2021 General Rate Case Rebuttal Testimony · 8 rebuttal testimony is an update for 2019 recorded...

Application No.: A.19-08-013 Exhibit No.: SCE-12 Vol. 01 Witnesses: K. Payne D. Snow

(U 338-E)

2021 General Rate Case Rebuttal Testimony

Policy

Before the

Public Utilities Commission of the State of California

Rosemead, California June 12, 2020

SCE-12, Vol. 01: Policy

Table Of Contents

Section Page Witness

-i-

I. INTRODUCTION .............................................................................................1 K. Payne

II. SCE POLICY REBUTTAL TO CAL ADVOCATES AND TURN TESTIMONY ....................................................................................................4

A. Cal Advocates’ And TURN’s Massive Proposed Reductions To SCE’s Most Important Wildfire Mitigation Program Are Unwarranted And Jeopardize Public Safety ....................4

1. Cal Advocates Incorrectly Assumes That SCE Will Be Unable To Fully Execute Its Requested Scope Of Work .....................................................................................5

2. TURN’s Opposition To The Scope Of WCCP Is Misguided ..................................................................................6

B. Cal Advocates’ And TURN’s Proposals For Shareholders To Fund Wildfire Liability Insurance Premiums Is Contrary To All Precedent And Would Undermine The Legislative Intent Of AB 1054 .................................................................................9

C. Cal Advocates’ And TURN’s Depreciation Proposals Would Unduly Burden Future Customers With Costs Associated With Assets Now Benefitting Current Customers ............................................................................................10

III. IMPACT OF COVID 19 ..................................................................................11

IV. SCE’S PROPOSALS CONTINUE TO MAINTAIN CUSTOMER AFFORDABILITY ..........................................................................................14

V. CHANGE IN REQUESTED REVENUE REQUIREMENT ..........................17 D. Snow

Appendix A Data Request Response

1

I. 1

INTRODUCTION 2

In this 2021 GRC, we have set forth a comprehensive proposal for 2021-20231 to continue 3

crucial wildfire risk mitigation activities and maintain necessary wildfire liability insurance to protect 4

our customers; affirm our commitment to SCE’s long-term goals of safety, reliability, responsive 5

customer service and clean energy; and achieve the appropriate balance between funding the necessary 6

work and maintaining customer affordability. Our initial filing included a requested revenue requirement 7

for Test Year 2021 of $7.625 billion, with an increase larger than what we have sought in the recent 8

past.2 Over the pendency of the proceeding, we have removed or reduced certain aspects of our original 9

proposal; accordingly, in this Rebuttal Testimony we have reduced our 2021 revenue requirement 10

request to $7.549 billion. 11

We fully acknowledged at the time of our original filing, and continue to recognize, the 12

magnitude of our request and its corresponding impact on our customers’ rates. But we also continue to 13

believe that our request strikes the necessary and appropriate balance between authorization for 14

time-sensitive public safety measures and doing what we can to re-prioritize or scale back other 15

initiatives that, while prudent and necessary, can be addressed in future GRCs. Catastrophic wildfire risk 16

remains an existential problem facing the citizens of this State, and SCE must continue to take all 17

immediate actions within our reasonable control to reduce the threat that wildfires pose to the 18

communities we are privileged to serve. That continues to remain true even in light of the COVID-19 19

global health pandemic that has emerged since we filed our GRC application. In response to the 20

pandemic, SCE has appropriately put into effect wide-ranging customer-protection measures to address 21

the near-term resulting economic effects customers are experiencing. In this GRC, however, SCE is 22

requesting the necessary funding to fulfill its mission to make the longer-term investments required now 23

to continue to deliver safe, reliable, affordable and increasingly clean electricity for more than 15 24

million Californians. 25

1 In the April 17, 2020 Amended Scoping Memo and Ruling of Assigned Commissioner and Assigned

Administrative Law Judges, a “Track 4” was added to this proceeding to address the third attrition year (i.e., 2024) contemplated by the Commission in Decision 20-01-002, which modified the utilities’ Rate Case Plans. When SCE filed its application, SCE’s proposed revenue requirement for this rate case cycle did not anticipate a fourth attrition year, but SCE will set forth a funding request for 2024 pursuant to the schedule set forth in the Amended Scoping Memo for Track 4.

2 November 7, 2019 Amended Application.

2

SCE has robustly supported our funding requests: In our prepared testimony and supporting 1

workpapers, we provided detailed analysis of recorded and forecast costs broken down into about 350 2

individual GRC activities. This work is needed to provide the electrical infrastructure and programs 3

necessary to implement the State’s laws and ambitious public policy goals, including protecting against 4

wildfires, de-carbonizing the economy through widespread electrification, and safely and reliably 5

integrating distributed energy resources across a rapidly modernizing grid. Since the time we submitted 6

our application, direct testimony and supporting workpapers to the parties and the Commission for their 7

review starting almost one year ago, more than a dozen parties have engaged in extensive discovery 8

concerning the details of our request, leading to more than 4,400 data request responses. 9

On April 10th of this year, the California Public Advocates Office (Cal Advocates) submitted its 10

recommendations for the GRC funding it proposes the Commission authorize for SCE in 2021. Of the 11

$1,103 million increase SCE proposes, Cal Advocates recommends an approximately $650 million 12

reduction, or 59%.3 Cal Advocates’ testimony was followed by recommendations from ten different 13

intervenor parties on May 5th. Some of those other intervenors, such as The Utility Reform Network 14

(TURN), had expansive recommendations that, like Cal Advocates, span across the GRC. For example, 15

TURN recommends reducing SCE’s proposed requested increase by 79% (approximately $875) 16

million).4 Other parties addressed much more limited and focused areas, which is typical in GRCs given 17

the breadth of the proceeding and the wide range of interested parties. In the following twelve exhibits 18

of rebuttal testimony, SCE addresses all Cal Advocates and intervenor proposals as warranted.5 This 19

policy rebuttal testimony is focused on and is structured as follows: 20

Chapter II rebuts at a high level three of the most impactful proposals from Cal Advocates 21

and TURN from a public safety, revenue requirement and regulatory policy standpoint. 22

Specifically, Chapter II first discusses Cal Advocates’ and TURN’s unjustified proposals to 23

dramatically reduce SCE’s most important public safety wildfire mitigation program, known 24

as Wildfire Covered Conductor Program (WCCP). WCCP is the most effective and 25

expeditious way for SCE to buy-down public safety risk by preventing the ignitions that can 26

3 Reduction is based on SCE’s preliminary modeling of Cal Advocates’ testimony.

4 Reduction is based on SCE’s preliminary modeling of TURN’s testimony.

5 A select few intervenor proposals are, in SCE’s view, beyond the appropriate scope of this proceeding, and are subject to currently pending legal motions to strike.

