BEFORE THE PUBLIC UTILITIES COMMISSION OF THE STATE OF CALIFORNIA ) ) ) ) ) ) ) ) OPENING COMMENTS OF SOUTHERN CALIFORNIA EDISON COMPANY (U-338-E)

BEFORE THE PUBLIC UTILITIES COMMISSION OF THE STATE OF CALIFORNIA Application of Southern California Edison Company (U 338-E for Approval of Its 2015-2017 Triennial Investment Plan for the Electric Program Investment Charge And Related Matters. A.14-05-005 (Filed May 1, 2014 Application 14-04-034 Application 14-05-003 Application 14-05-004 OPENING COMMENTS OF SOUTHERN CALIFORNIA EDISON COMPANY (U-338-E Pursuant to Rule 13.11 of the California Public Utilities Commission (Commission Rules of Practice and Procedure and the Administrative Law Judge s (ALJ Scoping Memo and Ruling issued on July 28, 2014, Southern California Edison Company (SCE hereby respectively submits its Opening Comments in support of approval of its 2015-2017 Electric Program Investment Charge (EPIC triennial investment plan. I. SUMMARY OF RECOMMENDATIONS SCE respectfully requests the Commission approve its 2015-2017 EPIC Investment Plan Application. 1 SCE s EPIC Investment Plan fully complies with the requirements established by Commission Decision (D. 12-05-037 and the additional requirements articulated in D.13-11- 1 A.14-05-005. 1

025. Furthermore, SCE s Investment Plan also fully complies with the statutory criteria under Public Utilities Code (PUC Sections 8360 and 740.1 for Smart Grid projects and other utility RD&D expenditures. SCE s Investment Plan has been developed transparently with extensive collaboration and input from stakeholders, and coordinated between the other EPIC Administrators (Pacific Gas &Electric Company (PG&E, San Diego Gas &Electric Company (SDG&E 2 and the California Energy Commission (CEC. During the development of its 2015-2017 EPIC Investment Plan, SCE has participated in the following stakeholder engagements: February 21, Joint Utilities webinar; March 17, Northern California Public Workshop hosted by the CEC; and March 21, Southern California Public Workshop hosted by SCE. In terms of program flexibility, SCE recommends the Commission adhere to the standard established in Ordering Paragraph 37 of D. 13-11-025, which provided that administrators may shift funds within a funding category/program area without limitation. To ensure appropriate transparency review of new projects, the Commission should require the Program Administrators to offer an informal briefing regarding the project to the Energy Division (ED, Office of Ratepayer Advocates (ORA and other interested Commission staff and require a Tier 1 advice letter. This will provide a means for stakeholders to submit protests, if any, regarding the furtherance of a new project on the grounds that it does not meet the Commission s requirements for EPIC. SCE recommends the Commission clarify that Program Administrators should use the budget table in D.12-05-037, as corrected by D.12-07-001 (Table 2, pg. 73, as the basis to calculate the EPIC Program Budget for Administrator s program and administrative expenditures and the CPUC Oversight Fee. 2 Referred to collectively as the Utilities. 2

SCE supports the CEC s recommendation to transfer funds collected by the Utilities to the CEC for program expenditures after gaining approval at a business meeting on a quarterly basis. Since the Commission ordered the inclusion of the Submetering Pilot into the EPIC Program, SCE requests the Independent Evaluator (IE audit required in the Submetering Proceeding coordinate its efforts with the EPIC Programmatic IE audit required by the Commission in 2016. II. DISCUSSION A. Compliance with D.12-05-037 and D.13-11-025 SCE s EPIC Investment Plan fully complies with the requirements established in D.12-05-037 and further articulated in D.13-11-025. Specifically, in D.12-05-037, the Commission established PG&E, SCE, SDG&E and the CEC as the EPIC Program Administrators. This decision also required the Administrators to file coordinated investment plans, map these investments to the electricity value chain and comply with PUC Sections 8360 and 740.1. In D.13-11-025, the Commission further established the requirement to not duplicate energy efficiency (EE and demand response (DR efforts by requiring the utilities to provide an appendix to the EPIC Application of current EE and DR projects. 3 Collectively, these Commission decisions specify the required elements for the Administrators respective investment plans. This proceeding s primary purpose is to determine if the EPIC Administrators investment plans include the required elements from these aforementioned Commission decisions and whether programmatic modifications are merited. The ALJ s Scoping Memo and 3 Ordering Paragraph 40, at 142. 3

