Southern California Edison Company 2021 GRC

A.19-08-013

TURN HEARING EXHIBIT

TURN-044

SCE response to TURN Data Request 91-03 Selected pages from www.nuclearmatters.org and www.nei.org

Southern California Edison A.19-08-013 – SCE 2021 General Rate Case

DATA REQUEST SET T U R N - S C E - 0 9 1

To: TURN

Prepared by: BOB BLEDSOE Job Title: Senior Advisor Received Date: 6/18/2020

Response Date: 6/29/2020

Question 03.a-d: On page 46, SCE references the percentage of Nuclear Energy Institute (NEI) membership dues that are “attributable to lobbying expenses” pursuant to Section 6033(e) of the Internal Revenue Code. a. How does Section 6033(e) define “lobbying expenses”? b. When did NEI begin identifying the portion of membership dues “attributable to lobbying expenses” pursuant to Section 6033(e)? c. Indicate the extent to which the following activities conducted by NEI are classified as “lobbying expenses” under the Section 6033(e) definition: 1. General advocacy of nuclear power, both nationally and globally. 2. Public policy advocacy in support of nuclear power 3. Participation in proceedings at the Federal Energy Regulatory Commission 4. Participation in formal proceedings at the US Nuclear Regulatory Commission and informal advocacy before the agency 5. Participation in proceedings by state utility commissions 6. Grants to 501(c)(3) organizations 7. Grants to 501(c)(4) organizations 8. Advertising expenditures 9. Support for the “Nuclear Matters” website (www.nuclearmatters.com) 10. Advocacy for wholesale electricity market reforms 11. Advocacy for new nuclear reactor development in the United States. 12. Advocacy for 123 agreements between the United States and other nations. 13. Advocacy for reforms to the Export-Import Bank 14. Advocacy for streamlining the processing of Part 810 applications by the US Department of Energy authorizing nuclear technology exports. d. Provide the three most recent annual reports produced by the Nuclear Energy Institute.

TURN-SCE-091: 03.a-d Page 2 of 2

Response to Question 03.a-d: a. To discuss how Section 6033(e) defines “lobbying expenses” requires a legal conclusion.

Internal Revenue Code (IRC) Section 6033(e)(1)(A)(ii) requires exempt organizations to provide notice to their members of the reasonable estimate of the portion of dues to which such “lobbying expenditures” are so allocable. Section 6033(e) incorporates the definition of lobbying expenditures in IRC 162(e)(1). NEI includes in its lobbying calculation all expenses related to support or opposition to legislation, advocacy on an election or national referendum, and direct communication with a covered executive branch official to influence their policy decision and state and federal legislators on specific legislation. NEI does not calculate the lobbying expenses by issue, nor is NEI required to do so under the IRC 6033(e).

b. NEI has complied with Section 6033(e) continually since it was established in 1994. c. Indicate the extent to which the following activities conducted by NEI are classified as

“lobbying expenses” under the Section 6033(e) definition: 1. See answer to part “a” above. 2. NEI includes in its lobbying calculation all expenses related to support or opposition to

legislation, advocacy on an election or national referendum, and direct communication with a covered executive branch official to influence their policy decision and state and federal legislators on specific legislation, does not calculate the lobbying expenses by issue, nor is NEI required to under the IRC 6033(e).

3. thru 9. See answer to part “a” above. 10. NEI engages in lobbying on legislation that supports electricity market reforms and

includes it in its lobbying calculation. 11. NEI engages in lobbying on legislation that supports new reactor development and

includes it in its lobbying calculation. 12. NEI engages in lobbying for legislation and Executive Branch policy that supports U.S.

nuclear exports and includes it in its lobbying calculation. 13. NEI has engaged in lobbying for legislation that supports the function of the Export-

Import Bank and has included it in its lobbying calculation. 14. NEI engages in lobbying for legislation that supports the streamlining export control

regulation under Part 810 and includes it in its lobbying calculation. d. NEI no longer produces a public “President’s Report” or annual report. NEI does produce an

annual plan, which is confidential and for members only, to which NEI programs, activities and initiatives are reported against. This annual plan results in a year-end report that is shared with members. SCE is providing the last three years’ report under the existing non-disclosure agreement between SCE and TURN.

CONFIDENTIAL

The Attachments Are Marked Confidential In Accordance With D. 16-08-024 and D.17-09-023. Basis for Confidentiality In Accompanying Confidentiality Declaration.

Public Disclosure Restricted.

7/5/20, 4)51 PMAbout

Page 1 of 5https://www.nuclearmatters.com/about

Our Mission

Nuclear Matters is a national coalition that works to inform the

public and policymakers about the clear benefits of nuclear

energy. The coalition supports solutions that properly value

nuclear energy as a reliable, affordable, safe and carbon-free

electricity resource that is essential to America’s energy future.

Nuclear Matters combines the former CASEnergy Coalition and

Nuclear Advocacy Network (NAN) with Nuclear Matters to form

a single, broad-based, multifunctional entity to leverage a

diverse community of advocates and support solutions that

encourage current and future nuclear energy use.

Nuclear Matters engages stakeholders and energy consumers

around the country to educate and activate them in support of

nuclear energy and to promote solutions that will help to

preserve this essential energy resource.

Advocacy Council

ABOUT

®

7/5/20, 5(23 PMTake Action

Page 1 of 2https://www.nei.org/take-action

Take ActionBecome a nuclear advocate today!

You’ve been reading about the benefits of nuclear energy and how it makes the world brighter andthe future cleaner. Now, it's time to act.

Be Heard With Nuclear MattersSupport the largest source of clean electricity by becoming an advocate for nuclear energy. JoinNuclear Matters, NEI’s advocacy coalition, to get updates and action alerts on how to preservenuclear energy for future generations.

