BEFORE THE PUBLIC UTILITIES COMMISSION OF THE STATE OF CALIFORNIA Application of Southern California Edison Company (U 338-E) for Authority to Securitize Certain Costs and Expenses Pursuant to Public Utilities Code Section 850 et seq. Application No. 20-07-008 SOUTHERN CALIFORNIA EDISON COMPANY'S (U 338-E) NOTICE OF EX PARTE COMMUNICATION CLAIRE E. TORCHIA KATHLEEN BRENNAN DE JESUS Attorneys for SOUTHERN CALIFORNIA EDISON COMPANY 2244 Walnut Grove Avenue Post Office Box 800 Rosemead, California 91770 Telephone: (626) 302-6945 E-mail: [email protected]Dated: July 13, 2020
Transcript
BEFORE THE PUBLIC UTILITIES COMMISSION OF THE
STATE OF CALIFORNIA
Application of Southern California Edison Company (U 338-E) for Authority to Securitize Certain Costs and Expenses Pursuant to Public Utilities Code Section 850 et seq.
Application No. 20-07-008
SOUTHERN CALIFORNIA EDISON COMPANY'S (U 338-E)
NOTICE OF EX PARTE COMMUNICATION
CLAIRE E. TORCHIA KATHLEEN BRENNAN DE JESUS
Attorneys for SOUTHERN CALIFORNIA EDISON COMPANY
2244 Walnut Grove Avenue Post Office Box 800 Rosemead, California 91770 Telephone: (626) 302-6945 E-mail: [email protected]
Dated: July 13, 2020
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BEFORE THE PUBLIC UTILITIES COMMISSION OF THE
STATE OF CALIFORNIA
Application of Southern California Edison Company (U 338-E) for Authority to Securitize Certain Costs and Expenses Pursuant to Public Utilities Code Section 850 et seq.
Application No. 20-07-008
SOUTHERN CALIFORNIA EDISON COMPANY'S (U 338-E)
NOTICE OF EX PARTE COMMUNICATION
Southern California Edison Company (SCE) hereby gives notice pursuant to Rule 8.4(a) of the
Rules of Practice and Procedure of the California Public Utilities Commission (Commission) of the
following communication.
DATE AND TIME OF COMMUNICATION: July 13, 2020 from 1:00 p.m. to 1:30 p.m.
TYPE OF COMMUNICATION: Telephonic.
WHO INITIATED THE COMMUNICATION: SCE
NAMES AND TITLES OF NON-CPUC INDIVIDUALS PRESENT: (1) Katie Sloan, Director of
Transportation Electrification; (2) Laura Genao, SCE Managing Director of Regulatory Affairs; and (3)
Lorene Miller, Managing Director of Customer Service Re-Platform Project.
NAMES AND TITLES OF CPUC INDIVIDUALS PRESENT:
Maria Sotero, Advisor to Commissioner Guzman Aceves.
BRIEF DESCRIPTION OF COMMUNICATION: Ms. Sloan, Ms. Genao, and Ms. Miller provided
an update on the Customer Service Re-Platform (CSRP) project using the attached materials.
WRITTEN MATERIALS PROVIDED: Yes, the attached materials were provided on the same day as
the meeting.
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Respectfully submitted, KATHLEEN BRENNAN DE JESUS CLAIRE E. TORCHIA
/s/ Claire E. Torchia By: Claire E. Torchia
Attorneys for SOUTHERN CALIFORNIA EDISON COMPANY
2244 Walnut Grove Avenue Post Office Box 800 Rosemead, California 91770 Telephone: (626) 302-6945 E-mail: [email protected]
July 13, 2020
Appendix A
From: Laura Genao Sent: Monday, July 13, 2020 8:51 AM To: '[email protected]' Subject: Materials for today's meeting with SCE Attachments: CPUC CSRP Update Exparte (July 2020) Final.pdf
Good morning, Maria. Attached are materials for use during our call later today.
