER06-186-001 and the Direct Access Cost Responsibility Surcharge (DA CRS) authorized in D.06-07-030.

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1 A04-12-014/I05-05-024 – GRC 2006 Establish a memorandum account to track the revenue requirement associated with its forecasted and recorded 2004 and 2005 plant additions Authority: D06-05-016 Decision Cite: Ordering Paragraph No. 23

Conclusion of Law No. 35 Action Required: SCE shall establish a memorandum account to track the revenue requirement associated with its forecasted and

recorded 2004 and 2005 plant additions. When plant additions are evaluated for the Capital Additions Adjustment Mechanism, SCE shall evaluate 2004 and 2005 recorded plant additions as described in the conclusions of law and credit ratepayers as necessary. CL 35 SCE should establish a memorandum account to track the revenue requirement associated with its forecasted and recorded 2004/2005 plant additions. When plant additions are evaluated for the CAAM: a. If SCE records plant additions at or in excess of $2,570,000,000 for the period 2004 – 2005, no further action is necessary. b. If SCE records plant additions that are lower than $2,570,000,000 for the period 2004 – 2005, SCE should credit ratepayers with the excess revenue requirement collected through this decision, that is the difference between the revenue requirement associated with the 2004/2005 plant additions forecasted in this GRC and the revenue requirement associated with the recorded 2004/2005 plant additions. The credit should be calculated from the effective date of this decision.

Status: Complete Status Detail: May 22, 2006, SCE filed AL 2003-E, which, among other things, established a memorandum account to track the

revenue requirement associated with forecast and recorded 2004 and 2005 plant additions.

2 A04-12-014/I05-05-024 – GRC 2006 File jointly determined levels of expenditures with supporting workpapers. Authority: D06-05-016 Decision Cite: Conclusion of Law No. 42 Action Required: Based on the results of this decision, the Settling Parties should jointly determine the levels of expenditures that will be

subject to SCE’s commitment to either spend the authorized amounts or credit ratepayers for the underspent amounts. When SCE files its compliance advice letter to submit the preliminary statement to establish the operation of the RIIM, it should include that jointly determined information, with supporting workpapers.

Status: Complete Status Detail: AL 2012-E, filed June 7, 2006 -- Establishment of the Reliability Investment Incentive Mechanism in Compliance with

D.06-05-016. 2009 GRC -- NOI - SCE-03, Vol 3, Part 4/T&D – Capital Expenditures

7

1 A04-12-014/I05-05-024 – GRC 2006 Demonstrate that employee safety has been and will continue to be a high priority over the entire general rate case cycle Authority: D06-05-016 Decision Cite: Ordering Paragraph No. 27 Action Required: SCE’s employee safety incentive mechanism shall be discontinued for the test year 2006 general rate case (GRC)

cycle. In its next GRC, SCE shall provide information or measurable data to demonstrate that, absent such mechanism, employee safety has been and will continue to be a high priority over the entire general rate case cycle.

Status: Complete Status Detail: 2009 GRC -- NOI - SCE-10, Operations Support Part 1, Appendix K (workpapers)

2 A04-12-014/I05-05-024 – GRC 2006 SCE should not use the data or information in question in determining results sharing goals and awards Authority: D06-05-016 Decision Cite: Conclusion of Law No. 27 Action Required: Until the current CPSD investigations regarding customer satisfaction and injury & illness recordkeeping problems are

resolved, SCE should not use the data or information in question in determining results sharing goals and awards. Status: Complete Status Detail: 2009 GRC -- NOI - SCE-06, Vol 2/HR - Total Compensation

3 A04-12-014/I05-05-024 – GRC 2006 SCE should follow the PG&E model for reporting executive compensation. Authority: D06-05-016 Decision Cite: Conclusion of Law No. 30 Action Required: For purposes of the General Order 77-L (now GO 77-M) report, SCE should follow the PG&E model for reporting

executive compensation. Status: Complete Status Detail: SCE filed GO 77-M on May 31, 2007 as instructed by D.06-12-029.

4 A04-12-014/I05-05-024 – GRC 2006 In its next GRC, provide full transparent and understandable information on the present and future market value of the retirement severance benefits of its top executives Authority: D06-05-016 Decision Cite: Conclusion of Law No. 31 Action Required: In its next GRC, SCE should provide full transparent and understandable information on the present and future market

value of the retirement severance benefits of its top executives. Status: Complete Status Detail: 2009 GRC -- NOI - SCE-06, Vol 2/HR - Total Compensation

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1 A04-12-014/I05-05-024 – GRC 2006 Application seeking final determination of reasonableness of costs recorded to Mohave balancing account Authority: D06-05-016 Decision Cite: Ordering Paragraph No. 9 Action Required: At an appropriate time, after the permanent status of Mohave is determined, SCE shall file an application seeking a

final determination of the reasonableness of the costs recorded to the Mohave balancing account. Status: Pending Status Detail: 2009 GRC -- NOI - SCE-02, Vol. 7/Generation – Coal O&M

2 A04-12-014/I05-05-024 – GRC 2006 Distribution of revenues from the sale of Mohave sulfur credits Authority: D06-05-016 Decision Cite: Ordering Paragraph No. 14 Action Required: If there is a timely determination that Mohave will return to service, the issue of the distribution of revenues from the

sale of Mohave sulfur credits shall be addressed as part of SCE’s application to be filed in compliance with Ordering Paragraph 9 of D.04-12-016 and shall be litigated in that subsequent proceeding.