3

lead to catastrophic wildfires. Second, we also rebut those intervenors’ proposals to 1

inappropriately assign the cost of wildfire liability insurance to shareholders. Such insurance 2

is a routine cost of service that has always been included in customer rates and provides vital 3

financial protection to customers from third-party liability claims arising from wildfires. 4

Third, Chapter II discusses Cal Advocates’ and TURN’s depreciation proposals, which if 5

adopted would inappropriately assign to future customers an inequitable burden of future net 6

salvage costs for assets that are in-service and benefitting current customers. More detailed 7

rebuttal testimony comprehensively addressing these positions also follows in other exhibits. 8

Chapter III discusses the ongoing COVID-19 pandemic, and advocates that the 9

Commission’s appropriate near-term responses to the economic fall-out from that pandemic 10

should be viewed separately from SCE’s proposed 2021-2023 GRC revenue requirement. 11

Chapter IV emphasizes how SCE’s proposals in this GRC, if adopted, will continue to 12

maintain affordability of our services for our customers. 13

Chapter V, which is sponsored by our GRC Director, Doug Snow, addresses the specific 14

changes in SCE’s proposed revenue requirement resulting from various updates for recorded 15

2019 data, amendments, errata, adjustments and concessions that SCE has made since filing 16

its original application.17

4

II. 1

SCE POLICY REBUTTAL TO CAL ADVOCATES AND TURN TESTIMONY 2

A. Cal Advocates’ And TURN’s Massive Proposed Reductions To SCE’s Most Important 3

Wildfire Mitigation Program Are Unwarranted And Jeopardize Public Safety 4

As SCE explained in its direct testimony, the highest priority and most important program in our 5

wide-ranging and comprehensive suite of wildfire mitigation programs and activities is our Wildfire 6

Covered Conductor Program (WCCP). Here, SCE is aggressively but prudently installing “covered 7

conductor” throughout the High Fire Risk Areas (HFRA) in our service territory in a risk-prioritized 8

manner. Based on our fault and ignition history, overhead conductors are the biggest contributors to 9

overall ignition risk, and installing covered conductor is the most effective and expeditious way for SCE 10

to safeguard the public and the communities we serve from wildfire risk. Moreover, the only realistic 11

viable alternatives to covered conductor that provide all of the equivalent risk-reduction benefits are 12

widespread undergrounding of energized equipment or repeated and increasing use of Public Power 13

Safety Shutoffs (PSPS). The former is cost-prohibitive and infeasible over the near-term; the latter is 14

contrary to Commission policy and not a viable long-term solution given the impacts of de-energization 15

on our customers and communities. 16

Without seriously challenging the proposition that installing covered conductor is the most 17

reasonable path to protect people and property from wildfire risk, Cal Advocates and TURN 18

nevertheless propose massive reductions to SCE’s forecast scope of work. SCE’s direct testimony 19

provides robust support for our position that it is prudent and important to install approximately 6,200 20

miles of WCCP covered conductor from the inception of the program in late 2018 through the original 21

end of this GRC cycle in 2023. To be clear, 6,200 miles is not the total number of miles SCE would 22

propose to install in the absence of labor resource constraints, but rather represents the feasible scope of 23

work we can reasonably expect to complete given those existing constraints. 24

Cal Advocates proposes that SCE install only 4,291 miles through 2023, an overall reduction of 25

some 32%, and TURN proposes an even more truncated scope, i.e. 2,500 miles through 2023, an overall 26

reduction of some 60%. These deep proposed cuts are unjustified and the Commission should reject 27

them in order to protect public safety. The Table II-1 below reflects the parties’ respective proposals on 28

the appropriate scope of covered conductor through 2023. 29

5

Table II-1 Summary of Parties’ Positions on Covered Conductor Scope (Circuit Miles)6

1. Cal Advocates Incorrectly Assumes That SCE Will Be Unable To Fully Execute Its 1

Requested Scope Of Work 2

Cal Advocates’ argument focuses on what it perceives as SCE’s inability to “ramp up” to 3

the forecast levels SCE proposes in its testimony. Accordingly, Cal Advocates recommends a scope of 4

1,000 miles in each of the GRC years. This is a drastic reduction compared to SCE’s forecast of 1,400, 5

1,600, and 1,900 miles for 2021-2023, respectively. Cal Advocates is simply incorrect that SCE cannot 6

or will not effectively “ramp up” to its forecast levels. WCCP is SCE’s most important public safety 7

program. In line with its importance, SCE has dedicated all necessary and available resources to 8

implement the program at the levels needed to protect public safety. As we explained in our direct 9

testimony, SCE has materially reduced spending elsewhere, including on infrastructure replacement 10

programs, in order to increase labor resource availability for WCCP. While those other programs remain 11

important and will continue to be necessary in the future, at this time SCE is appropriately and 12

predominantly focused on WCCP given its unparalleled risk-reduction benefits for public safety. 13

Finally, Cal Advocates’ argument that SCE will likely only be able to “ramp up” to execute 1,000 miles 14

starting in 2021 is belied by the fact that SCE remains on track to install more than 1,000 miles this year, 15

in 2020. 16

6 SCE proposes to use 2019 Recorded in place of 2019 Forecast as its rebuttal position. The original total scope

amount is 6,191 miles. Cal Advocates accepts SCE’s 2019 Forecast until 2019 Actuals are reviewed and validated by parties and the Commission. Cal Advocates does not specify its 2022-2023 Forecast in testimony, but its RO model shows the same dollar amount as SCE’s. Accordingly, SCE assumes Cal Advocates’ position is 1,000 miles each for 2022-2023. TURN did not specify 2019-2020 scope in its testimony, but proposed 2,500 cumulative miles, which implies that TURN accepts SCE’s 2019 and 2020 forecast of 291 and 1,000 miles, respectively.

6

2. TURN’s Opposition To The Scope Of WCCP Is Misguided 1

TURN’s opposition to the scope of SCE’s WCCP proposals, on the other hand, is 2

primarily focused on how much covered conductor SCE should install, instead of how much SCE can 3

install.7 In TURN’s view, because there is a diminishing marginal level of risk reduction per-mile as 4

more miles are completed in the highest-risk areas, SCE should stop installing covered conductor at a 5

point relatively early on the “risk buy-down curve.” TURN argues that areas further down the risk 6

buy-down curve are less risky and therefore it is less cost-effective to install covered conductor in those 7

areas as compared to earlier areas. In other words, TURN believes that stopping covered conductor 8

installation at 2,500 circuit miles provides the public with what TURN unilaterally deems to constitute 9

an acceptable level of ongoing public safety risk. 10

We vigorously disagree with such a view as discussed at length in our detailed rebuttal 11

testimony set forth in Exhibit SCE-15, Volume 5. TURN’s view of the risk-buy down curve is 12

misinformed by the way that the curve is structured and by its natural limitations. The fact that more 13

relative risk is “bought down” on earlier-installed circuit miles as compared to later-installed miles is 14

both expected and positive: It is a natural consequence of SCE’s installation of circuit miles pursuant to 15

our risk-informed prioritization methodology. In other words, because SCE is installing covered 16

conductor first on the riskiest segments, it is natural that later-installed segments will have 17

proportionally less risk reduction, from a relative perspective. In addition, because of the fact that circuit 18

segments furthest to the left on the curve are extremely risky, and as a result of how the model that 19

creates the curve works, the curve looks steep. Our detailed rebuttal testimony discusses the various 20

important reasons the Commission should view risk reduction differently. 21

At a high level, we strongly believe that TURN is not looking at the issue from the 22

correct perspective, for the following reasons. First, the risk buy-down curve is measuring relative risk 23

7 TURN’s testimony that “the actual increases sought in its request here are driven largely by costs not tied to

wildfire prevention” (Exhibit TURN-01 at p. 3) understates the magnitude and importance of our wildfire prevention activities included in this GRC, which include necessary funding for other important programs in addition to WCCP and enhanced vegetation management. These include Enhanced Overhead Inspections for our distribution and transmission lines, Public Power Safety Shutoff (PSPS), Community Resiliency Incentive programs, advanced fire science modelling, and others. TURN also misinterprets AB 1054’s equity rate base exclusion, which pertains to capital expenditures included in a utility’s wildfire mitigation plan. As to the latter issue, SCE expects to reach its AB 1054 statutory cap of $1.575 billion in early 2021; therefore any capital expenditures incurred after that date will be included in equity rate base and therefore do impact the 2021-2024 revenue requirements reflected in SCE’s showing. Those forecast expenditures are substantial.

