BEFORE THE PUBLIC UTILITIES COMMISSION OF THE STATE OF CALIFORNIA

REPLY COMMENTS OF SCE REGARDING COMMISSION STAFF PROPOSAL FOR EPIC POLICY + INNOVATION COORDINATION GROUP TABLE OF CONTENTS Section Page I. INTRODUCTION...1 II. SCE AGREES WITH THE CEC THAT THE PICG SHOULD NOT SECOND- GUESS APPROVED PORTFOLIOS, BUT CAN SERVE AS A FORUM TO EXAMINE NEW PROJECTS...2 III. SCE SUPPORTS ORA S POSITION THAT THE PICG SHOULD COORDINATE WITH ALL RELEVANT PROCEEDINGS...3 IV. PROJECT BENEFITS ARE ALREADY PROVIDED IN FINAL PROJECT REPORTS, WHICH ARE INCLUDED IN THE EPIC ANNUAL REPORTS...3 V. CONCLUSION...4 -i-

BEFORE THE PUBLIC UTILITIES COMMISSION OF THE STATE OF CALIFORNIA In the Matter of the Application of Pacific Gas and Electric Company for Approval of its 2018-2020 Electric Program Investment Charge Investment Plan And Consolidated Matters. A.17-04-028 (Filed April 28, 2017) A.17-05-003 A.17-05-005 A.17-05-009 REPLY COMMENTS OF SOUTHERN CALIFORNIA EDISON COMPANY (U-338-E) REGARDING COMMISSION STAFF PROPOSAL FOR AN ELECTRIC PROGRAM INVESTMENT CHARGE POLICY + INNOVATION COORDINATION GROUP I. INTRODUCTION Southern California Edison Company (SCE) respectfully submits these Reply Comments pursuant to the Energy Division (ED) Staff s proposal for an Electric Program Investment Charge (EPIC) Policy + Innovation Coordination Group (PICG). This proposal was attached to Commission Decision (D.)18-01-008. 1 SCE supports the PICG, and our Opening Comments offered suggestions to the proposed scope to help make the proposed activities more efficient and effective. The PICG could certainly assist in identifying EPIC technology gaps, and areas that need shoring up in order to more ably support California energy policy goals and Commission proceedings. Furthermore, the PICG has the potential to provide meaningful feedback on emerging technologies, thereby helping increase portfolio flexibility and improve program effectiveness. This PICG framework benefits the Administrators and the Commission by limiting technology gaps and providing guidance on new projects, while also educating and informing interested stakeholders as to how EPIC fosters policy goals and assists Commission proceedings. 1 Decision Addressing Approval of the California Energy Commission (CEC), Pacific Gas and Electric Company (PG&E), SCE, and San Diego Gas & Electric Company (SDG&E) Triennial Investment Plans for the EPIC program for years 2018 through 2020 and modifying D.12-05-037. 1

II. SCE AGREES WITH THE CEC THAT THE PICG SHOULD NOT SECOND-GUESS APPROVED PORTFOLIOS, BUT CAN SERVE AS A FORUM TO EXAMINE NEW PROJECTS SCE supports the CEC s view that the PICG should not add a process that second guesses the results of the Commission s proceedings or its approval of an administrator s investment plan. 2 As noted in SCE s Opening Comments, SCE recommends that the PICG focus on coordination, and in particular provide meaningful feedback on emerging technologies and policy issues. The PICG can potentially increase portfolio flexibility and improve program effectiveness by replacing the existing advice letter process for new projects with the PICG s proposed PIPA feedback engagement process. 3 If the PICG identifies a technology gap, and there is consensus from the PICG that the project meets the requirements of EPIC, the Utility Administrators would then be able to implement the demonstration. As an example, the recent Wine Country and Tubbs wildfires that California experienced late last year have had devastating consequences. 4 Back when the Utility Administrators filed their respective EPIC 2018-2020 (EPIC III) Investment Plans, wildfires were not contemplated as a policy issue that needed to be addressed through EPIC. However, at a recent Commission Safety En Banc, President Picker stated that EPIC Portfolios should have the flexibility to address wildfire risks. 5 The PICG can potentially provide such a forum. This would benefit the Administrators and the Commission by making EPIC more dynamic and flexible in responding to emerging issues, while also fostering an environment to educate and inform interested stakeholders as to how EPIC supports policy goals and assists Commission proceedings. 2 CEC Opening Comments at p. 3. 3 Opening Comments at p. 3; SCE Evaluation Report Opening Comments at p. 5. 4 See, e.g., California Department of Insurance Press Release, December 12, 2017. This press release can be found online at https://www.insurance.ca.gov/0400-news/0100-press-releases/2017/release135-17.cfm 5 Commission Wildfire Safety En Banc, January 31, 2018. 2