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Customer Service Re-Platform (CSRP) Project Update
July 2020
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CSRP Project Background and Update Background SCE's existing Customer Service System has become outdated and costly to maintain
• System is core to customer billing, customer programs and service interactions • Custom mainframe-based aging system is less reliable and hinders service to customers • An assessment of system failure risk led to the decision to upgrade and replace the
majority of customer systems
Customer Service Re-Platform (CSRP) project will modernize the technology and improve service to customers
• SAP solution will enable greater reliability, efficiency, and a better customer experience • Project originally targeted for delivery in April 2020
Project Update • Project experienced delays in 2019 due to unanticipated complexity and issues identified
during testing • Project team shifted to remote work in March 2020 with minimal impacts from COVID-19
to date; project plan was updated to support virtual training delivery and deployment • Testing has been progressing well and current test cycle will complete by August 2020 • Any new regulatory requirements for 2020 or 2021 will need to be assessed for impacts
due to CSRP system freeze and implementation timing
Implementation target window is early 2nd quarter of 2021; Go-Live date expected to be confirmed in September 2020
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Plan & Analyze 6 months
Design 6 months
Build 9 months
Test 12 months
Deploy 8‐10 months
Stabilize 6+ months
2021 2020 2019 2018 2017
System Freeze*
Risks • Implementing new scope or code changes
during the CSRP system freeze introduces significant risk
• 3rd Parties must make changes to their systems to test new interfaces with SCE
• Operational resources will be increasingly focused on CSRP implementation
• Our objective is to reduce risks of potential billing and customer care issues
Timeline • SCE carefully considered regulatory
mandates and associated risks in confirming its implementation schedule
• SCE remains committed to Residential Time-of-Use and Community Choice Aggregation migration timelines
• SCE has assessed the CSRP timeline and system freeze impact on external projects to coordinate timing
CSRP program launched in 2017 and will implement in 2021 Requires a “system freeze” in the months before and after Go-Live
* System freeze expected to run through early 4th quarter 2021; new complex automation changes may not be available until 2022 due to system freeze and TOU/CCA implementations in 4th quarter 2021
Training Course Development / Prep for Virtual Training End User and Refresher Training
Temporary Operations Hiring & Training
2020 Community Choice Aggregation (CCA) Implementations
Temporary Operations Ramp-Down
2021 CCA Implementations
System Testing and Final Code Hand-Off
User Acceptance Testing
Customer Service Re-Platform Timeline 2020 2021
Jan Feb Mar Apr May Jun Jul Aug Sep Oct Nov Dec Jan Feb Mar Apr May Jun Jul Aug Sep Oct
Final Data Prep and Imp'l Cutover
Go-Live Window
External Projects**
System Freeze
2020 Community Choice Aggregation
(CCA) Implementations April - October 2020 Five entities with ~230k service accounts migrating to CCA
October 2020 Residential Time-of-Use (TOU) to begin and Critical Peak Pricing for non-residential customers to resume annual default
Temporary Operations Ramp-Down
2021 CCA Implementations
Timing to be confirmed for two new CCAs (~80k accounts)
Jan/Feb 2021 Annual rate factor changes
April 2021 COVID-19 protections expire; Disconnections OIR measures begin
October 2021 Re-start TOU default migration (continues through March 2022)
* Go-Live is followed by a six-month stabilization period where system and process changes will be limited ** Timing of 2021 rate changes for pending proceedings and system automation to support Disconnection not yet confirmed
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Training Course Development / Prep for Virtual Training
Residential TOU & CCA Timelines Residential TOU (D.18-05-011, D.18-12-004, D.19-07-004)
• Full rollout schedule approved for October 2020 - March 2022 - Customer notifications have begun for October 2020 rate defaulting, then rollout will
pause for ~1 year for CSRP system stabilization - Out of 4.2 million residential accounts, 2.8 million are eligible* for TOU default: 400k
have already gone through TOU migration, 230k will migrate by October 2020, and ~2.2 million will migrate October 2021 - March 2022.