7

reduction, not absolute risk reduction. As shown in the detailed rebuttal testimony in Exhibit SCE-15, 1

Volume 5, destructive wildfires recently have occurred in SCE’s service territory on circuit miles 2

located in areas on the risk buy-down curve that TURN would want to leave uncovered. In other words, 3

there remains a substantial amount of wildfire risk beyond the circuit miles that TURN’s proposal would 4

address. SCE’s proposal, on the other hand, would buy down a substantial amount of absolute risk. 5

Second, even more destructive wildfires could occur in such areas. It is important to keep 6

in mind that WCCP is almost exclusively focused on “Tier 3” and “Tier 2” HFRA, which the 7

Commission has already deemed to have inherently “extreme” and “elevated” wildfire risk, respectively. 8

The Commission made that risk determination after a rigorous, scientific process using the same kind of 9

risk modelling that SCE uses. That mathematical model only simulates the estimated effects of a 10

wildfire that burns for six hours (a limitation of the model). Experience has taught us that extremely 11

dangerous and destructive fires like the Thomas and Woolsey fires can last for days, not hours. The risk 12

of a relatively small fire becoming a catastrophic fire such as those is largely driven by exogenous 13

factors (most importantly weather and fire-fighting response) that are not only outside of SCE’s 14

reasonable control but also are not sufficiently captured in the risk curve’s modelling.8 It is critical to 15

keep in mind that many potential ignitions – given the wrong conditions – could turn into the next 16

catastrophic wildfire event. It is the frequency of ignitions that covered conductor is uniquely conducive 17

to reducing. And the majority of ignitions associated with SCE’s utility infrastructure are associated 18

with risk drivers covered conductor addresses, as discussed at length in our wildfire-specific direct and 19

rebuttal testimony. 20

Third, the risk curve modelling was completed at a fixed point in time based on historical 21

data (many of which pre-dated the climate change impacts that the State is currently experiencing). 22

The Commission should recognize the inherent limitations of overly relying on such a “snapshot” view, 23

especially in the wildfire context. It is beyond reasonable dispute that California’s population continues 24

to expand into the wildland-urban interface and that the climate continues to warm. Unfortunately, both 25

factors make future catastrophic wildfires more likely. SCE cannot control either of those factors, but it 26

can significantly reduce the number of ignitions associated with our equipment. Covered conductor is 27

the most effective way to do so. 28

8 While the model that produced the risk buy-down curve does consider historical long-term weather data, it

cannot predict real-time extreme weather events. Nor can it model the relative effectiveness or ineffectiveness of third-party firefighting response.

8

Fourth, the risk curve assumptions in the model are heavily weighted towards acres 1

burned instead of structures and people impacted by a potential wildfire. Focusing on the latter instead, 2

as demonstrated in SCE’s detailed wildfire rebuttal testimony, the curve appears much “flatter.” In other 3

words, there are significant numbers of homes and businesses that could be impacted by potential 4

wildfires starting much further down the risk curve as compared to areas that TURN would propose 5

covering. Even more important than structures affected by a potential wildfire, are the hundreds of 6

thousands of people living in SCE’s HFRA in areas that TURN’s proposal would exclude from the 7

protection of WCCP. As explained in more detail in Exhibit SCE-15, Volume 5, that population includes 8

thousands of critical care customers and critical infrastructure customers. In SCE’s view, despite the 9

natural mathematical effect of diminishing relative risk reduction that results from installing covered 10

conductor in a risk-prioritized fashion, it remains important to include in WCCP the people and 11

communities that would be left out if one focuses solely on that single measure.9 12

In the end, we urge the Commission to view the risk buy-down curve for what it is: 13

A mathematical model that demonstrates the right covered conductor circuit prioritization, not the right 14

amount of covered conductor circuit final scope. In other words, the risk model demonstrates where 15

covered conductor installation should start, not the appropriate place it should stop. Cal Advocates and 16

TURN propose accepting the material ongoing risk that would result from a vastly reduced scope of 17

WCCP, leaving the majority of the HFRA unprotected by the risk-mitigation benefits of covered 18

conductor. Cal Advocates and TURN propose accepting the material ongoing risk that would result from 19

a vastly reduced scope of WCCP, leaving the majority of the HFRA unprotected by the risk-mitigation 20

benefits of covered conductor. Their proposals do not go far enough. Just as the State, amidst an 21

unprecedented health pandemic crisis, continues to seriously invest resources into mitigating the risk of 22

wildfires, so should SCE. The greatest benefit SCE can provide the State and its firefighting resources is 23

avoided ignitions that could potentially lead to the kinds of catastrophic wildfires whose frequency is 24

increasing because of climate change. And that is what SCE’s WCCP request in this GRC aspires to do. 25

Covered conductor is particularly effective at reducing the types of ignitions that occur during high-wind 26

events, which happen to be the same kinds of weather conditions that can lead to catastrophic wildfires 27

9 In addition, as discussed in Exhibit SCE-15, Volume 5, in order to “target” a certain number of risk-informed

circuit miles, SCE will necessarily have to install additional miles of covered conductor for operational feasibility and efficiency reasons.

9

if an ignition does occur. We urge the Commission to authorize our request and accordingly empower us 1

to help continue to meaningfully address the wildfire crisis. 2

B. Cal Advocates’ And TURN’s Proposals For Shareholders To Fund Wildfire Liability 3

Insurance Premiums Is Contrary To All Precedent And Would Undermine The Legislative 4

Intent Of AB 1054 5

Both Cal Advocates and TURN propose that SCE’s shareholders fund significant portions of 6

SCE’s wildfire liability insurance premium costs (25% in the case of Cal Advocates; 50% in the case of 7

TURN). These recommendations are inappropriate and fundamentally inconsistent with basic 8

cost-of-service ratemaking principles. To start, they are completely without precedent. The Commission 9

has always – and correctly so – included the cost of liability insurance, including wildfire liability 10

insurance, in customer rates as a reasonable cost-of-service. Liability insurance is a normal cost for any 11

business, which is a relatively simple concept that the Commission has long recognized without 12

exception. 13

Wildfire liability insurance is designed to protect customers from third-party legal claims 14

pursued under the inverse condemnation doctrine and for alleged negligence; it is not designed to protect 15

shareholders from the consequences of utility “imprudence,” even if one illogically assumes that one 16

could predict such alleged potential future imprudence on a forecast ratemaking basis. 17

In addition to being wholly without precedent or logical merit, both Cal Advocates’ and TURN’s 18

proposals would also be contrary to the financial responsibility construct the California Legislature 19

adopted last summer in AB 1054. AB 1054 set up the Wildfire Fund, which is designed to cover 20

uninsured losses resulting from wildfires associated with utility infrastructure and is a crucial statutory 21

safeguard that protects the very viability of California utilities. As the Commission has long recognized, 22

financially stable utilities are critical for California customers. As part of the AB 1054 statutory 23

framework, SCE (and the other IOUs) were required to contribute billions of dollars in shareholder 24

funding to pay for what the Legislature deemed to be their equitable share of the cost burden of the 25