Status: Complete Status Detail: December 20, 2006, SCE filed its Application regarding distribution of SO2 Allowance Sale Proceeds related to the


3 A04-12-014/I05-05-024 – GRC 2006 Application for authority to disburse funds accumulated in the Mohave sulfur credit sub-account along with a proposal for such disbursement Authority: D06-05-016 Decision Cite: Ordering Paragraph No. 15 Action Required: If Mohave is shut down or the resolution of Mohave’s future operating status is delayed, SCE should file an

application, no later than January 1, 2007, for authority to disburse funds accumulated in the Mohave sulfur credit sub-account along with a proposal for such disbursement.



9

1 A04-12-014/I05-05-024 – GRC 2006 New Mohave Sulfur Credit Sub-Account in SCE’s Energy Resource Recovery Account tariff Authority: D06-05-016 Decision Cite: Ordering Paragraph No. 15

Conclusion of Law No. 7 Action Required: That part of the Coalition’s Motion that requests creation of a new Mohave Sulfur Credit Sub-Account in SCE’s

Energy Resource Recovery Account tariff is granted. SCE shall establish that sub-account and separately track as a credit entry the revenues from the sales of SCE’s sulfur credits created by Mohave’s closure, effective December 31, 2005. CL. 7 The issue of the distribution of revenues accumulated in the Mohave Sulfur Credit Sub-Account should be addressed when more information on the future operating status of Mohave is known.



2 A04-12-014/I05-05-024 – GRC 2006 Project Development Division (PDD) costs related to specific proposed projects should be excluded from the request. Authority: D06-05-016 Decision Cite: Conclusion of Law No. 8, 9 Action Required: 8. For this GRC, SCE’s request of $4,950,000 in expenses to fund its proposed PDD should be excluded from rates.

However, SCE should be allowed rate recovery of costs that support new generation and that are not associated with proposed projects. SCE should track such supportive project development costs in a memorandum account. Such costs can then be recovered in future rates to the extent that they are incurred, to the extent that SCE can justify their supportive nature, and to the extent that the total recorded PDD costs do not exceed SCE’s forecasted amount.

9. In SCE’s next GRC, PDD costs related to specific proposed projects should be excluded from the request. Status: Complete Status Detail: 2009 GRC -- NOI - SCE-02, Vol 12/Generation (Other) – Project Development Division (PDD)

3 A04-12-014/I05-05-024 – GRC 2006 Submit the results of an audit of its compliance with the requirements of D99-09-070 Authority: D06-05-016 Decision Cite: Ordering Paragraph No. 17 Action Required: In its next GRC, SCE shall submit the results of an audit of its compliance with the requirements of D.99-09-070 which

adopted SCE’s Gross Revenue Sharing Mechanism for revenues received from its non-tariffed products and services. As part of this audit, SCE shall review its determination and recording of incremental and non-incremental costs related to non-tariffed products and services from the adoption of D.99-09-070 (September 1999) through the recorded base year for its next GRC.

Status: Complete Status Detail: See 2009 GRC -- NOI - SCE-13, Ch. III/Compliance

10

1 A04-12-014/I05-05-024 – GRC 2006 Provide detailed information on how its final results sharing goals were determined for the 2006 – 2008 Authority: D06-05-016 Decision Cite: Conclusion of Law No. 21 Action Required: In its next GRC, SCE should provide detailed information on how its final results sharing goals were determined for

the 2006 – 2008 period, what steps were taken to ensure the integrity of both the data and the process for making awards, and any further consequences or any required actions imposed by either SCE or the Commission, as a result of the Customer Satisfaction and Injury & Illness Recordkeeping investigations.

Status: Complete Status Detail: 2009 GRC -- NOI - SCE-06, Vol 2/HR - Total Compensation

2 A04-12-014/I05-05-024 – GRC 2006 Provide analysis which quantifies potential accrual deficiencies for the future removal costs of existing assets Authority: D06-05-016 Decision Cite: Conclusion of Law No. 32, 33, 34 Action Required: CL 32. Depreciation and amortization expense amounting to $793,387,000 as detailed in Appendix C, should be

adopted for the test year. CL 33. In its next GRC, SCE should, as part of its account by account analysis for depreciation, analyze the effects of past inflation on its proposed cost of removal rates and justify the implicit inflation rates reflected in its proposed rates. CL 34. SCE should, as part of its account-by-account analysis for depreciation, provide analysis which quantifies potential accrual deficiencies for the future removal costs of existing assets. SCE should provide an analysis of what is causing any likely deficiencies.

Status: Complete Status Detail: 2009 GRC -- NOI - SCE-11, Vol 3/Results of Operations - Depreciation

3 A04-12-014/I05-05-024 – GRC 2006 Nuclear Energy Institute (NEI) dues – provide detailed descriptions of activities, associated costs, and resulting company and ratepayer benefits associated with participation Authority: D06-05-016 Decision Cite: Ordering Paragraph No. 28

Conclusion of Law No. 45 Action Required: For future requests for ratepayer funding of NEI dues, SCE should provide detailed descriptions of the activities, the

associated costs, and the resulting company and ratepayer benefits associated with participation in that organization. Status: Complete Status Detail: 2009 GRC -- NOI - SCE-02, Vol 2, Ch. XIII/Generation – SONGS O&M

11

1 A04-12-014/I05-05-024 – GRC 2006 Next GRC – provide detailed showing on need and cost of transmission life extension included in Accounts 571.100 and 571.200 Authority: D06-05-016 Decision Cite: Conclusion of Law No. 15 Action Required: In the next GRC, SCE should provide a detailed showing on the need and cost of the transmission life extension

program (for poles and structures as well as insulators and conductors) that is include in Accounts 571.100 and 571.200. The showing should also demonstrate the incremental nature of the life extension program.