• Rate conversations for new customers and TOU as the standard rate at turn-on to begin October 2020
- Phone center and online experience on track to execute on-time
Community Choice Aggregation (CCA) • Reached agreement on timing with five CCAs for implementation in 2020 • Targeting October 2021 for two new CCA implementations; coordinating timing
of additional CCA accounts and CCA TOU migration schedule in 2021
*Accounts with less than 12 months of usage and CARE/FERA eligible/enrolled customers in hot zones are not eligible. 5
Any new regulatory requirements for 2020 or 2021 will need to be assessed for impacts due to CSRP implementation timing
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Disconnection and Other Proceedings* Disconnection (D.20-06-003) • Assessing current system options and potential manual workarounds
- Arrearage Management Program (AMP) and LIHEAP portal and payment posting changes cannot be automated before Q4 2021
Manual Billing and Workarounds • Limited capacity to accommodate new requirements in 2020 and 2021 • Resources planned to support Disconnection proceeding, Disadvantaged
Community Green tariffs, Enhanced Community Renewables and several other projects
• Billing exception work expected to increase with TOU and CCA implementations Rate Changes • Several customer rate changes in 2021 are planned for coordination with CSRP
implementation timing - Annual and seasonal factor changes and other active proceedings underway - AB1054 Safety Investment Securitization and EITE credits expected by April 2021 - New PCIA line item on bundled customer bills required by December 31, 2021
* Primary focus is on billing and customer care areas that may have longer lead times due to automation and testing requirements ** Some automation changes may not be available until 2022 due to system freeze and TOU/CCA implementations in 4th quarter 2021
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SCE's Revenue Services Organization has staffed additional resources to support manual billing and workarounds until early 2022**
and encompasses over 200 discrete application systems • Scope includes complex rates, customer programs, regulatory environment,
and market participants with frequent changes in mandates and utility requirements
• Increasing customer expectations, digital engagement, data privacy and security needs
• First adoption of SAP utility and cloud solutions at scale • Integration with ~300 internal and external systems supporting 5 million
customer accounts and used by 4,200 employees and 800 third-party stakeholders
• Extensive data volumes with 600 million rows for migration,18 terabytes of storage, and nine technical environments
• Custom development of SAP and Nexant solutions for program enrollment and rebates
• Covers 25% of company SOx controls and 20% of Customer Service compliance requirements
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2021 General Rate Case (GRC)
• SCE updated its 2021 General Rate Case testimony in February 2020 to remove CSRP related costs and benefits and include costs to support existing systems
- Approximately $275 million in project-related costs were removed
• CSRP implementation related costs will continue to record to memorandum account approved in 2018 General Rate Case*
- Total forecasted capital expenditures for the CSRP project are approximately $540 million from inception through 2021
- Cost increases driven by extended implementation timeframe and unanticipated complexity of SCE rates and interfacing system changes
• CSRP on-going costs and benefits will also be tracked and recorded after project implementation
• Cost recovery will be sought in a future standalone application
*In the 2018 GRC, SCE provided a cost estimate to the CPUC of $209 million in capital expenditures for the CSRP program.
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CSRP requires a "system freeze" before and after Go-Live
• Implementing new scope or code changes introduces significant risk - Data in legacy systems must be as clean as possible or customer billing issues may arise - Need to test and compare output from old and new systems before Go-Live - Changes after Go-Live will be limited to defect correction and stabilization needs for up
to six months while users become proficient in the new system
• 3rd Parties making changes to their systems and test new interfaces with SCE - Changes in data exchange formats and new SCE account numbers for all customers
• Operational resources will be increasingly focused on CSRP implementation
- The most significant impact will be in late 2020 and early 2021 due to training - Several hundred temporary staff will be hired starting in mid-2020 to mitigate impacts
until users are fully proficient and the new system has stabilized - If focus is diverted to support other system or process changes, then resources may not
be sufficiently trained to effectively perform their functions
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Managing Risk: Common CIS Implementation Challenges
Potential Customer Challenges > Data migration errors As with all large-scale software projects, there are inherent risks associated with the implementation that may affect customers
> Billing errors > Delays in pursuing collections > Increased handle times > Billing and service order delays
Efforts to Minimize Customer Impacts
> Peer Assessments - Apply best practices from other large utilities with similar projects
> System Integrator - Partnership with experienced vendors to oversee the implementation
> Data Cleansing and Testing - Extensive data cleansing and testing efforts to ensure integrity of the solution
> Quality Assurance - Third-party reviews to ensure high quality deliverables and risk mitigation
> Temporary Operations Staffing - Increased staffing levels during stabilization to minimize customer impacts while staff is becoming proficient with the new system
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CPUC Staff and Working Group Briefings on CSRP • November 2, 2016 - 2018 GRC Overview of CSRP • June 27, 2017 - CIS Workshop (with SDG&E and PG&E) • August 14, 2017 - TOU Working Session Update • May 24, 2019 - Energy Division and Western Community Energy CCA Discussion • September 16, 2019 - Ex Parte Update on CSRP Schedule • December 12, 2019 - Ex Parte Update on CSRP Status and Schedule • December 13, 2010 - TOU - Residential Electric Rates Summit • March 2, 2020 - Ex Parte Update on CSRP Status and Schedule • May 7, 2020 - Energy Division and Monterey Bay CCA Discussion