Wildfire Fund. 26

AB 1054 requires SCE to maintain a reasonable amount of insurance as determined by the 27

Wildfire Fund Administrator, and also requires that SCE must incur at least $1 billion in wildfire claims 28

10

payments to receive access to the Wildfire Fund.10 Cal Advocates and TURN would have SCE’s 1

shareholders pay for much of the cost for those statutorily-required insurance premiums. Accordingly, 2

their proposals would turn the painstakingly-crafted AB 1054 legislative approach on its head by 3

effectively requiring that SCE’s shareholders – but not PG&E’s or SDG&E’s – pay an additional multi-4

hundred-million-dollar annual “access fee” to the Wildfire Fund. That would be an unwarranted and 5

unsupportable result; there is simply no basis in law, precedent, or logic to support Cal Advocates’ and 6

TURN’s proposals, as discussed in further detail in Exhibit SCE-17, Volume 2. 7

C. Cal Advocates’ And TURN’s Depreciation Proposals Would Unduly Burden Future 8

Customers With Costs Associated With Assets Now Benefitting Current Customers 9

In Exhibit SCE-18, Volume 3, we address Cal Advocates’ and TURN’s depreciation proposals. 10

Our direct testimony explained at length why SCE’s proposal to moderately increase depreciation 11

expense is necessary at this time to begin to reverse the effects of many years of having it set too low. 12

When depreciation expense is set too low, current customers inappropriately avoid some of the future 13

costs of the removal of the utility infrastructure that is in-service now and that they are benefitting from. 14

But this deferral unfairly leaves future customers with that unpaid bill. SCE does not believe that is a 15

responsible ratemaking strategy. Our depreciation proposal—particularly for making progress on a 16

handful of accounts where we are currently not accruing for net salvage at rates sufficient to collect the 17

costs we are experiencing today—represents a reasonable increase to more closely align customer cost 18

responsibility with customer benefits. When paired with SCE’s proposed life extensions, which have the 19

effect of reducing depreciation expense, SCE’s overall proposal is reasonable and urgent. 20

Cal Advocates’ and TURN’s proposals, on the other hand, would further exacerbate the current inequity 21

instead of ameliorating it. 22

10 See Cal. Pub. Util. Code § 3293 (requiring that “[a] participating electrical corporation shall maintain

reasonable [wildfire] insurance coverage.”).

11

III. 1

IMPACT OF COVID 19 2

Cal Advocates “proposes to make an adjustment of $125 million to SCE’s estimated 2020 capital 3

expenditure budget. This adjustment is based upon the recent economic downturn associated with the 4

COVID-19 pandemic.”11 5

SCE is sensitive to the effects that COVID-19 is having on our customers and on the 6

communities we are privileged to serve, but respectfully notes that Cal Advocates’ proposed adjustment 7

is premature. First, the COVID-19 crisis is ongoing. At this juncture, no stakeholder knows to any 8

reasonable degree what the ultimate impacts of the COVID-19 pandemic will be on SCE’s costs, or 9

what will be the timing associated with those impacts. No one knows to what extent the social distancing 10

and restrictions may affect the amount and timing of work that SCE reasonably needs to accomplish. 11

The lack of evidence or analysis underpinning Cal Advocates’ proposal illustrates that it is not 12

possible at this juncture to gauge with any accuracy what the impacts of COVID-19 will be on SCE’s 13

2020 costs. Cal Advocates requests a $125 million reduction, without a single workpaper or analysis in 14

support of that reduction. Cal Advocates simply asserts that the $125 million figure is arrived at by 15

making a 25% reduction in capital expenditures for New Service Connections and Customer Requested 16

Projects.12 Cal Advocates does not even attempt to explain or justify how it arrived at the 25% figure. 17

It simply arbitrarily picks 25%. 18

The arbitrary nature of the 25% proposed reduction is also illustrated through Cal Advocates’ 19

GRC testimony on New Service Connections and Customer-Requested Projects in Exhibit PAO-04. 20

In that exhibit, Cal Advocates effectively adopts SCE’s 2020 forecast.13 21

Moreover, there are likely to be puts and takes when gauging the final impact of the COVID-19 22

crisis on SCE’s GRC request. In some areas, costs may go down in 2020. In other areas, costs appear to 23

11 Exhibit PAO-01, p. 8, lines 8-10.

12 Exhibit PAO-01, lines 16-18.

13 See Exhibit PAO-04, p. 25, Table 4-1b. After adopting SCE’s forecast for New Service Connections and Customer-Requested Projects, Cal Advocates includes a conclusory sentence that illustrates that no analysis can be shown regarding what the actual effects of COVID-19 would be on New Service Connections and Customer-Requested Projects. Cal Advocates simply says: “While not shown or discussed in this volume, it should also be pointed out that the Public Advocates Office is recommending an overall 2020 adjustment to this capital category to reflect the economic downturn due to the COVID-19 pandemic; that adjustment is discussed in Ex. PAO-01.” Exhibit PAO-04, p. 26, lines 7-10.

12

be increasing as a result of COVID-19. For example, SCE’s Information Technology (IT) spending 1

appears to be rising, because of the need to support a substantial majority of the SCE workforce 2

handling their jobs remotely. A second example is occurring with increased bad debt expense.14 3

Further, the Commission and stakeholders are already taking measures to address the effects of 4

COVID-related changes to utility spending. When SCE notified the Commission that SCE would be 5

recording incremental COVID-related costs to its Catastrophic Event Memorandum Account (CEMA),15 6

SCE stated that it also intends to account for savings it may realize that are a direct result of the 7

governmental directives on COVID-19. SCE confirmed in writing that those savings will offset the costs 8

recorded to CEMA for COVID-19.16 The Commission has also taken certain measures to address 9

COVID-related consumer protection costs, such as authorizing the establishment of the COVID 10

Pandemic Protections Memorandum Account (CPPMA) where SCE seeks to record uncollectibles 11

above the levels authorized in the GRC. If there are later adjustments that need to be made due to the 12

effects of COVID-19, such adjustments can occur through ratemaking mechanisms outside the GRC and 13

should not delay the timely processing of this case. 14

COVID-19 is a unique crisis. Reduced activity is occurring because of enforced restrictions. It is 15

the first crisis in modern history where (for health and safety reasons) much of the world essentially 16

forced all but the most essential of economic activities to temporarily grind to a halt. The work SCE 17

needs to perform on its grid will still need to be performed. The mitigations that SCE must undertake to 18

lower the threat of wildfires must still be undertaken. Other economically-driven activity is also likely to 19

increase when economic and social conditions return to normal, or something closer to normal. 20

Making arbitrary reductions now, before fuller information is available on the impact that COVID-19 21

will ultimately have on SCE’s capital work, is premature. This is illustrated by the fact that, as widely 22

announced on May 18, 2020, State government authorities have eased certain COVID-19 restrictions to 23

allow economic and work activities to begin to return to normal.17 Los Angeles County previously 24

14 A bad debt expense is recognized when a receivable is no longer collectible because a customer is unable to

fulfill their obligation to pay an outstanding debt due to financial challenges.

15 See SCE’s March 31, 2020 letter to CPUC Executive Director Alice Stebbins, regarding activation of SCE’s CEMA due to the COVID-19 global pandemic. A copy of this document is found in our workpapers.