J O I N N U C L E A R M A T T E R S T O D AY

A Platform for Nuclear AdvocatesNuclear Matters works throughout the country, championing the advantages of nuclear energy. NewYork, Illinois, Connecticut and New Jersey have already taken action—and other states areconsidering similar actions. Nuclear Matters has been adding allies and rallying support for measuresacross the United States. Through targeted campaigns, Nuclear Matters helps ordinary peopleorganize and promote policies that support this essential energy source. With Nuclear Matters, youcan get engaged.

Political Involvement

7/5/20, 5(23 PMTake Action

Page 2 of 2https://www.nei.org/take-action

NEI’s Federal Political Action Committee (PAC) supports legislators working to ensure the nuclearenergy industry remains strong. As a member of Nuclear Matters, you will be able to learn moreabout the PAC and its efforts. Join Nuclear Matters now to learn more.

Your Voice Is Needed in the Nuclear Energy DebateDon’t stay on the sidelines. You can help defend local economies, keep pollutants and carbon out ofthe air, and power space travel and high-tech innovation by becoming a nuclear advocate. In 2017,Nuclear Matters helped grass-roots allies send more than 5,000 messages to lawmakers. Will youmake your voice heard?

Amplify your voice:

Support a local Nuclear Matters campaign and share it with your friends on social media.

Find your lawmakers and ask them to show love for nuclear energy. Contact them via Twitter,send a letter or make a phone call.

Become a member of Nuclear Matters and learn how to get involved in the NEI Federal PAC.

Donate to Nuclear Matters today.

7/5/20, 5(16 PMAdvantages

Page 1 of 2https://www.nei.org/advantages

The Advantages of Nuclear EnergyPowering our way of life while barely leaving a trace.

Nuclear powers America’s cities and towns more reliably than any other energy source. It holds thekey to our high-tech future and drives our highest hopes for a brighter world. It creates thousands ofjobs and adds billions to our economy. It keeps our grid online and our homeland safe. It stays on nomatter what Mother Nature throws at it. And it is by far our largest source of clean energy.

— P R E S I D E N T D W I G H T D . E I S E N H O W E R

This plant—using the power of the atom to supply electrical power—represents what can be done, not only in America, but throughout the world,to put the atom to work for the good of mankind.”

“

National SecurityAmerica’s nuclear energy industry shapes international safetyrules. But our leadership is now at risk. Learn why nuclear energyis mission-critical to our national security.

ClimateNuclear produces more of America’s carbon-free electricity thanall other clean energy sources combined. See how nuclear fightsclimate change on multiple fronts.

Technology LeadershipWe pioneered nuclear technology for the world and are poised torevolutionize it again. Learn how our next-generation nucleartechnology is driving the energy future.

7/5/20, 5(16 PMAdvantages

Page 2 of 2https://www.nei.org/advantages

InfrastructureAmericans will need 28 percent more electricity by 2050. Learnhow nuclear power can fill the gap, carbon-free.

JobsNuclear power plants create more job growth than any other typeof energy facility. See how nuclear provides approximately475,000 direct and secondary jobs in the United States.

Air QualityNuclear energy emits zero air pollutants. Learn how nuclear goesthe furthest in protecting public health and helping states complywith the Clean Air Act.

Sustainable DevelopmentMore than 1 billion people worldwide live without electricity. See how nuclear can give developingnations a low-cost, ever-ready, safe, secure and clean source of energy.

Electric VehiclesNuclear already provides nearly 55 percent of our carbon-freeelectricity. Learn how nuclear technology can support electricvehicles to reduce fossil fuel-reliance even more.

7/5/20, 5(15 PMAdvocacy

Page 1 of 2https://www.nei.org/advocacy

AdvocacyWho benefits from nuclear energy? Our communities. Our environment.Our health. Our economy. Aren’t they worth advocating for?

At NEI, we work to drive policies that promote the beneficial uses of nuclear energy. We take pride inour role of resolving complex technical and business issues. Here we provide accurate and timelyinformation on important advocacy issues to inform your decision-making.

Preserve Nuclear PlantsDozens of nuclear reactors in the United States may be at risk ofclosing in the next five to 10 years. Preventing unnecessary plantclosures can save jobs, secure our grid and sustain progress onclean energy goals.

Make Regulations SmarterWith right-sized regulations, we can implement even safertechnology and support our nuclear fleet. It’s time to embrace anew generation of nuclear fuel designs and resolve lingeringissues like second license renewals, decommissioning and usednuclear fuel management.

Build New ReactorsThe next generation of reactors will protect the climate, boost theeconomy with long-term, well-paying jobs and ensure our globalleadership and national security. Government partnership isessential for small modular and advanced reactors to be licensed

7/5/20, 5(15 PMAdvocacy

Page 2 of 2https://www.nei.org/advocacy

A Winning StrategyThe National Nuclear Energy Strategy, developed by NEI and the U.S. nuclear industry, outlines fourkey initiatives to guide policy.

PRESERVE: We must preserve the current fleet of nuclear power plants and ensure theirattributes are appropriately valued at national, regional and state levels.

SUSTAIN: We can sustain efficient operations of the existing fleet through smarter regulationsand sharing best practices.

INNOVATE: Innovating new nuclear technologies will help deliver a cleaner energy future.

THRIVE: Thriving in the global nuclear energy marketplace is essential to our country’sleadership abroad.

essential for small modular and advanced reactors to be licensedand commercialized quickly enough to make a difference.

Compete GloballyThe global nuclear energy market offers a multibillion-dollaropportunity and direct influence over international nuclear safetyand nonproliferation. Yet our ability to compete is hampered byour own system. Small steps can help us compete withoutcompromising safety and security standards.