III. SCE SUPPORTS ORA S POSITION THAT THE PICG SHOULD COORDINATE WITH ALL RELEVANT PROCEEDINGS SCE supports ORA s comment that PICG coordination should extend to all relevant proceedings and programs where the EPIC Program may serve a useful role. 6 SCE agrees with ORA that the PICG presents an opportunity to better align Commission policy goals and avoid mandates for the Utilities to execute demonstrations outside the confines of the EPIC Program. 7 As evidence, ORA references the Distributed Resources Plan (DRP) proceeding. 8 ORA states that although the EPIC Program is the Commission s primary program for reviewing and approving the Utilities technology demonstration and deployment (TD&D) projects, it was not included within the list of key proceedings the Commission identified for coordination with the DRP. 9 ORA further notes that only SCE used its EPIC portfolio to execute one of its DRP Demos. 10 SCE has consistently taken this view in EPIC, as well as other proceedings. And SCE agrees with ORA that it is important to proactively look for opportunities to leverage existing assets to reduce costs for the benefit of our customers. IV. PROJECT BENEFITS ARE ALREADY PROVIDED IN FINAL PROJECT REPORTS, WHICH ARE INCLUDED IN THE EPIC ANNUAL REPORTS SCE wishes to clarify one point ORA raised. ORA s recommendation to identify and document ratepayer benefits, and, thereafter verify that the benefits are actually accruing to 6 ORA Opening Comments at p. 5. 7 Ibid. 8 Commission Rulemaking (R.)14-08-013. 9 ORA Opening Comments at p. 8. 10 ORA Opening Comments at p. 6; D.17-02-007, pp. 13-14. For DRP Demo D, the Commission recognized that SCE s proposal also utilizes its existing Integrate Grid Project (IGP) that is funded through the Electric Program Investment Charge (EPIC). Id. at p. 13. The Commission stated: SCE is instructed to utilize EPIC funding to meet the non-procurement expenses. Id. at pp. 13-14. See also R.14-08-013, Assigned Commissioner s Ruling on Guidance for Public Utilities Code Section 769 Distribution Resource Planning (filed February 6, 2015), Attachment, p. 6 (encouraging the Utilities to coordinate the DRP Demos with the Utilities smart grid deployment plan and EPIC investment plan, when feasible). 3

ratepayers is already being addressed to a significant degree. Such information can be found in EPIC final project reports. These final project reports are included in the EPIC Annual Reports. 11 In addition to the final project reports, project benefits are also discussed during the annual Symposium for highlighted projects. Therefore, SCE recommends that the PICG not prioritize further discussion of project benefits. Instead the PICG would be more effective if it focused on coordination. In this way, the PICG can identify technology gaps and provide meaningful feedback, and pinpoint future opportunities to align policy goals and leverage EPIC for additional applications (e.g., supporting the DRP) and thereby reduce costs to customers. V. CONCLUSION SCE appreciates the opportunity to provide these Reply Comments regarding the Commission Staff s proposal for the PICG. SCE supports the CEC s view that the PICG should not be a forum to second-guess approved Portfolios. SCE also supports ORA s suggestion that the PICG would be most effective if it focused on coordinating with all relevant proceedings. SCE recommends specifically focusing on identifying technology gaps and providing meaningful feedback. SCE further proposes that the PICG PIPA engagement and consensus process replace the existing advice letter process for new projects. This should improve portfolio flexibility and enhance program effectiveness when emergent technology and policy issues arise. SCE looks forward to participating in the PICG, and establishing an EPIC program that is more dynamic, responds more quickly to technology changes and gaps, and fosters greater transparency and coordination with interested stakeholders. 11 See, e.g., SCE 2017 EPIC Annual Report, Final Reports, Project Results Section. 4