16 Id. at p. 2, fn. 7.

17 See Los Angeles Times, May 18, 2020, “Newsom Eases California Reopening Rules, Allowing More Counties to Restart Their Economies.”

13

announced that it intended to more widely reopen by July 4, 2020,18 and reopening steps are accelerating 1

as this testimony is being submitted. 2

Finally, in light of the COVID-19 crisis, the Commission has made mandatory a variety of 3

voluntary consumer protection measures that SCE promptly put in place in early March 2020 to protect 4

residential and small business customers. These protective measures include, but are not limited to, a 5

moratorium on disconnections for nonpayment, and suspension of late fees and deposits. Current 6

information indicates that many of these protections are likely to remain in place at least until April of 7

next year. 8

For all of these reasons, the proposed reduction by Cal Advocates is premature. Adjustments, if 9

any, can be made at a later time through other ratemaking mechanisms when more complete information 10

is available and reasonably accurate adjustments can be made. 11

18 See Los Angeles Times, May 19, 2020, “LA County Aims to Reopen by July 4, Must Rely on Data And

Science, Official Warns.”

14

IV. 1

SCE’S PROPOSALS CONTINUE TO MAINTAIN CUSTOMER AFFORDABILITY 2

As discussed above, SCE fully acknowledges the magnitude of this GRC request, and we are 3

sensitive to its resulting impact on customer bills. However, catastrophic wildfire risk is an existential 4

problem facing the citizens of this State and requires SCE to take all actions within our reasonable 5

control to reduce wildfire risks to our communities.19 That vital wildfire mitigation work—which is the 6

largest driver of our incremental funding request in this proceeding—cannot be delayed. Where 7

possible, SCE has endeavored to reprioritize or scale back other initiatives so that SCE can do what it 8

must to reduce the wildfire risk. However, SCE must also continue to perform its foundational work to 9

maintain and prudently improve the grid, the support functions necessary to provide service to our 10

customers, and efforts needed to implement the State’s vital policy objectives. As explained in detail in 11

Exhibit SCE-18, Volume 4, SCE’s proposed rate increases reflect the costs for these necessary 12

activities.20 13

SCE also demonstrates in Exhibit SCE-18, Volume 4 that overall customer bills will remain 14

affordable, even when considering the necessary investments and associated costs proposed in this 15

GRC.21 In particular, while a single metric alone cannot determine affordability for all customers, SCE 16

presented multiple metrics in its opening testimony which, when considered together, demonstrate that 17

SCE’s requests in this GRC and other proceedings produce affordable bills for those consuming 18

electricity within the “essential usage” or “baseline amount.” 19

First, SCE presented evidence concerning the long-term trend in SCE’s rates and how those rates 20

compare to other major utilities in California. Specifically: 21

SCE’s bundled system average rate (SAR) has generally tracked local area inflation over 22

time;22 23

When adjusting for inflation, SCE’s residential bills compared to twenty years ago are not 24

materially higher;23 25

19 Exhibit SCE-01, Vol. 1, p. 1, lines 28-30.

20 Exhibit SCE-18, Vol. 4, pp. 1-2.


22 Exhibit SCE-07, Vol. 4A, pp. 3-4.


15

Over the last decade, SCE’s overall SAR increase has been below the Consumer Price Index, 1

and SCE’s overall SAR increase has been lower than the overall SAR increases of PG&E 2

and SDG&E;24 and 3

SCE’s average residential bills in 2018 were among the lowest in the nation among large 4

investor-owned utilities (IOUs).25 5

This evidence provides context for SCE’s rate requests, namely that, while SCE is seeking a 6

sizeable rate increase, it is starting from rates that have historically been low compared to SCE’s peers in 7

California and across the country. 8

Second, SCE presented evidence that (1) the average energy burden of California customers (the 9

percentage of a household’s annual income that is spent on electricity) is among the lowest when 10

compared to electric IOU customers nationally, (2) that even if household income remains static from 11

2019-2023, the expected change in energy burden for SCE’s customers would only increase from 2019 12

levels by a little more than 1% on average by 2023; and (3) for SCE customers consuming “essential” 13

amounts of electricity, the anticipated change from 2019-2023 in energy burden would be minimal.26 14

Third, SCE analyzed the Hours at Minimum Wage metric (defined as the time it takes for a 15

customer working at minimum wage to pay essential utility service charges), and showed that the hours 16

worked at minimum wage to pay the essential portion of a monthly SCE bill will not differ materially in 17

2023 compared to 2019. 18

When considered collectively, these metrics (the long-term trends in SCE’s rates, energy burden, 19

and Hours at Minimum Wage) demonstrate that SCE’s requests in this GRC and other proceedings 20

produce affordable bills for those consuming electricity within the essential usage or baseline amount.27 21

Finally, SCE is cognizant of the fact that the COVID-19 pandemic has increased the economic 22

stress for many households and resulted in an unemployment spike. As discussed in Exhibit SCE-18, 23

Volume 4, SCE has worked with the Commission to institute protective measures to mitigate economic 24

hardship from the COVID-19 pandemic for its customers, including temporarily suspending service 25

disconnections, freezing CARE/FERA program standards, and temporarily reducing the high usage 26




27 See also Exhibit SCE-18, Vol. 4, pp. 3-8.

16

charge.28 As the pandemic continues, SCE and the Commission will consider other appropriate customer 1

protections. However, essential work on SCE’s grid still needs to be performed, including mitigations to 2

lower the threat of wildfires. It remains just as critical than ever for the Commission to fund the 3

necessary work for SCE to continue to provide safe and reliable electricity for the 15 million 4

Californians we are privileged to serve. If adopted, SCE’s proposals will allow us to do so, while still 5

maintaining customer affordability. 6


17

V. 1

CHANGE IN REQUESTED REVENUE REQUIREMENT 2

As shown in Figure V-1 below, SCE’s updated 2021 revenue requirement is $7.549 billion, 3

which is $76.6 million lower than the 2021 revenue requirement at the time SCE filed its Amended 4

Application on November 7, 2019. In addition, SCE has also reduced its attrition year funding requests 5

by $61.3 million and $95.6 million in 2022 and 2023, respectively.29 6

Figure V-1 Updates to SCE’s Revenue Requirement ($000s)

As also shown in Figure V-1 above, among the changes included and supported throughout the 7

rebuttal testimony is an update for 2019 recorded capital expenditures. Prior to this rebuttal testimony, 8

SCE included recorded capital expenditures through 2018, and forecasts for the five-year period of 2019 9

through 2023. Consistent with the Rate Case Plan, at the time SCE filed this GRC application 2018 was 10

29 See Exhibit SCE-18 Vol. 1 for the testimony supporting the updated revenue requirements included in rebuttal

testimony. Pursuant to the Amended Scoping Memo, the third attrition year (i.e., 2024) will be examined in Track 4 of this proceeding.