Ruling reinforces this theme in Section 4, which addresses the scope of issues included in this proceeding. 1. Mapping of the Investments SCE s Investment Plan is divided into four program categories (1 renewable and distributed energy resource integration; (2 grid modernization and optimization; (3 customer-focused products and services enablement and integration; and (4 crosscutting/foundational strategies and technologies. This framework was jointly used among all of the utility Administrators and follows the same framework used by the utilities in their 2012-2014 investment plans, consistent with prior Commission decisions. The description of each program category maps its initiatives to the electricity system value chain. 4 The project descriptions explain the relevant technology and how it fits in the electricity system value chain, how the project plans to overcome current barriers, and whether the project offers primary and/or secondary benefits. Appendix B includes a list of all current EE and DR projects, and describes each potential project in further detail. B. Program Administration The ALJ s Scoping Memo and Ruling included a number of issues pertaining to program administration. The public workshop convened by the Energy Division provided a useful forum for stakeholders and the Program Administrators to further discuss these issues raised by the ALJ. During the workshop, consensus was reached on the majority of these issues. SCE provides further comments on the remaining issues that merit additional discussion. 4 See SCE s Investment Plan at 14, 23, 32, 38. 4

1. Program Flexibility To most effectively and efficiently administer the EPIC Investment Plan, it is imperative the Commission continue to afford Program Administrators portfolio flexibility. Specifically, in Ordering Paragraph 37 of D. 13-11-025, the Commission provides that the EPIC administrators may shift funds within a funding category/program area 5 without limitation. 6 As noted in the workshop, all participants, including the expert panelists, 7 agreed that new technologies and/or policies could be developed at any time and research portfolios need to be nimble and flexible enough to react to these changes to be effective. Moreover, the Commission encourages the use and leveraging of matching funds whenever possible, 8 which is entirely consistent with stakeholder 9 comments filed in the proceeding, and requires the EPIC Administrators to track and report on such funds as part of their annual reports. 10 As the Commission is aware, opportunities to leverage matching funds with other public agencies (e.g., United States Department of Defense, United States Department of Energy and Electric Power Research Institute arise extemporaneously and the timing afforded for responding to such opportunities is often limited. Unnecessarily limiting the flexibility of Administrators to manage their programs by establishing excessive filing requirements will have the unintended consequence of slowing progress and all but eliminate the ability to meet the timelines associated with securing federal match funding. SCE recognizes the need to transparently inform the Commission and stakeholders of modifications to its EPIC portfolio on a timelier basis than the Annual 5 The Commission defines the EPIC areas as Applied Research, Technology Demonstration & Deployments and Market Facilitation, per D.12-05-037, OP 3, at 99-100. 6 D. 13-11-025, Ordering Paragraph 37 at 142. 7 George Simons, Itron; Craig Horne, Enervault. 8 D. 13-11-025, Conclusion of Law 45 at 122. 9 Silicon Valley Leadership Group (SVLG and the Efficiency Council, per D.12-05-037 at 44. 10 D. 13-11-025, Attachment 5 at pages 1-2 and Attachment 6 at page 2. 5