Respectfully submitted, KRIS G. VYAS WALKER A. MATTHEWS, III /s/ Kris G. Vyas By: Kris G. Vyas Attorneys for SOUTHERN CALIFORNIA EDISON COMPANY 2244 Walnut Grove Avenue Post Office Box 800 Rosemead, California 91770 Telephone: (626) 302-6613 Facsimile: (626) 302-6997 E-mail: kris.vyas@sce.com March 15, 2018 5

BEFORE THE PUBLIC UTILITIES COMMISSION OF THE STATE OF CALIFORNIA In the Matter of the Application of Pacific Gas and Electric Company for Approval of its 2018-2020 Electric Program Investment Charge Investment Plan And Consolidated Matters. A.17-04-028 (Filed April 28, 2017) A.17-05-003 A.17-05-005 A.17-05-009 CERTIFICATE OF SERVICE I hereby certify that, pursuant to the Commission s Rules of Practice and Procedure, I have this day served a true copy of REPLY COMMENTS OF SOUTHERN CALIFORNIA EDISON COMPANY (U-338-E) REGARDING COMMISSION STAFF PROPOSAL FOR AN ELECTRIC PROGRAM INVESTMENT CHARGE POLICY + INNOVATION COORDINATION GROUP on all parties identified on the attached consolidated service list(s): A.17-04-028 et al. Service was effected by one or more means indicated below: Transmitting the copies via e-mail to all parties who have provided an e-mail address. Placing the copies in sealed envelopes and causing such envelopes to be delivered by hand or by overnight courier to the offices of the Assigned ALJ(s) or other addressee(s), and by U.S. mail to those on the service list without an email address. ALJ Stephen C. Roscow CPUC 505 Van Ness Ave. San Francisco, CA 94102 Executed March 15, 2018, at Rosemead, California. /s/gina Leisure Gina Leisure SOUTHERN CALIFORNIA EDISON COMPANY 2244 Walnut Grove Avenue Post Office Box 800 Rosemead, California 91770

CPUC - Service Lists - A1704028 https://ia.cpuc.ca.gov/servicelists/a1704028_84365.htm Page 1 of 5 3/15/2018 CPUC Home CALIFORNIA PUBLIC UTILITIES COMMISSION Service Lists PROCEEDING: A1704028 - PG&E - FOR APPROVAL FILER: LIST NAME: LIST LAST CHANGED: FEBRUARY 27, 2018 Download the Comma-delimited File About Comma-delimited Files Back to Service Lists Index Parties MADELINE STANO MARIA STAMAS ENERGY LEGAL COUNSEL LEGAL FELLOW, ENERGY PROGRAM THE GREENLINING INSTITUTE NATURAL RESOURCES DEFENSE COUNCIL, CA 00000, CA 00000 FOR: THE GREENLINING INSTITUTE FOR: NATURAL RESOURCES DEFENSE COUNCIL (NRDC) KRIS G. VYAS, ESQ. JAMES ANDERSON SR. ATTORNEY PRESIDENT AND CEO SOUTHERN CALIFORNIA EDISON COMPANY CLEANTECH SAN DIEGO 2244 WALNUT GROVE AVE. / PO BOX 800 2159 INDIA STREET ROSEMEAD, CA 91770 SAN DIEGO, CA 92101 FOR: SOUTHERN CALIFORNIA EDISON COMPANY FOR: CLEANTECH SAN DIEGO KIRSTIE C. RAAGAS ANAND DURVASULA REGULATORY COUNSEL CALIF PUBLIC UTILITIES COMMISSION SAN DIEGO GAS & ELECTRIC COMPANY LEGAL DIVISION 8330 CENTURY PARK COURT, CP31F ROOM 4107 SAN DIEGO, CA 92123 505 VAN NESS AVENUE FOR: SAN DIEGO GAS & ELECTRIC COMPANY SAN FRANCISCO, CA 94102-3214 FOR: ORA CHRISTOPHER J. WARNER MARK MILES ATTORNEY CEO MARK CONSULTING, INC. 77 BEALE STREET / PO BOX 7442 1200 LAKESHORE AVENUE, SUITE 25A SAN FRANCISCO, CA 94120 OAKLAND, CA 94606