18

the last year of recorded capital information available. It has been common practice for the Commission 1

during the pendency of GRCs to update the first forecast year, or in this GRC, 2019, with recorded 2

amounts once those amounts are known.30 In the last three rate cases, the Commission has updated the 3

first forecast year of capital expenditures with recorded amounts with limited exception. Consistent with 4

the findings in D.12-11-051, the Commission adopted updating for the first forecast year (i.e., 2010) “for 5

all business units where the recorded costs were made available during the course of the proceeding.” 6

The Commission in that same decision goes on to state that “there is nothing in the Rate Case Plan 7

which limits discovery of 2010 actual recorded expenditures and the Commission finds them 8

informative.” More recently the Commission, in Decision (D.)20.01-002 modifying the Rate Case Plan, 9

stated “in the recently concluded SCE 2018 test year GRC, the base year was 2015. However, during the 10

proceeding SCE was able to update its recorded spending data in its June 2017 rebuttal testimony to 11

include all of 2016 (i.e., Base Year +1). It is neither surprising nor alarming that the recorded 2016 data 12

was often very different from the corresponding 2016 forecasts included in SCE’s September 2016 13

application. The Commission’s decision-making benefited from having the recorded 2016 data available 14

because of the improved accuracy, so that should be considered a standard milestone in every energy 15

GRC.”31 16

In response to Cal Advocates Data Request PubAdv-SCE-056-TXB, SCE provided unadjusted 17

recorded 2019 capital expenditure by GRC activity. Table V-2 below includes a summary that compares 18

SCE’s forecast for 2019 and the actual recorded amounts. As can be seen in the table, SCE’s recorded 19

capital expenditures in 2019 were essentially flat as compared to the forecast, with the exception of 20

wildfire mitigation, and other resiliency and grid safety programs (the majority of costs of which were 21

beyond SCE’s control). SCE’s overall Total Company 2019 recorded capital expenditures were 7% 22

greater than forecast. 23

30 The Commission in D.06-05-016, SCE’s 2006 GRC Decision, stated: “In past GRCs, updating for more

recent recorded information, especially for plant related items, was common.”

31 D.20-01-002, pg. 61 (internal quotation omitted).

19

Table V-2 2019 Recorded Vs. Forecast Capital Expenditures ($000s)

In Appendix A, SCE has included the entire response to Cal Advocates’ data request.32 1

As shown in Table V-2, cumulatively the recorded capital expenditures for 2019 are greater than 2

amounts originally forecast by about $282 million. Of that amount, the greatest variance between the 3

forecast and recorded amounts is primarily associated with the spending in the Wildfire Risk Mitigation 4

category shown on the last line of Table V-2.33 In addition, with respect to the Other Resiliency and Grid 5

Safety cost category the actual 2019 recorded capital expenditures were greater than the forecast 6

primarily due to the restoration of power as the result of storms. Cal Advocates has recommended the 7

Commission adopt some but not all of the recorded 2019 capital expenditures amounts. Essentially, in 8

many instances Cal Advocates “cherry picks” those areas where the expenditures ended up being lower 9

than the original forecast and chose not to use the recorded data when the expenditures ended up being 10

higher than the original forecast.34 There is no principled basis for this inconsistency. Consistent with 11

past GRCs, in rebuttal testimony, SCE has updated all the original 2019 capital expenditures with the 12

recorded amounts.35 13

32 Refer to Appendix A, PubAdv-SCE-056-TXB, p. A2 to A5.

33 The actual spend for 2019 for these wildfire activities are being reviewed by the Commission in Tracks 2 and 3 of this proceeding.

34 See, e.g., PAO-07, pp. 31-32.

35 SCE witnesses explain material variances between the original 2019 forecast and the recorded amounts in the respective volumes of rebuttal testimony.

Cost Category2019

Recorded

2019

Forecast

Variance

(Rec. ‐ Forecast)

% Variance

(Rec. ‐ Forecast)

/(Forecast)

Customer Interactions and Support $298,048 $305,341 ($7,293) ‐2%

Generation $90,865 $89,015 $1,850 2%

Infrastructure Replacement, System

Augmentation and Other Grid Support Activities$3,089,081 $3,084,126 $4,955 0%

Other Resil iency & Grid Safety $247,430 $219,904 $27,526 13%

Wildfire Risk Mitigation $649,079 $394,110 $254,969 65%

Totals $4,374,503 $4,092,496 $282,007 7%

20

SCE’s rebuttal testimony also includes certain revenue requirement adjustments to reflect 1

changes due to the discovery of errors and concessions made in response to intervenor positions.36 2

The overall effect of these errata and concessions is a reduction to the proposed revenue requirement.3

36 For example, SCE has conceded to the adoption of Cal Advocates’ proposal to track Distributed Energy

Resources (DER)-driven load growth expenditures in a new memorandum account (see Exhibit SCE-13, Vol. 04, Pt. 2) and TURN’s proposal to adopt a lower commercial meter set forecast (see Exhibit SCE-18, Vol. 1, Chapter IV).

Appendix A

Data Request Response

SCE-12, Vol. 01: Rebuttal Testimony on Policy Appendix A Data Request Response

A1

DATA REQUEST PAGE(S)

PubAdv-SCE-056-TXB A2 - A5

2019 Direct Capital Expenditures (Nominal $000)

Considerations:- Capital expenditures shown above are direct costs; Corporate Overheads have been removed.- Data includes contributions for Distribution and Transmission Joint Pole Capital Credits but excludes all other contributions.- CS Replatform shown in Non-GRC in accordance with SCE Amendment filing.- 2019 forecast shown includes forecasts suppressed in RO Model (suppressions in RO Modek due to small dollar).- Includes capital expenditures that will be removed from the RO model consistent with AB1054.- Non GRC represents capital recovered via other mechanisms.

AreaExhibit/Volume Number

Exhibit Volume Title GRC Activity Forecast 2019 Recorded 2019

GRC SCE-02 , Vol. 1 Pt. 1 SCE-02 Grid Activities Distribution Infrastructure Replacement 4 kV Cutovers 48,326$ 58,414$

GRC SCE-02 , Vol. 1 Pt. 1 SCE-02 Grid Activities Distribution Infrastructure Replacement 4 kV Substation Eliminations 6,054$ 5,857$

GRC SCE-02 , Vol. 1 Pt. 1 SCE-02 Grid Activities Distribution Infrastructure Replacement Automatic Reclosers Replacement Program 2,435$ 1,488$

GRC SCE-02 , Vol. 1 Pt. 1 SCE-02 Grid Activities Distribution Infrastructure Replacement Cable Life Extension (CLE) Program 20,574$ 11,235$

GRC SCE-02 , Vol. 1 Pt. 1 SCE-02 Grid Activities Distribution Infrastructure Replacement Cable-in-Conduit (CIC) Replacement Program 17,074$ 19,973$

GRC SCE-02 , Vol. 1 Pt. 1 SCE-02 Grid Activities Distribution Infrastructure Replacement Capacitor Bank Replacement Program 10,318$ 9,736$

GRC SCE-02 , Vol. 1 Pt. 1 SCE-02 Grid Activities Distribution Infrastructure Replacement Overhead Conductor Program (OCP) 100,063$ 125,029$

GRC SCE-02 , Vol. 1 Pt. 1 SCE-02 Grid Activities Distribution Infrastructure Replacement PCB Transformer Removal 1,813$ 2,114$

GRC SCE-02 , Vol. 1 Pt. 1 SCE-02 Grid Activities Distribution Infrastructure Replacement Underground Structure Replacements 27,573$ 48,247$

GRC SCE-02 , Vol. 1 Pt. 1 SCE-02 Grid Activities Distribution Infrastructure Replacement Underground Switch Replacements 3,389$ 8,594$

GRC SCE-02 , Vol. 1 Pt. 1 SCE-02 Grid Activities Distribution Infrastructure Replacement Worst Circuit Rehabilitation (WCR) 67,291$ 75,231$