Report filing currently provides. To ensure an appropriate and transparent review of new projects, SCE recommends the Commission require the Program Administrators to offer an informal briefing regarding the project to the Energy Division (ED, Office of Ratepayer Advocates (ORA and other interested Commission staff. Additionally, the Commission should require the Utilities to file a Tier 1 advice letter and the CEC to file a business letter advice filing. 11 The advice filing will provide a means for the Commission and stakeholders to be timely notified of the Administrators intended modifications to its EPIC portfolio. Importantly, the advice filing process will provide an opportunity for stakeholders to submit protests, if any, regarding the furtherance of a new project on the grounds that the new project does not meet the Commission s requirements for EPIC. Furthermore, the advice letter process provides a quick and simplified review of the types of utility requests that are expected neither to be controversial nor to raise important policy questions. 12 C. EPIC Program Budget To resolve any lingering confusion on how to calculate the EPIC Program Budget, SCE recommends the Commission clarify that Program Administrators should use the budget table in D.12-05-037, as corrected by D.12-07-001. 13 Using this EPIC Program budget table as the basis of the utilities collections, PG&E created a complementary budget table (shown below to show the EPIC triennial period and presented this table at the EPIC public workshop. SCE 11 The CEC is also eligible to file an advice filing, because the advice letter process does apply in certain circumstances to certain non-utilities subject to limited regulation by the Commission, per D.13-11-025, Conclusion of Law 104, at 131. 12 D.13-11-025, at 99. 13 This Commission decision clarified that the Program Administration budget for the Utilities should be corrected to $3.4 million annually. This correction is necessary to allow the Program Administration row of the table to add correctly to the total. 6

recommends the Commission adopt this aforementioned budget table 14, in order to calculate the Program Administrators project and administrative expenditures and the Commission oversight fee. D. Program Expenditure Remittances to the CEC During the Program Administrators weekly coordination calls, the CEC has recommended that the utilities remit program expenditures on the same quarterly basis, as the administrative budget allocations. SCE supports the CEC s recommendation, with the stipulation that in order for SCE to remit program expenditures, a project must first gain approval at a CEC business meeting. 15 E. Coordination of Independent Evaluator efforts between the Submetering Pilot and the EPIC Program When the Commission approved the submetering project in D.13-11-002, one of the compliance requirements includes an IE to audit the pilot. The Commission also required the submetering pilot to be funded through the utilities respective EPIC programs. The 14 This budget table will be updated to reflect the adjustment on January 1, 2015 by the amount of the change in the average consumer price index, specifically the Consumer Price Index for Urban Wage Earners and Clerical Workers (CPI-W for the third quarter, over the previous three-year period, per the Commission s requirements in D.13-11-025, Ordering Paragraph 3, at 135. SCE will also reduce the budget, less the interest collected in its EPIC balancing account. 15 A.12-11-004, at 56; A.14-05-005, at 46. 7

Commission already requires the EPIC program to have an IE evaluate the Administrators Programs in 2016. 16 Therefore, SCE recommends the Commission require the submetering IE audit to coordinate its efforts with the programmatic EPIC IE audit. III. GENERAL POLICY SCE respectively requests oral argument on its application. SCE reserves the right to withdraw this request upon reviewing the other parties opening comments. IV. CONCLUSION For the reasons explained above, the Commission should approve SCE s 2015-2017 EPIC triennial investment plan. 16 D.12-05-037, Finding of Facts 12, at 91. 8

Respectfully submitted, KRIS G. VYAS WALKER A. MATTHEWS, III /s/ Walker A. Matthews, III By: Walker A. Matthews, III Attorney for SOUTHERN CALIFORNIA EDISON COMPANY 2244 Walnut Grove Avenue Post Office Box 800 Rosemead, California 91770 Telephone: (626 302-6879 Facsimile: (626 302-6997 E-mail: walker.matthews@sce.com September 17, 2014 9

BEFORE THE PUBLIC UTILITIES COMMISSION OF THE STATE OF CALIFORNIA Application of Southern California Edison Company (U 338-E for Approval of Its 2015-2017 Triennial Investment Plan for the Electric Program Investment Charge And Related Matters. A.14-05-005 (Filed May 1, 2014 A.14-04-034 A.14-05-003 A.14-05-004 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 OPENING COMMENTS OF SOUTHERN CALIFORNIA EDISON COMPANY (U-338-E, on all parties identified on the attached service list(s A.14-04-034 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 office of the assigned Administrative Law Judge. ALJ David M. Gamson CPUC, Div of ALJ's 505 Van Ness Ave, Room 5115 San Francisco, CA 94102 Executed this September 17, 2014, at Rosemead, California. _/s/ Raquel Ippoliti Raquel Ippoliti Project Analyst SOUTHERN CALIFORNIA EDISON COMPANY 2244 Walnut Grove Avenue Post Office Box 800 Rosemead, California 91770