Status: Complete Status Detail: 2009 GRC -- NOI - SCE-03, Part 2, Ch. VIII/T&D -- O&M Expenses

2 A04-12-014/I05-05-024 – GRC 2006 Next GRC – provide study on time-tracking system for its in-house counsel Authority: D06-05-016 Decision Cite: Conclusion of Law No. 23 Action Required: In its next GRC, SCE should provide a study on, or analysis of, a time-tracking system for its in-house counsel. It

should include an estimated cost of performing this activity, any perceived benefits or detriments and any analysis related to the tracking system that was in place during the 1994 – 1998 timeframe.

Status: Complete Status Detail: 2009 GRC -- NOI - SCE-07, Vol 2, Ch. II/A&G - Legal and Ethics & Compliance

3 A04-12-014/I05-05-024 – GRC 2006 Next GRC – redo time-tracking study to reflect the areas of responsibilities requested for the test year Authority: D06-05-016 Decision Cite: Conclusion of Law No. 24 Action Required: In its next GRC, for the Public Affairs Department, SCE should redo the time-tracking study to reflect the areas of

responsibilities requested for the test year and ensure that the results are appropriately applied to whatever methodology is used to forecast test year expenses.

Status: Complete Status Detail: 2009 GRC -- NOI - SCE-04, Vol 3/Customer Service

4 A04-12-014/I05-05-024 – GRC 2006 Next GRC – conduct another statistical study for recorded 2006 reimbursable expenses Authority: D06-05-016 Decision Cite: Conclusion of Law No. 25 Action Required: For its next GRC, SCE should conduct another statistical study for recorded 2006 reimbursable expenses, for the

employees whose annual reimbursable expenses are less than $25,000, similar to that performed for 2003 recorded reimbursable expenses.

Status: Complete Status Detail: See 2009 GRC – NOI, SCE-13

12

1 A04-12-014/I05-05-024 – GRC 2006 Next GRC – provide information on workforce diversity achievements similar to that provided by Greenlining in Exhibit 505 Authority: D06-05-016 Decision Cite: Conclusion of Law No. 29 Action Required: As part of its next GRC filing, SCE should provide information on its workforce diversity achievements, similar to that

provided by Greenlining in Exhibit 505. Status: Complete Status Detail: 2009 GRC -- NOI - SCE-06, Vol 1/HR - HR Departmental

2 A04-12-014/I05-05-024 – GRC 2006 Next GRC – provide full transparent and understandable information on present and future market value of retirement severance benefits of top executives Authority: D06-05-016 Decision Cite: Conclusion of Law No. 31 Action Required: In its next GRC, SCE should provide full transparent and understandable information on the present and future market

value of the retirement severance benefits of its top executives. Status: Complete Status Detail: 2009 GRC -- NOI - SCE-06, Vol 2/HR - Total Compensation

3 A05-05-023 -- GRC Phase 2 Advice Letter (AL) with revised tariff sheets Authority: D05-12-040 Decision Cite: Ordering Paragraph No.2, 3, 4 Action Required: Op. 2 If the Commission approves a decision in Rulemaking (R.) 02-01-011 no later than September 21, 2006, then within

three days of the effective date of the Commission’s decision in R.02-01-011 resolving cost responsibility surcharge obligations, Southern California Edison Company (SCE) shall file an Advice Letter (AL) with revised tariff sheets to implement the authority granted in this decision, and the Commission’s decision in R.02-01-011. The revised tariff sheets shall become effective three days after the decision in R.02-01-011. Op. 3 In the event that the Commission’s order in R.02-01-011 is not adopted by September 21, 2006, then the Direct Access (DA) rates to be filed shall not include the changes recommended in the Working Group Report in R.02-01-011, and instead DA rates shall be based on the existing rate design wherever the Working Group Report would change current rates. SCE shall then file an AL with revised tariff sheets on or before Sept. 30, 2006 to implement new rates reflecting the authority granted in this decision to be effective Oct. 1, 2006. Op. 4 In either event, the AL shall comply with GO 96-A (or its successor) and D.05-01-032. The revised tariff sheets shall apply to service rendered on or after their effective date, subject to Energy Division’s determination that they are in compliance with this decision.

Status: Complete Status Details: SCE filed AL 2046-E on October 2, 2006.

13

1 A05-05-023 -- GRC Phase 2 RTP-2-1 should terminate at the end of SCE’s opt-out period in November 2006 Authority: D06-06-067 Decision Cite: Ordering Paragraph No. 5 Action Required: Schedule RTP-2-I should terminate at the end of SCE’s opt-out period in November 2006, and therefore this schedule

(revised to reflect current allocated revenues) should remain in effect until that opt-out period has ended. Former RTP-2-I customers should have the option of transferring to Schedule I-6, or any other applicable rate schedule at that time.

Status: Complete Status Details: SCE filed AL 2046-E on October 2, 2006.

2 A05-05-023 -- GRC Phase 2 Provide notice to all customers on rate schedules that will be closed as proposed in the Settlement Agreement Authority: D06-06-067 Decision Cite: Ordering Paragraph No. 6 Action Required: SCE shall provide notice to all customers on rate schedules that will be closed as proposed in the Settlement Agreement.

The notice shall be mailed to existing customers at least 30 days prior to closing these existing schedules and include other schedule options available to these existing customers.

Status: Complete Status Details: SCE’s Business Customer Division (BCD) provided the required written notice to all affected customers in Summer (July /

August) 2006) together with a description of their options as to alternative rates.