CPUC - Service Lists - A1704028 https://ia.cpuc.ca.gov/servicelists/a1704028_84365.htm Page 2 of 5 3/15/2018 FOR: FOR: MARK MILES CONSULTING, INC. (MMCI) SHIRLEY GEE DEEPA LOUNSBURY MANAGING PARTNER CALSEED PROGRAM MGR. ANGEL PLUS, LLC CALIFORNIA CLEAN ENERGY FUND 844 PROSPECT AVENUE 436 14TH STREET, SUITE 1220 OAKLAND, CA 94610 OAKLAND, CA 94612 FOR: ANGEL PLUS, LLC FOR: CALIFORNIA CLEAN ENERGY FUND (CALCEF) ANDREW G. CAMPBELL ANDREW G. CAMPBELL EXE. DIR EXEC. DIR., ENERGY INSTITUTE AT HAAS UNIVERSITY OF CALIFORNIA, BERKELEY UNIVERSITY OF CALIFORNIA, BERKELEY ENERGY INSTITUTE AT HAAS UNIVERSITY OF CALIFORNIA, BERKELEY 324 GIANNINI HALL 324 GIANNINI HALL BERKELEY, CA 94720 BERKELEY, CA 94720 FOR: SOCIAL SCIENCE RESEARCHERS FOR: RESEARCH CENTER COALITION SHANA LAZEROW ANTHONY HARRISON ATTORNEY DIR - PUBLIC POLICY COMMUNITIES FOR A BETTER ENVIRONMENT CHARGEPOINT 120 BROADWAY, SUITE 2 254 E. HACIENDA AVENUE RICHMOND, CA 94804 CAMPBELL, CA 95008 FOR: CALIFORNIA ENVIRONMENTAL JUSTICE FOR: CHARGEPOINT, INC. ALLIANCE (CEJA) ALLAN L. WARD, II CHIEF COUNSELS OFFICE 1516 9TH STREET, MS 14 SACRAMENTO, CA 95814 FOR: CALIFORNIA ENERGY RESOURCES CONSERVATION AND DEVELOPMENT COMMISSION Information Only AARON RENFRO SOUTHERN CALIFORNA EDISON, CA 00000 BONNIE DATTA SR. DIR - AMERICAS & ASIA PACIFIC SIEMENS, CA 00000 ISAAC SEVIER JOHN MINNICUCCI NATURAL RESOURCES DEFENSE COUNCIL SOUTHERN CALIFORNIA EDISON, CA 00000, CA 00000 KENT THOMSON LARA ETTENSON SOUTHERN CALIFORNIA EDISON NATURAL RESOURCES DEFENSE COUNCIL, CA 00000, CA 00000 LESLIE ALMOND PAMELA DOUGHMAN

CPUC - Service Lists - A1704028 https://ia.cpuc.ca.gov/servicelists/a1704028_84365.htm Page 3 of 5 3/15/2018 CALIF. ENERGY COMMISSION, CA 00000, CA 00000 MRW & ASSOCIATES LLC, CA 00000 DANIEL DOUGLASS ATTORNEY DOUGLASS & LIDDELL 4766 PARK GRANADA, SUITE 209 CALABASAS, CA 91302 FOR: WESTERN POWER TRADING FORUM CASE ADMINISTRATION WALKER A. MATTHEWS, III SOUTHERN CALIFORNIA EDISON COMPANY SR. ATTORNEY 2244 WALNUT GROVE AVE. / PO BOX 800 SOUTHERN CALIFORNIA EDISON COMPANY ROSEMEAD, CA 91770 2244 WALNUT GROVE AVE. / PO BOX 800 ROSEMEAD, CA 91770 ANNLYN FAUSTINO DEAN A. KINPORTS REGULATORY & COMPLIANCE REGULATORY CASE MGR. SAN DIEGO GAS & ELECTRIC COMPANY SAN DIEGO GAS & ELECTRIC COMPANY 8330 CENTURY PARK COURT, CP32F 8330 CENTURY PARK COURT, CP32F SAN DIEGO, CA 92123 SAN DIEGO, CA 92123 EMMA D. SALUSTRO CENTRAL FILES ATTORNEY SAN DIEGO GAS & ELECTRIC COMPANY SAN DIEGO GAS & ELECTRIC COMPANY 8330 CENTURY PARK CT, CP31-E 8330 CENTURY PARK COURT, CP32D SAN DIEGO, CA 92123-1530 SAN DIEGO, CA 92123 FOR: SAN DIEGO GAS & ELECTRIC COMPANY (SDG&E) BRENT COLASURDO JULIE CERIO UMBERG ZIPSER LLP 77 BEALE ST., RM. 2388B, CA 92614 SAN FRANCISCO, CA 94104 DANIEL OHLENDORF GREG STEWART 77 BEALE STREET, ROOM 2388B 77 BEALE STREET, ROOM 2388B SAN FRANCISCO, CA 94105 SAN FRANCISCO, CA 94105 GEORGE ZAHARIUDAKIS FRANCESCA WAHL RESOURCE / ENTEGRATED PLANNING SR. ASSOCIATE, BUS. DEVELOPMENT TESLA, INC. 77 BEALE STREET, RM 2388B 444 DE HARO STREET, STE. 101 SAN FRANCISCO, CA 94105-0001 SAN FRANCISCO, CA 94107 DEBORAH BEHLES CASE ADMINISTRATION OF COUNSEL CALIFORNIA ENVIRONMENTAL JUSTICE ALLIANC, CA 94177, CA 94131 FOR: CALIFORNIA ENVIRONMENTAL JUSTICE ALLIANCE (CEJA)