CPUC - Service Lists - A1404034 http://www.cpuc.ca.gov/service_lists/a1404034_81723.htm Page 1 of 3 9/17/2014 CPUC Home CALIFORNIA PUBLIC UTILITIES COMMISSION Service Lists PROCEEDING: A1404034 - CALIFORNIA ENERGY CO FILER: CALIFORNIA ENERGY COMMISSION LIST NAME: LIST LAST CHANGED: AUGUST 29, 2014 DOWNLOAD THE COMMA-DELIMITED FILE ABOUT COMMA-DELIMITED FILES Back to Service Lists Index Parties KRIS G. VYAS, ESQ. EMMA D. SALUSTRO ATTORNEY ATTORNEY SOUTHERN CALIFORNIA EDISON COMPANY SAN DIEGO GAS & ELECTRIC COMPANY 2244 WALNUT GROVE AVE. / PO BOX 800 101 ASH STREET, HQ-12B ROSEMEAD, CA 91770 SAN DIEGO, CA 92101-3017 FOR: SOUTHERN CALIFORNIA EDISON COMPANY FOR: SAN DIEGO GAS & ELECTRIC COMPANY ROBERT HAGA CHRISTOPHER J. WARNER STAFF COUNSEL PACIFIC GAS AND ELECTRIC COMPANY CPUC LAW DEPT. 505 VAN NESS AVENUE 77 BEALE STREET, MC B30A, RM 3145 SAN FRANCISCO, CA 94102 SAN FRANCISCO, CA 94105 FOR: ORA FOR: PACIFIC GAS AND ELECTRIC COMPANY COLLEEN QUINN ALLAN L. WARD, II VP - GOV'T. RELATIONS AND PUBLIC POLICY CALIFORNIA ENERGY COMMISSION CHARGEPOINT, INC CHIEF COUNSELS OFFICE 1692 DELL AVENUE 1516 9TH STREET, MS 14 CAMPBELL, CA 95008 SACRAMENTO, CA 95814 FOR: CHARGEPOINT, INC. FOR: CALIFORNIA ENERGY COMMISSION (CEC Information Only CASE ADMINISTRATION JEREMY WAEN