3 SCE Advice Letter 2026-E Policy for carrying over RD&D funds between GRC cycles Authority: ResE-4033 Decision Cite: Ordering Paragraph No. 3 Action Required: SCE shall address the policy for carrying over RD&D funds between GRC cycles in its 2009 GRC application. Status: Complete Status Details: 2009 GRC -- NOI - SCE-03, Vol 2, Part 4/T&D - O&M

14

OIIs and OIRs 1 2 R97-04-011/I97-04-012 - OIR: AFFILIATES Regulatory Oversight -- Affiliates -- Compliance Plans Authority: D97-12-088 Decision Cite: Ordering Paragraph No. 2.

Discussion at Appendix A. Action Required: No later than December 31, 1997, Respondent utilities Kirkwood Gas and Electric Company, PacifiCorp, Pacific Gas and

Electric Company (PG&E), San Diego Gas & Electric Company (SDG&E), Sierra Pacific Company, Southern California Edison Company (Edison), Southern California Gas Company (SoCalGas), Southern California Water Company (SCWC), Southwest Gas Company, and Washington Water and Power Company shall file a compliance plan demonstrating to the Commission that there are adequate procedures in place implementing the rules we adopt today.

The utilities shall file these compliance plans as an advice letter with the Commission’s Energy Division and serve them on the service list of this proceeding.

The utilities’ compliance plans will be in effect between their filing and a Commission decision on the advice letter.

A utility shall file a compliance plan annually thereafter using the same advice letter process when there is some change in the compliance plan (i.e., a new affiliate has been created, or the utility has changed the compliance plan for any other reason).

Status: Complete Status Detail: Advice Letter 2136-E , filed June 29, 2007.

3 R97-04-011/I97-04-012 - OIR: AFFILIATES Regulatory Oversight -- Affiliates -- New Affiliates Authority: D97-12-088 Decision Cite: Ordering Paragraph No. 2.

Discussion at Sec. VI. A, pages 15-16. Action Required: Also, no later than 60 days after the creation of a new affiliate, the utility shall file an advice letter with the Energy

Division of the Commission, which should also be served on the parties to this proceeding. The advice letter shall demonstrate how the utility will implement these rules with respect to the new entity. Any Respondent utility which applies for an exemption under Rule 2G does not have to comply with this Ordering Paragraph unless further ordered by the Commission or required by Rule 2G.

Status: On-Going Status Detail: AL 1992-E, April 21, 2006.

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1 R97-04-011/I97-04-012 - OIR: AFFILIATES Disclosure and Information -- Affiliates --Service Provider Information Authority: D97-12-088 Decision Cite: Appendix A.

Discussion at Sec. IV. Action Required: IV. Disclosure and Information

C. Service Provider Information: 1. Except upon request by a customer or as otherwise authorized by the Commission, or approved by another governmental body, a utility shall not provide its customers with any list of service providers, which includes or identifies the utility’s affiliates, regardless of whether such list also includes or identifies the names of unaffiliated entities. A utility shall submit lists approved by other governmental bodies in the first semi-annual advice letter filing referenced in Rule IV.C.2 following such approval, but may provide customers with such lists pending action on the advice letter. 2. If a customer requests information about any affiliated service provider, the utility shall provide a list of all providers of gas-related, electricity-related, or other utility-related goods and services operating in its service territory, including its affiliates. The Commission shall authorize, by semi-annual utility advice letter filing, and either the utility, the Commission, or a Commission-authorized third party provider shall maintain on file with the Commission a copy of the most updated lists of service providers which have been created to disseminate to a customer upon a customer’s request. Any service provider may request that it be included on such list, and, barring Commission direction, the utility shall honor such request. Where maintenance of such list would be unduly burdensome due to the number of service providers, subject to Commission approval by advice letter filing, the utility shall direct the customer to a generally available listing of service providers (e.g., the Yellow Pages). In such cases, no list shall be provided. If there is no Commission-authorized list available, utilities may refer customers to a generally available listing of service providers (e.g., the Yellow Pages.) The list of service providers should make clear that the Commission does not guarantee the financial stability or service quality of the service providers listed by the act of approving this list.

Status: Complete Status Detail: Advice 2082-E, December 28, 2006– Semi-Annual Filing Regarding Service Provider Lists.

D06-12-029 -- The utility is no longer required to file this list.

16

R97-04-011/I97-04-012 - OIR: AFFILIATES Separation -- Affiliates -- Employees Authority: D97-12-088 Decision Cite: Discussion at Sec. V.G, pages 12-13. Action Required: V. Separation

G. Employees: 1. Except as permitted in Section V E (corporate support), a utility and its affiliates shall not jointly employ the same employees. This Rule prohibiting joint employees also applies to Board Directors and corporate officers, except for the following circumstances: In instances when this Rule is applicable to holding companies, any board member or corporate officer may serve on the holding company and with either the utility or affiliate (but not both). Where the utility is a multi-state utility, is not a member of a holding company structure, and assumes the corporate governance functions for the affiliates, the prohibition against any board member or corporate officer of the utility also serving as a board member or corporate officer of an affiliate shall only apply to affiliates that operate within California. In the case of shared directors and officers, a corporate officer from the utility and holding company shall verify in the utility’s compliance plan the adequacy of the specific mechanisms and procedures in place to ensure that the utility is not utilizing shared officers and directors as a conduit to circumvent any of these Rules. In its compliance plan required in Rule VI, the utility shall list all shared directors and officers between the utility and affiliates. No later than 30 days following a change to this list, the utility shall notify the Commission's Energy Division and the parties on the service list of R.97-04-011 / I.97-04-012 of any change to this list. 2. All employee movement between a utility and its affiliates shall be consistent with the following provisions:

c. When an employee of a utility is transferred, assigned, or otherwise employed by the affiliate, the affiliate shall make a one-time payment to the utility in an amount equivalent to 25% of the employee’s base annual compensation, unless the utility can demonstrate that some lesser percentage (equal to at least 15%) is appropriate for the class of employee included. In the limited case where a rank-and-file (non-executive) employee's position is eliminated as a result of electric industry restructuring, a utility may demonstrate that no fee or a lesser percentage than 15% is appropriate. The Board of Directors must vote to classify these employees as "impacted" by electric restructuring and these employees must be transferred no later than December 31, 1998, except for the transfer of employees working at divested plants. In that instance, the Board of Directors must vote to classify these employees as "impacted" by electric restructuring and these employees must be transferred no later than within 60 days after the end of the O&M contract with the new plant owners. All such fees paid to the utility shall be accounted for in a separate memorandum account to track them for future ratemaking treatment (i.e. credited to the Electric Revenue Adjustment Account or the Core and Non-core Gas Fixed Cost Accounts, or other ratemaking treatment, as appropriate), on an annual basis, or as otherwise necessary to ensure that the utility’s ratepayers receive the fees. This transfer payment provision will not apply to clerical workers. Nor will it apply to the initial transfer of employees to the utility’s holding company to perform corporate support functions or to a separate affiliate performing corporate support functions, provided that that transfer is made during the initial implementation period of these rules or pursuant to a § 851 application or other Commission proceeding. However, the rule will apply to any subsequent transfers or assignments between a utility and its affiliates of all covered employees at a later time.

d. Any utility employee hired by an affiliate shall not remove or otherwise provide information to the affiliate which the affiliate would otherwise be precluded from having pursuant to these Rules.

e. A utility shall not make temporary or intermittent assignments, or rotations to its energy marketing affiliates. Utility employees not involved in marketing may be used on a temporary basis (less than 30% of an employee's chargeable time in any calendar year) by affiliates not engaged in energy marketing only if:

i. All such use is documented, priced and reported in accordance with these Rules and existing Commission reporting requirements, except that when the affiliate obtains the services of a non-executive employee, compensation to the utility should be priced at a minimum of the greater of fully loaded cost plus 10% of direct labor cost, or fair market value. When the affiliate obtains the services of an executive employee, compensation to the utility should be priced at a minimum of the greater of fully loaded cost plus 15% of direct labor cost, or

17

fair market value.

ii. Utility needs for utility employees always take priority over any affiliate requests;

iii. No more than 5% of full time equivalent utility employees may be on loan at a given time;

iv. Utility employees agree, in writing, that they will abide by these Affiliate Transaction Rules; and

v. Affiliate use of utility employees must be conducted pursuant to a written agreement approved by appropriate utility and affiliate officers.

Status: On-Going Status Detail: Advice Letter 2136-E, filed June 29, 2007.

1 R97-04-011/I97-04-012 - OIR: AFFILIATES Regulatory Oversight -- Affiliates -- Affiliate Audit Authority: D97-12-088 Decision Cite: Discussion at Sec. VI. C, page 15. Action Required: VI. Regulatory Oversight

C. Affiliate Audit: No later than December 31, 1998, and every year thereafter, the utility shall have audits performed by independent auditors that cover the calendar year which ends on December 31, and that verify that the utility is in compliance with the Rules set forth herein. The utilities shall file the independent auditor's report with the Commission’s Energy Division beginning no later than May 1, 1999, and serve it on all parties to this proceeding. The audits shall be at shareholder expense.

Status: On-going Status Detail: Ninth Audit (2006) by Northstar LLC to be submitted May 1, 2007.

D98-08-035 ordered a bi-annual audits to be conduct by the commission.

2 R01-10-024 - OIR: Generation Procurement and Renewable Resource Development Meet this 15-17% requirement by no later than January 1, 2008 Authority: D04-01-050 Decision Cite: Conclusion of Law No. 5, 6, 7

Discussion at Sec.IV.5 pages 20-27 Action Required: Conclusion of Law 5. In D.02-12-074, the Commission provisionally adopted a 15% reserve level subject to further

revision in this proceeding. Based on the record developed in this proceeding, we should reaffirm and make permanent the 15 % reserve level, as well as allow for a range up to 17% to account for the lumpiness of investment. Conclusion of Law 6. A 15-17% reserve level also strikes an appropriate balance for ensuring reliable service by providing incentives to encourage the retention of existing resources, whereas setting reserves at a higher level could require the utilities to make short-term investment decisions inconsistent with the Energy Action Plan’s preferred “loading order” of new resources. Conclusion of Law 7. The utilities should meet this 15-17% requirement by no later than January 1, 2008. In their procurement filings, the utilities should justify reserve levels above 15%, although we recognize that given the inherent “lumpiness” of resource additions, the utilities may acquire reserves above 15%, depending on the timing of the resource additions to meet demand.

Status: On-going Status Detail: Advice Letter 2120-E, April 30, 2007 – Procurement Plan Compliance Report.

18

1 R05-10-030 -- Affiliates SCE should follow the PG&E model for reporting executive compensation. Authority: D06-12-029 Decision Cite: Ordering Paragraph No. 6,

Discussion at Sec. 1, pages 2, 3. Action Required: The Affiliate Transaction Rules Applicable to Large California Energy Utilities, appended as Appendix A-3 to this

decision, and General Order (GO) 77-M, appended as Appendix B-3 to this decision, are adopted. Both apply to Respondents (Southern California Edison Company/Edison International, Pacific Gas and Electric Company/PG&E Corporation, and Southern California Gas Company and San Diego Gas & Electric Company, both owned by Sempra Energy).