GRC SCE-02 , Vol. 1 Pt. 2 SCE-02 Grid Activities Distribution I&M and Capital-Related Distribution Claim 38,879$ 41,848$

GRC SCE-02 , Vol. 1 Pt. 2 SCE-02 Grid Activities Distribution I&M and Capital-RelatedDistribution Preventive and Breakdown Capital Maintenance

280,238$ 363,794$

GRC SCE-02 , Vol. 1 Pt. 2 SCE-02 Grid Activities Distribution I&M and Capital-Related Distribution Tools and Work Equipment 3,325$ 2,947$

GRC SCE-02 , Vol. 1 Pt. 2 SCE-02 Grid Activities Distribution I&M and Capital-Related Distribution Transformers 95,737$ 102,432$

GRC SCE-02 , Vol. 1 Pt. 2 SCE-02 Grid Activities Distribution I&M and Capital-Related Prefabrication 18,946$ 18,267$

GRC SCE-02 , Vol. 1 Pt. 2 SCE-02 Grid Activities Distribution Inspections & Maintenance and Capital-Related Streetlight Maintenance and LED Conversions 52,984$ 52,895$

GRC SCE-02 , Vol. 1 Pt. 3 SCE-02 Grid Activities Meter Activities Meter Engineering 27,327$ 24,270$

GRC SCE-02 , Vol. 1 Pt. 3 SCE-02 Grid Activities Meter Activities Meter System Maintenance Design 850$ 288$

GRC SCE-02 , Vol. 2 SCE-02 Grid Activities Transmission Grid Telecommunication Inspection and Maintenance 3,207$ 5,384$

GRC SCE-02 , Vol. 2 SCE-02 Grid Activities Transmission Grid Transmission Capital Maintenance 43,527$ 32,865$

GRC SCE-02 , Vol. 2 SCE-02 Grid Activities Transmission Grid Transmission Claim 3,344$ 4,315$

GRC SCE-02 , Vol. 2 SCE-02 Grid Activities Transmission Grid Transmission Emergency Equipment 154$ -$

GRC SCE-02 , Vol. 2 SCE-02 Grid Activities Transmission Grid Transmission Line Rating Remediation (TLRR) 129,385$ 116,321$

GRC SCE-02 , Vol. 2 SCE-02 Grid Activities Transmission Grid Transmission Tools and Work Equipment 1,306$ 812$

GRC SCE-02 , Vol. 3 SCE-02 Grid Activities Substation Circuit Breaker Replacement 42,956$ 39,148$

GRC SCE-02 , Vol. 3 SCE-02 Grid Activities Substation Monitoring Bulk Power System 45,925$ 51,412$

GRC SCE-02 , Vol. 3 SCE-02 Grid Activities Substation Oil Containment Diversion System 375$ 635$

GRC SCE-02 , Vol. 3 SCE-02 Grid Activities Substation Preventive Maintenance 45,210$ 65,438$

GRC SCE-02 , Vol. 3 SCE-02 Grid Activities Substation Relays, Protection and Control Replacements 36,655$ 36,402$

GRC SCE-02 , Vol. 3 SCE-02 Grid Activities Substation Substation Capital Breakdown Maintenance 12,241$ 17,259$

GRC SCE-02 , Vol. 3 SCE-02 Grid Activities Substation Substation Claim 369$ (23)$

GRC SCE-02 , Vol. 3 SCE-02 Grid Activities Substation Substation Emergency Equipment 25,116$ 21,598$

GRC SCE-02 , Vol. 3 SCE-02 Grid Activities Substation Substation Switchrack Rebuild 21,320$ 13,382$

GRC SCE-02 , Vol. 3 SCE-02 Grid Activities Substation Substation Tools and Work Equipment 7,202$ 7,398$

GRC SCE-02 , Vol. 3 SCE-02 Grid Activities Substation Substation Transformer Bank Replacement 65,112$ 39,442$

GRC SCE-02 , Vol. 4 Pt. 1 SCE-02 Grid ActivitiesSystem Augmentation - Grid Modernization, Grid Technology, and Energy Storage

Automation 73,398$ 44,368$


Communications 13,445$ 13,483$


DER-Driven Grid Reinforcement 491$ 139$


Energy Storage 18,615$ 2,959$


Energy Storage Deployment -$ 138$

A2




Engineering and Planning Software Tools 36,352$ 36,998$


Grid Management System 33,064$ 32,217$


Laboratory Operations 4,455$ 776$

GRC SCE-02 , Vol. 4 Pt. 2 SCE-02 Grid ActivitiesSystem Augmentation - Load Growth, Transmission Projects, and Engineering

4 kV Cutovers - Load Growth Driven 38,118$ 19,492$


Distribution Circuit Upgrades 50,038$ 53,160$


Distribution Plant Betterment 17,333$ 28,892$


Distribution Substation Plan (DSP) Circuits 36,340$ 30,758$


Distribution Substation Plan Substations 75,829$ 73,063$


Distribution Volt VAR Control and Capacitor Automation Program

2,365$ 2,023$


Generation Interconnection Remedial Action Scheme

4,914$ 3,842$


Grid Reliability Projects 243,286$ 185,738$


Land Rights Management 580$ 1,795$


New Capacitors 9,427$ 6,968$


Other Transmission Projects -$ -$


Renewable Transmission Projects 190,204$ 249,533$


Substation Equipment Replacement Program 16,315$ 11,806$


Transmission Substation Plan (TSP) 87,102$ 73,942$

GRC SCE-02 , Vol. 4 Pt. 3 SCE-02 Grid ActivitiesSystem Augmentation - New Service Connections and Cust. Requested System Mod

Agricultural New Service Connections 6,817$ 3,409$


Commercial New Service Connections 94,359$ 94,111$


Distribution Added Facilities 14,223$ 7,217$


Distribution Relocations 52,947$ 47,747$


Residential New Service Connections 128,246$ 110,480$


Rule 20 B/C Conversions 37,186$ 30,788$


Rule 20A Conversions 16,723$ 12,332$


Streetlights New Service Connections 22,653$ 14,692$


Transmission Relocations 14,692$ 9,012$


Transmission/Substation Added Facilities - Customer Financed

12,805$ 3,956$


Transmission/Substation Added Facilities - SCE Financed

13,637$ 12,724$


WDAT/TO/Gen-Tie - Customer Funded 17,991$ 11,122$


WDAT/TO/Gen-Tie - SCE Funded 5,710$ 2,545$

GRC SCE-02 , Vol. 5 SCE-02 Grid Activities Poles Distribution Deteriorated Pole Replacement 160,108$ 196,678$

GRC SCE-02 , Vol. 5 SCE-02 Grid Activities Poles Distribution Joint Pole Capital Credits (77,447)$ (95,192)$

GRC SCE-02 , Vol. 5 SCE-02 Grid Activities PolesDistribution Pole Loading Program Pole Replacement

174,701$ 157,950$

GRC SCE-02 , Vol. 5 SCE-02 Grid Activities Poles Distribution Wood Pole Disposal 2,582$ 4,669$

GRC SCE-02 , Vol. 5 SCE-02 Grid Activities PolesDistribution Wood Pole Disposal - Pole Loading Program

1,131$ -$

GRC SCE-02 , Vol. 5 SCE-02 Grid Activities PolesTelecommunication Deteriorated Pole Replacement