CPUC - Service Lists - A1404034 http://www.cpuc.ca.gov/service_lists/a1404034_81723.htm Page 2 of 3 9/17/2014 PACIFIC GAS & ELECTRIC COMPANY EMAIL ONLY EMAIL ONLY, CA 00000 REGULATORY ANALYST MARIN CLEAN ENERGY EMAIL ONLY EMAIL ONLY, CA 00000 MCE REGULATORY MRW & ASSOCIATES, LLC MARIN CLEAN ENERGY EMAIL ONLY EMAIL ONLY EMAIL ONLY, CA 00000 EMAIL ONLY, CA 00000 CASE ADMINISTRATION DONALD C. LIDDELL SOUTHERN CALIFORNIA EDISON COMPANY ATTORNEY 2244 WALNUT GROVE AVE. / PO BOX 800 DOUGLASS & LIDDELL ROSEMEAD, CA 91770 2928 2ND AVENUE SAN DIEGO, CA 92103 JOY C. YAMAGATA ROSS G. SIMMONS REGULATORY MGR. ATTORNEY AT LAW SAN DIEGO GAS & ELECTRIC COMPANY IMPERIAL IRRIGATION DISTRICT 8330 CENTURY PARK COURT, CP32D 333 EAST BARIONI BLVD., PO BOX 937 SAN DIEGO, CA 92123 IMPERIAL, CA 92243 NICHOLAS JIMENEZ PETER MILLER NATURAL RESOURCES DEFENSE COUNCIL NATURAL RESOURCES DEFENSE COUNCIL 111 SUTTER STREET, 20TH FLOOR 111 SUTTER STREET, 20TH FLOOR SAN FRANCISCO, CA 94104 SAN FRANCISCO, CA 94104 FOR: NATURAL RESOURCES DEFENSE COUNCIL (NRDC NOAH LONG AMANDA MOORE NATURAL RESOURCES DEFENSE COUNCIL PACIFIC GAS & ELECTRIC COMPANY 111 SUTTER ST., 20TH FLOOR 77 BEALE STREET, B9A SAN FRANCISCO, CA 94104-4540 SAN FRANCISCO, CA 94105 JAMES D. SQUERI CALIFORNIA ENERGY MARKETS ATTORNEY AT LAW 425 DIVISADERO ST STE 303 GOODIN MACBRIDE SQUERI DAY & LAMPREY SAN FRANCISCO, CA 94117-2242 505 SANSOME STREET, SUITE 900 SAN FRANCISCO, CA 94111 FOR: CALIFORNIA BUILDING INDUSTRY ASSOCIATION PAUL D. HERNANDEZ LYNN HAUG ENERGY & TRANSPORTATION MANAGER ATTORNEY AT LAW CENTER FOR SUSTAINABLE ENERGY ELLISON, SCHNEIDER & HARRIS, LLP 426 17TH STREET, SUITE 700 2600 CAPITOL AVENUE, SUITE 400 OAKLAND, CA 94612 SACRAMENTO, CA 95816-5905 State Service CHARI WORSTER ANALYSTS CHRISTOPHER MYERS CALIFORNIA PUBLIC UTILITIES COMMISSION

CPUC - Service Lists - A1404034 http://www.cpuc.ca.gov/service_lists/a1404034_81723.htm Page 3 of 3 9/17/2014 CALIFORNIA PUBLIC UTILITIES COMMISSION OFFICE OF RATEPAYER ADVOCATES EMAIL ONLY EMAIL ONLY EMAIL ONLY, CA 00000 EMAIL ONLY, CA 00000 JOSE ALIAGA-CARO LAURIE TEN HOPE UTILITIES ENGINEER DEPUTY DIR. CALIFORNIA PUBLIC UTILITIES COMMISSION CALIF. ENERGY COMMISSION EMAIL ONLY EMAIL ONLY EMAIL ONLY, CA 00000 EMAIL ONLY, CA 00000 MARIA SOTERO PAM DOUGHMAN REGULATORY ANALYST-ENERGY DIVISION CALIFORNIA ENERGY COMMISSION CALIFORNIA PUBLIC UTILITIES COMMISSION EMAIL ONLY EMAIL ONLY EMAIL ONLY, CA 00000 EMAIL ONLY, CA 00000 CHRISTINE J. HAMMOND CHRISTOPHER MYERS CALIF PUBLIC UTILITIES COMMISSION CALIF PUBLIC UTILITIES COMMISSION LEGAL DIVISION ELECTRICITY PLANNING & POLICY BRANCH AREA ROOM 4104 505 VAN NESS AVENUE 505 VAN NESS AVENUE SAN FRANCISCO, CA 94102-3214 SAN FRANCISCO, CA 94102-3214 DAVID M. GAMSON MARIA AMPARO WORSTER CALIF PUBLIC UTILITIES COMMISSION CALIF PUBLIC UTILITIES COMMISSION DIVISION OF ADMINISTRATIVE LAW JUDGES WATER BRANCH ROOM 5019 ROOM 4209 505 VAN NESS AVENUE 505 VAN NESS AVENUE SAN FRANCISCO, CA 94102-3214 SAN FRANCISCO, CA 94102-3214 GABRIEL HERRERA OFFICE OF CHIEF COUNSEL CALIFORNIA ENERGY COMMISSION 1516 NINTH STREET, MS 14 SACRAMENTO, CA 95814-5512 TOP OF PAGE BACK TO INDEX OF SERVICE LISTS