Status: Complete Status Detail: SCE filed GO 77-M on May 31, 2007, as instructed by D06-12-029.

19

III. 1

NON-TARIFFED PRODUCTS & SERVICES 2

A. Audit Results Pertaining to Review of SCE’s Gross Revenue Sharing Mechanism 3

Decision 06-05-016 (SCE’s 2006 GRC) stated, “Per agreement with TURN, SCE will perform 4

an audit of its compliance with the requirements of D.99-09-070 which adopted SCE’s Gross Revenue 5

Sharing Mechanism for revenues received from its non-tariffed products and services. SCE will submit 6

the results of the audit as a compliance item in its next general rate case. As part of this audit, SCE will 7

review its determination and recording of incremental and non-incremental costs related to non-tariffed 8

products and services from the adoption of D.99-09-070 (September 1999) through the present.” 9

Pursuant to this agreement, SCE’s Audit Services Department (ASD) conducted an audit of 10

SCE’s non-tariffed products and services (NTP&S) between 1999 and 2006. This audit included an 11

analysis of the 31 NTP&S categories established in Advice 1286-E-A to determine whether the 12

incremental costs were identified and recorded correctly and excluded from rates. In addition, SCE 13

reviewed the revenues received for NTP&S to verify that they were appropriately recorded and shared 14

with customers pursuant to the sharing percentages established in SCE’s Gross Revenue Sharing 15

Mechanism adopted in D.99-09-070.1 16

ASD concluded that the gross revenues received for NTP&S from 1999 through 2006 were 17

recorded correctly and appropriately shared with customers. 18

In its 2006 GRC, SCE agreed with TURN that the rationale SCE used to support classifying the 19

costs associated with its Corporate Real Estate (CRE) department’s enhanced revenue generation 20

activities, which fall into several NTP&S categories,2 was inconsistent with the original rationale used to 21

develop its gross revenue sharing percentages. Thus, SCE agreed to exclude these costs from its 2006 22

1 In accordance with D.99-09-070 annual sharing with ratepayers begins after the first $16.671 million of gross revenues is

received. The $16.671million has been included in SCE’s 2009 GRC as a reduction to its revenue requirement request. 2 The gross revenues and incremental costs associated with CRE’s enhanced revenue generation activities fall within the

following NTP&S categories Secondary Use of Transmission Right of Ways and Land; Secondary Use of Distribution Right of Ways, Land, Facilities and Substations; Secondary Use of Utility Owned Generation Facilities and Land; Secondary Use of Utility Owned Buildings and Offices; and Property Management, Property Maintenance, and Real Property Brokerage Services.

20

GRC. Commencing in 2006, SCE has recorded the costs associated with CRE’s enhanced revenue 1

generation activities as NTP&S incremental costs and have excluded them from its 2009 GRC. 2

Through its audit, ASD only identified one additional NTP&S category where the incremental 3

costs were incorrectly recorded. In reviewing the application of its incremental costs definition, SCE 4

determined that the rationale used to support the costs associated with its Geographic Information 5

Systems (GIS) NTP&S category as being not incremental was not fully supportable. Thus, SCE 6

determined that the costs of the one employee that provides mapping services to third-parties under the 7

Gross Revenue Sharing Mechanism should be reclassified as incremental. These costs are 8

approximately $65,000 per year. While these costs were included in SCE’s NOI, they have been 9

excluded from this 2009 GRC application.3 10

ASD has determined that the incremental costs associated with the remaining NTP&S categories 11

were appropriately identified and excluded from rates. 12

3 See workpapers for SCE-03 T&D (FERC Account 588.300) company wide adjustment 1 for the appropriate removal

from SCE’s 2009 GRC Application.

21

IV. 1

REIMBURSABLE EXPENSE REVIEWS 2

A. Results Are Not Statistically Significant And Cannot Be Extrapolated To Reimbursable 3

Expense Population – 2004, 2005, And 2006 Reviews 4

In concurrence with DRA’s recommendation as stated in the 2006 GRC Decision 06-05-016, 5

SCE agreed to perform reviews of reimbursable expenses, similar to that performed during the 2003 6

GRC, to determine whether shareholder expenses were incorrectly recorded to customer accounts. SCE 7

reviewed all reimbursable expense records for its employees included in SCE’s submittal pursuant to 8

General Order 77-L who had total reimbursable expenses of $25,000 or greater during the respective 9

year under review.4 SCE’s audit included an analysis of reimbursable expenses paid directly to the 10

employee and expenses that were paid by SCE on behalf of the employee. This included an assessment 11

of expense reports and related supporting documentation. 12

SCE agreed to perform the reviews for years 2004, 2005, and 2006. In addition, to cover the 13

remaining reimbursable expenses for employees who had reimbursable expenses less than $25,000, SCE 14

agreed to perform a statistically-significant study for recorded 2006 expenses. As of the NOI filing, the 15

reviews for 2004 and 2005 had been completed. The results of the 2006 reviews were completed after 16

SCE’s NOI filing and, as such, the results are included below. 17

For 2004, SCE reviewed $1,457,946 in reimbursable expenses paid to or on behalf of 31 18

employees. The detailed review determined that of the 982 expense records reviewed: 800 expense 19

records (totaling $1,243,658) correctly recorded either customer or shareholder reimbursable expenses, 7 20

expense records (totaling $7,560) could not be located, and 175 expense records (totaling $206,728) had 21

charged reimbursable expenses incorrectly to customers totaling $58,281, or 4.0 percent of the 22

$1,457,946 population.5 23 4 Effective December 14, 2006, General Order 77-L was superseded by General Order 77-M per CPUC Decision

06-012-029. Thus, the 2006 reviews were performed using the information included in SCE’s General Order 77-M filing.

