before the public utilities commission of the state of ... · 3. customer marketing, education and...

BEFORE THE PUBLIC UTILITIES COMMISSION OF THE

STATE OF CALIFORNIA

Application of San Diego Gas & Electric Company (U 902E) for Approval of SB 350 Transportation Electrification Proposals.

Application 17-01-020 (Filed January 20, 2017)

And Consolidated Matters.

Application 17-01-021 Application 17-01-022

REPLY BRIEF OF SOUTHERN CALIFORNIA EDISON COMPANY (U 338-E) ON THE STANDARD REVIEW TRANSPORTATION ELECTRIFICATION PROPOSALS FROM

SAN DIEGO GAS & ELECTRIC COMPANY, SOUTHERN CALIFORNIA EDISON COMPANY, AND PACIFIC GAS AND ELECTRIC COMPANY

FADIA RAFEEDIE KHOURY ANDREA L. TOZER

Attorneys for SOUTHERN CALIFORNIA EDISON COMPANY

2244 Walnut Grove Avenue Post Office Box 800 Rosemead, California 91770 Telephone:(626) 302-6713 Facsimile: (626) 302-6693 E-mail: [email protected]

Dated: December 21, 2017

REPLY BRIEF OF SOUTHERN CALIFORNIA EDISON COMPANY (U 338-E) ON THE STANDARD REVIEW TRANSPORTATION

ELECTRIFICATION PROPOSALS Table Of Contents

Section Page

i

I. PG&E SMART CHARGE DCFC MAKE READY PROGRAM ...................................................2

II. SCE AND PG&E MEDIUM- AND HEAVY-DUTY VEHICLE CHARGING PROGRAMS....................................................................................................................................3

A. Introduction and SB 350 Transportation Electrification Policy, Goals and Benefits ................................................................................................................................3

1. PG&E .......................................................................................................................3

2. SCE ..........................................................................................................................3

a) SCE’s Proposed Program Will Accelerate Widespread TE, Reduce Dependence on Petroleum, Improve Air Quality, and Reduce GHG Emissions, Consistent with SB 350’s Mandates ......................................................................................................3

B. Scope of Projects ..................................................................................................................4

1. Reducing the Scope or Phasing SCE’s Proposed Program Would Not Satisfy the Goals of SB 350 ..............................................................................4

2. The Commission Should Reject CEFC’s Arguments ..............................................6

3. SoCalGas’s Request to Exclude Heavy-Duty Vehicles is Contrary to Statute and Regulatory Guidance ........................................................................7

C. Implementation of Projects ..................................................................................................9

1. Program Design .......................................................................................................9

a) PG&E ...........................................................................................................9

b) SCE ..............................................................................................................9

2. Disadvantaged Communities .................................................................................11

a) PG&E .........................................................................................................11

b) SCE ............................................................................................................11

3. Customer Marketing, Education and Outreach ......................................................13



Section Page

ii

a) PG&E .........................................................................................................13

b) SCE ............................................................................................................13

4. Data Collection, Reporting, Performance Metrics, Collaboration and Advisory Council ............................................................................................14

a) PG&E .........................................................................................................14

b) SCE ............................................................................................................14

5. Other Project-Specific Details ...............................................................................15

a) PG&E .........................................................................................................15

b) SCE ............................................................................................................15

D. Budgets, Cost Recovery and Ratemaking ..........................................................................15

1. PG&E .....................................................................................................................15

2. SCE ........................................................................................................................16

a) SCE’s Proposed Contingency is Reasonable .............................................16

b) SCE’s Proposal to Capitalize the Rebates is Appropriate Accounting and Equitable Ratemaking .....................................................17

c) After-the-Fact Reasonableness Review is Not Required ...........................20

d) SCE’s Proposal Appropriately Allocates Costs to Distribution Rates ......................................................................................20

E. Rate Design ........................................................................................................................21

1. PG&E .....................................................................................................................21

2. SCE ........................................................................................................................22

F. Competition Issues .............................................................................................................24

1. PG&E .....................................................................................................................24



Section Page

iii

2. SCE ........................................................................................................................24

G. Other Issues ........................................................................................................................26

1. PG&E .....................................................................................................................26

2. SCE ........................................................................................................................26

a) Tesla’s Request to Use Existing Meters for the Proposed Program is Infeasible and Inconsistent with the Stipulation Between SCE and the Joint Parties ............................................................26

b) ChargePoint’s Requested Workshop is Unnecessary and Will Delay Implementation........................................................................26

c) SCE Complies with Affiliate Transaction Rules .......................................27