3,197$ 1,817$

GRC SCE-02 , Vol. 5 SCE-02 Grid Activities PolesTelecommunication Pole Loading Program Replacement

177$ 1$

GRC SCE-02 , Vol. 5 SCE-02 Grid Activities Poles Transmission Deteriorated Pole Replacement 81,228$ 88,766$

GRC SCE-02 , Vol. 5 SCE-02 Grid Activities Poles Transmission Joint Pole Capital Credits (17,581)$ (6,333)$

GRC SCE-02 , Vol. 5 SCE-02 Grid Activities PolesTransmission Pole Loading Program Replacement

29,156$ 41,471$

GRC SCE-02 , Vol. 7 SCE-02 Grid Activities Other Costs and OOR Utility Joint Ownership Obligations 30,614$ 42,582$

GRC SCE-03 , Vol. 5 SCE-03 Customer Interactions Customer Care Services CS Capital 390$ 1,691$

GRC SCE-04 , Vol. 1 SCE-04 Resiliency Business ContinuationAll Hazards Assessment, Mitigation and Analytics

43,900$ 44,981$

GRC SCE-04 , Vol. 2 SCE-04 Resiliency Emergency Management Distribution Storm Response Capital 41,988$ 66,108$

GRC SCE-04 , Vol. 2 SCE-04 Resiliency Emergency Management Transmission/Substation Storm Response Capital 6,164$ 9,605$

GRC SCE-04 , Vol. 3 SCE-04 Resiliency Cybersecurity Cybersecurity Delivery and IT Compliance 36,000$ 44,701$

GRC SCE-04 , Vol. 3 SCE-04 Resiliency Cybersecurity Grid Mod Cybersecurity 25,702$ 26,136$

A3



GRC SCE-04 , Vol. 4 SCE-04 Resiliency Physical Security NERC Compliance Programs 33,303$ 31,572$

GRC SCE-04 , Vol. 4 SCE-04 Resiliency Physical Security Protection of Generation Assets 2,335$ 1,794$

GRC SCE-04 , Vol. 4 SCE-04 Resiliency Physical Security Protection of Grid Infrastructure Assets 20,774$ 12,952$

GRC SCE-04 , Vol. 4 SCE-04 Resiliency Physical Security Protection of Major Business Functions 9,738$ 9,581$

GRC SCE-04 , Vol. 5 SCE-04 Resiliency Wildfire Management Distribution Fault Anticipation 2,340$ 3,445$

GRC SCE-04 , Vol. 5 SCE-04 Resiliency Wildfire ManagementEnhanced Overhead Inspections and Remediations

154,849$ 300,592$

GRC SCE-04 , Vol. 5 SCE-04 Resiliency Wildfire Management Enhanced Situational Awareness 6,364$ 5,252$

GRC SCE-04 , Vol. 5 SCE-04 Resiliency Wildfire Management Fire Science and Advanced Modeling 12,953$ 6,487$

GRC SCE-04 , Vol. 5 SCE-04 Resiliency Wildfire Management Fusing Mitigation 54,795$ 70,298$

GRC SCE-04 , Vol. 5 SCE-04 Resiliency Wildfire Management HFRA Sectionalizing Devices 6,292$ 11,951$

GRC SCE-04 , Vol. 5 SCE-04 Resiliency Wildfire Management PSPS Execution 180$ 1,766$

GRC SCE-04 , Vol. 5 SCE-04 Resiliency Wildfire Management Wildfire Covered Conductor Program 156,337$ 249,288$

GRC SCE-05 , Vol. 1SCE-05 Generation & Energy Procurement

Generation Catalina - Diesel 2,860$ 5,186$


Generation Hydro - Dams and Waterways 12,156$ 14,964$


Generation Hydro - Decommissioning 650$ 790$


Generation Hydro - Electrical Equipment 6,470$ 5,501$


Generation Hydro - Prime Movers 10,470$ 3,086$


Generation Hydro - Relicensing 6,230$ 7,804$


Generation Hydro - Structures and Grounds 8,666$ 7,123$


Generation Mountainview 1,228$ 2,992$


Generation Palo Verde 37,920$ 37,553$


Generation Peakers 1,300$ 1,244$


Generation Solar 100$ 3,878$


Energy Procurement Communications Equipment 965$ 744$

GRC SCE-06 , Vol. 1 Pt. 1 SCE-06 Enterprise Support Enterprise Technology Software Maintenance and Replacement 23,507$ 19,100$

GRC SCE-06 , Vol. 1 Pt. 1 SCE-06 Enterprise Support Enterprise TechnologyTechnology Infrastructure Maintenance and Replacement

50,376$ 51,778$

GRC SCE-06 , Vol. 1 Pt. 2 SCE-06 Enterprise Support Enterprise Technology Technology Solutions 97,870$ 99,383$

GRC SCE-06 , Vol. 2 SCE-06 Enterprise Support Enterprise Planning & Governance Corporate Services -$ (2)$

GRC SCE-06 , Vol. 2 SCE-06 Enterprise Support Enterprise Planning & Governance Digital and Process Transformation 4,545$ 3,703$

GRC SCE-06 , Vol. 2 SCE-06 Enterprise Support Enterprise Planning & Governance Logistics, Graphics, and Center of Excellence 371$ 294$

GRC SCE-06 , Vol. 4 SCE-06 Enterprise SupportEnvironmental Services, Audit, Ethics and Compliance, and Safety Programs

Environmental Programs 560$ 680$

GRC SCE-06 , Vol. 5 SCE-06 Enterprise Support Enterprise Operations Acquire and Dispose of Land Rights 1,580$ 1,119$

GRC SCE-06 , Vol. 5 SCE-06 Enterprise Support Enterprise Operations Air Operations 2,559$ 2,320$

GRC SCE-06 , Vol. 5 SCE-06 Enterprise Support Enterprise Operations CRE Project Management 67,201$ 56,847$

GRC SCE-06 , Vol. 5 SCE-06 Enterprise Support Enterprise Operations Facility Asset Management 53,528$ 58,458$

GRC SCE-06 , Vol. 5 SCE-06 Enterprise Support Enterprise Operations Fleet Asset Management 2,372$ 2,232$

GRC SCE-06 , Vol. 5 SCE-06 Enterprise Support Enterprise Operations Fleet Operations and Maintenance 482$ 445$

GRC Subtotal 4,092,496$ 4,374,503$

Non GRC CS Replatform 131,430$ 112,877$

Non GRC Charge Ready Customer Products and Services -$ 1,553$

Non GRC Charge Ready SCE Portion 12,767$ 7,188$

Non GRC Demonstrations -$ 29$

Non GRC Edison Carrier Solutions 39,662$ 39,319$

Non GRC Financial Oversight and Transactional Processing -$ (11,940)$

Non GRC Long Beach Remediation 805$ 2,006$

Non GRC Mobile Home Park - Customer Side 27,612$ 44,988$

Non GRC Mobile Home Park - SCE Responsibility 18,450$ 136$

A4



Non GRC Other - Catalina (Gas and Water) 915$ 515$

Non GRC SONGS -$ (1)$

Non GRCTransportation Electrification Priority Review Projects

45,724$ 286$

Non GRC Catalina Gas and Water 5,185$ 2,132$

Non-GRC Subtotal 282,550$ 199,088$

Grand Total 4,375,046$ 4,573,591$

A5

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2021 General Rate Case Rebuttal Testimony · 8 rebuttal testimony is an update for 2019 recorded...

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