5 The expense records that could not be located and the incorrectly charged reimbursable expense records were removed from the 2009 General Rate Case for forecasting purposes. See workpapers for results summary of 2004 reimbursable expense review.

22


employees. The detailed review determined that of the 1,560 expense records reviewed: 1,488 expense 2

records (totaling $2,243,019) correctly recorded either customer or shareholder reimbursable expenses, 3

24 expense records (totaling $41,055) could not be located, and 48 expense records (totaling $57,301) 4

had charged reimbursable expenses incorrectly to customers totaling $29,130, or 1.2 percent of the 5

$2,341,374 population.6 6


employees. The detailed review determined that of the 1,290 expense records reviewed: 1,149 expense 8

records (totaling $1,132,297) correctly recorded either customer or shareholder reimbursable expenses, 9

16 expense records (totaling $28,066 of which $21,071 was charged to a customer account) could not be 10

located, and 125 expense records (totaling $176,630) had charged reimbursable expenses incorrectly to 11

customers totaling $45,981, or 3.4 percent of the $1,336,992 population. 12

In response to SCE’s data request from the 2003 GRC (SCE-ORA-18, Question 2), DRA stated 13

that “a tolerable [error] rate [for reimbursable expenses] is 5% or less.” In addition, as noted by ALJ 14

Fukutome in the 2006 GRC Decision 06-05-016, “SCE stated that while it will correct any errors found 15

in the review, it is important to note that since the sample will not be statistically significant (selected at 16

random), any error found in the judgmentally selected sample cannot be extrapolated to the entire 17

population. SCE is correct.” As such, SCE agrees to remove expenses totaling $65,841, $70,185 and 18

$67,052 for 2004, 2005 and 2006, respectively, for forecasting purposes.7 19

6 The expense records that could not be located and the incorrectly charged reimbursable expense records were removed

from the 2009 General Rate Case for forecasting purposes. See workpapers for results summary of 2005 reimbursable expense review.

7 The $65,841 includes $58,281 for reimbursable expenses that were incorrectly recorded to a customer account and $7,560 for expense records that could not be located. The $70,185 includes $29,130 for reimbursable expenses that were incorrectly recorded to a customer account and $41,055 for expense records that could not be located. The $67,052 includes $45,981 for reimbursable expenses that were incorrectly recorded to a customer account and $21,071 for the customer recorded portion of expense records that could not be located.

23

B. Results of Statistically Significant Review - 2006 1

In 2006 GRC Decision 06-05-016, SCE also agreed to perform a statistically-significant review 2

that will include the remaining employees whose annual reimbursable expenses are less than $25,000, 3

similar to the review performed for the 2006 GRC. 4

Pursuant to D.06-05-016, SCE conducted a review of recorded 2006 reimbursable expenses to 5

verify that reimbursable expenses charged to ratepayer accounts (and thus reflected in the General Rate 6

Case) were appropriate ratepayer expenses and not expenses that should be charged to shareholder 7

accounts or below-the-line.8 In its review, SCE determined by use of a statistically valid sampling 8

methodology that there were some reimbursable expenses that were inadvertently charged to ratepayer 9

accounts. Based on this sample, SCE determined that the most likely error was $301,001, or 1.61%. 10

Thus, $301,001 of the $18,729,190 recorded 2006 reimbursable expenses (“The Population”), should 11

have been charged to shareholder funded accounts instead of ratepayer funded accounts. 12

Since it is impractical to review all of the expense reports for a given year, SCE used a Monetary 13

Unit Sampling (MUS) statistical methodology which selects a statistically representative sample of 14

expense reports to make inferences about the entire Population. SCE used ACL for Windows, a 15

statistical software application to select a statistically valid sample of expense reports to review. The 16

$18,729,190 population9 was not stratified because there was no reasonable basis to conclude that one 17

group of expense reports had a greater likelihood of containing errors. 18

The ACL software, using a 95% confidence interval, selected a sample size of 432 expense 19

reports, with reimbursable expenses totaling $406,962. ACL did not allow for the same expense report 20

(duplicate record) to be selected twice. The detailed review of this sample determined that of the 432 21

expense reports reviewed: 409 expense reports (totaling $383,073) correctly classified either ratepayer 22

or shareholder reimbursable expenses, 9 expense reports (totaling $6,812) could not be located, and 14 23

8 SCE’s review did not look at those expenses charged to shareholder accounts to determine if any should have been

charged to ratepayers. 9 The $18,729,190 sample population refers to total reimbursable expenses recorded in 2006 that were not included in the

2006 General Order 77-M Review.

24

expense reports (totaling $17,077) had charged reimbursable expenses incorrectly to ratepayers totaling 1

$9,011 or 2.21% of the $406,962 sample.10 Again, in response to SCE’s data request from the 2003 2

GRC (SCE-0RA-18, Question 2), DRA stated that “a tolerable [error] rate [for reimbursable expenses] is 3

5% or less.” 4

Under the MUS methodology, the most likely error is statistically extrapolated to The 5

Population. The MUS methodology assumes that the error in the sample is typical of the error in The 6

Population. Using a 95% confidence interval, the MUS statistical results extrapolated the sample error 7

into the most likely error for The Population of $301,001, or 1.61%. SCE agrees to make the 8

appropriate adjustment to exclude $301,001 of 2006 recorded reimbursable expenses from its 2009 GRC 9

forecast. 10

C. Reimbursable Expense Reviews Are No Longer Necessary 11

SCE has performed reimbursable expense reviews for each of the last three years leading up to 12

the 2009 General Rate Case. In response to SCE’s data request from the 2003 GRC (SCE-0RA-18, 13