CPUC - Service Lists - A1704028 https://ia.cpuc.ca.gov/servicelists/a1704028_84365.htm Page 4 of 5 3/15/2018 CHRIS KING ROGER LIN GLOBAL CHIEF REGULATORY OFFICER CENTER ON RACE POVERTY & THE ENVIRONMENT SIEMENS SMART GIRD SOLUTIONS 1999 HARRISON STREET, STE. 650 4000 E 3RD AVE., STE. 400 OAKLAND, CA 94612 FOSTER CITY, CA 94404 FOR: CALIFORNIA ENVIRONMENTAL JUSTICE ALLIANCE RENEE SAMSON GABRIEL HERRERA, ESQ. DIR - UTILITY SOLUTIONS OFFICE OF CHIEF COUNSEL CHARGEPOINT, INC. 245 HACIENDA AVENUE 1516 NINTH STREET, MS 14 CAMPBELL, CA 95008 SACRAMENTO, CA 95814-5512 LYNN HAUG ANDREW B. BROWN ATTORNEY ATTORNEY AT LAW ELLISON SCHNEIDER HARRIS & DONLAN LLP ELLISON SCHNEIDER HARRIS & DONLAN LLP 2600 CAPITOL AVE., STE. 400 2600 CAPITAL AVENUE, SUITE 400 SACRAMENTO, CA 95816 SACRAMENTO, CA 95816-5905 State Service MARIA SOTERO CHRISTOPHER MYERS REGULATORY ANALYST-ENERGY DIVISION CALIF PUBLIC UTILITIES COMMISSION CALIFORNIA PUBLIC UTILITIES COMMISSION ELECTRICITY PLANNING & POLICY BRANCH ROOM 4104, CA 00000 505 VAN NESS AVENUE SAN FRANCISCO, CA 94102-3214 JOANNA GUBMAN KARIN M. HIETA CALIF PUBLIC UTILITIES COMMISSION CALIF PUBLIC UTILITIES COMMISSION COMMISSIONER RANDOLPH ELECTRICITY PLANNING & POLICY BRANCH AREA 4-A ROOM 5010 505 VAN NESS AVENUE 505 VAN NESS AVENUE SAN FRANCISCO, CA 94102-3214 SAN FRANCISCO, CA 94102-3214 STEPHEN C. ROSCOW THOMAS GARIFFO CALIF PUBLIC UTILITIES COMMISSION CALIF PUBLIC UTILITIES COMMISSION DIVISION OF ADMINISTRATIVE LAW JUDGES ELECTRICITY PLANNING & POLICY BRANCH ROOM 5109 AREA 505 VAN NESS AVENUE 505 VAN NESS AVENUE SAN FRANCISCO, CA 94102-3214 SAN FRANCISCO, CA 94102-3214 DAVID X. HUANG SARA KIM CALIF PUBLIC UTILITIES COMMISSION STAFF ATTORNEY PROCUREMENT STRATEGY AND OVERSIGHT BRANC 300 Capitol Mall 1516 NINTH STREET, MS-14 Sacramento, CA 95814 SACRAMENTO, CA 95814 ANTHONY NG DORIS YAMAMOTO 1516 NINTH STREET, MS 51 1516 NINTH STREET, MS 51 SACRAMENTO, CA 95814-5512 SACRAMENTO, CA 95814-5512

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