Question 2), DRA stated that “a tolerable [error] rate [for reimbursable expenses] is 5% or less.” For 14

years 2004, 2005, and 2006, the error rates identified in the reimbursable expense reviews were 4.0%, 15

1.2%, 3.4% (for the non-statistical review), and 2.21% (for the statistical review), respectively, which is 16

well under the DRA’s 5% tolerable error rate. 17

SCE believes that the performance of these reimbursable expense reviews satisfies the 18

requirement set forth in Decision 06-05-016. These reviews have demonstrated that SCE has solid 19

internal controls in place in order to mitigate the risk of incorrectly reporting shareholder expenses in 20

ratepayer accounts; and therefore, these studies should no longer be required for future GRCs. In 21

addition, these reviews are labor intensive. The labor cost associated with performing the reviews is 22

more than the adjustment to the GRC; thus, these reviews are not a benefit to our customers. 23

10 For the nine expense reports that could not be located, SCE assumed an error rate of 2.21%, which is consistent with the

error found in the remainder of the sample. This is a reasonable assumption since there is nothing that indicates that these nine expense reports had any greater likelihood of having shareholder funded expenses included in them, and that those expenses would have inadvertently been charged to ratepayers in error.

Appendix A

Witness Qualifications

A-1

SOUTHERN CALIFORNIA EDISON COMPANY 1

QUALIFICATIONS AND PREPARED TESTIMONY 2

OF ZACHARY BUHLER 3

Q. Please state your name and business address for the record. 4

A. My name is Zachary Buhler, and my business address is 2244 Walnut Grove Avenue, 5

Rosemead, California 91770. 6

Q. Briefly describe your present responsibilities at the Southern California Edison Company. 7

A. I am a Project Manager in the Affiliates Compliance Office for SCE’s Regulatory Policy 8

and Affairs Department. I am responsible for SCE’s compliance with non-tariffed 9

products and services. 10

Q. Briefly describe your educational and professional background. 11

A. I have a Bachelor of Arts degree in Law and Society from the University of California, 12

Santa Barbara, and a Master of Arts degree from the Peter F. Drucker Graduate School of 13

Management at Claremont Graduate University. I began my career at SCE in 1996 in the 14

Research, Development and Demonstration Department and in 1998 I began working in 15

the Regulatory Policy and Affairs Department. 16

Q. What is the purpose of your testimony in this proceeding? 17

A. The purpose of my testimony in this proceeding is to sponsor the portions of Exhibit 18

SCE-13, entitled Compliance, as identified in the Table of Contents thereto. 19

Q. Was this material prepared by you or under your supervision? 20

A. Yes, it was. 21

Q. Insofar as this material is factual in nature, do you believe it to be correct? 22

A. Yes, I do. 23

Q. Insofar as this material is in the nature of opinion or judgment, does it represent your best 24

judgment? 25

A. Yes, it does. 26

Q. Does this conclude your qualifications and prepared testimony? 27

A-2

A. Yes, it does. 1

A-3



OF SUSAN P. DIBERNARDO 3


A. My name is Susan DiBernardo, and my business address is 2244 Walnut Grove Avenue, 5



A. Currently, I am a project manager in the Regulatory Policy & Affairs Department. I am a 8

member of the General Rate Case team responsible for providing support to business 9

units in the development of SCE’s 2009 General Rate Case. 10


A. I graduated from the University of Southern California with a Bachelor of Arts degree in 12

psychology and also attended numerous business courses. In addition, I earned a 13

Master’s Degree in Business Administration from the University of Nevada, Reno. I 14

have also earned the designation of Certified Internal Auditor (CIA). In 2000, I joined 15

SCE as a Corporate Auditor within the within the Audit Services Department. My 16

responsibilities included audit and advisory services for business units in the areas of 17

Transmission & Distribution, Generation, Shared Services, and Regulatory Policy & 18

Affairs, and others as required. Audit services include the assessment of corporate risk 19

areas, adequacy of internal controls, special investigations, and the evaluation of SCE 20

compliance with regulatory requirements/directives. In 2005, I joined the Regulatory 21

Compliance/Audits & Investigations group where I worked with external regulators 22

during their performance of regulatory audits as well as worked with our internal 23

business units to ensure compliance with regulatory requirements. 24




A-4


A. Yes, it was. 2


A. Yes, I do. 4


judgment? 6

A. Yes, it does. 7


A. Yes, it does. 9

A-5



OF ROBERT RAMIREZ 3


A. My name is Robert Ramirez, and my business address is 2244 Walnut Grove Avenue, 5



A. I am the Manager of Regulatory Compliance in the Regulatory Policy and Affairs 8

(RP&A) Department. My responsibilities include regulatory support of SCE’s 9

implementation of Affiliate Rules, Non- Tariff Products and Services and Revenue 10

Reporting; project management of regulatory activities involving safety inspections and 11

emergency response standards; and the tracking of SCE’s compliance with Commission 12

directives. 13


A. I received a Bachelor of Arts degree in Psychology from California State University at 15

Dominguez Hills in 1975. I have held various analytical and managerial positions within 16

SCE’s information technology and regulatory organizations with responsibility for the 17

development of various software applications, management of load research projects, 18

development of the revenue reporting function, and the implementation of regulatory 19

compliance processes. From 1980 through 1995, I was in the Information Technology 20

Department. From 1995 to 2005 I was the Manager of Organizational Effectiveness for 21

RP&A. Since 2005, I have held my current position. 22





A. Yes, it was. 27

A-6


A. Yes, I do. 2


judgment? 4

A. Yes, it does. 5


A. Yes, it does. 7

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