H. Conclusion .........................................................................................................................27

1. PG&E .....................................................................................................................27

2. SCE ........................................................................................................................27

III. SDG&E RESIDENTIAL CHARGING PROGRAM ....................................................................27


ELECTRIFICATION PROPOSALS Table Of Authorities

Section Page

iv

StatutesCal. Health & Safety Code § 38566................................................................................................ 3 Cal. Pub. Util. Code § 740.12(a)(1)(A) ...................................................................................... 3, 8 Cal. Pub. Util. Code § 740.12(a)(1)(B) ....................................................................................... 3, 8 Cal. Pub. Util. Code § 740.12(a)(1)(C) ........................................................................................... 3 Cal. Pub. Util. Code § 740.12(a)(1)(E) ................................................................................. 2, 8, 24 Cal. Pub. Util. Code § 740.12(a)(2) ...................................................................................... 2, 3, 24 Cal. Pub. Util. Code § 740.12(b) .................................................................................................. 24

LegislationCal. Senate Bill (SB) 350 ....................................................................................................... passim

CPUC DecisionsD.01-03-073 .................................................................................................................................. 20 D.14-03-021 .................................................................................................................................. 19 D-16-01-023 .............................................................................................................................. 5, 11 D.16-12-065 .................................................................................................................................. 18

CPUC Rules of Practice and ProcedureRule 13.11 ....................................................................................................................................... 1

1


STATE OF CALIFORNIA



And Consolidated Matters.


REPLY BRIEF OF SOUTHERN CALIFORNIA EDISON COMPANY (U 338-E) ON THE STANDARD REVIEW TRANSPORTATION ELECTRIFICATION PROPOSALS FROM

SAN DIEGO GAS & ELECTRIC COMPANY, SOUTHERN CALIFORNIA EDISON COMPANY, AND PACIFIC GAS AND ELECTRIC COMPANY

In accordance with Rule 13.11 of the California Public Utilities Commission’s

(“Commission’s”) Rules of Practice and Procedure, and the October 12, 2017 email ruling of

Administrative Law Judge Cooke, Southern California Edison Company (“SCE”) submits this

reply to parties’ opening briefs on the standard-review proposals filed by San Diego Gas &

Electric Company (“SDG&E”), SCE, and Pacific Gas and Electric Company (“PG&E”) in

Application (“A.”) 17-01-020 et al.1

1 Opening briefs were filed by Pacific Gas and Electric Company (“PG&E”); San Diego Gas & Electric

Company (“SDG&E”); CALSTART; ChargePoint, Inc. (“ChargePoint”); Clean Energy Fuels Corp. (“CEFC”); California Transit Association (“CTA”); Environmental Defense Fund (“EDF”); East Yard Communities for Environmental Justice, Center for Community Action and Environmental Justice, and Union of Concerned Scientists (collectively, “EYCEJ”); Green Power Institute and Community Environmental Council (“GPI/CEC”); Greenlining Institute (“Greenlining”); National Diversity Coalition (“NDC”); Natural Resources Defense Council, the Greenlining Institute, Plug In America, Coalition of California Utility Employees, Sierra Club, Environmental Defense Fund, Union of Concerned Scientists, Greenlots, Siemens, and E-Motorworks (collectively, “NRDC et al.”); Office of Ratepayer Advocates (“ORA”); Small Business Utility Advocates (“SBUA”); Santa Clara Valley Transportation Authority (“SCVTA”); San Diego Airport Parking Company; Southern California Gas Company (“SoCalGas”); Tesla, Inc. (“Tesla”); The Utility Reform Network (“TURN”); Small Business Utility Advocates (“SBUA”); Utility Consumers’ Action Network (“UCAN”).

2

The California Legislature set a policy “to encourage transportation electrification as a

means to achieve ambient air quality standards and the state’s climate goals.”2 The Legislature

recognizes the fundamental role that utilities must play to increase access to the use of electricity

as a transportation fuel, which is necessary to achieve the state’s desired widespread

transportation electrification (“TE”).3 SCE’s proposed infrastructure program for medium- and

heavy-duty electric vehicle (“EV”) charging and innovative rate design for EV charging will

facilitate and accelerate transportation electrification, consistent with state goals.

SCE’s opening brief demonstrated that its infrastructure and rate design programs satisfy

the applicable statutory requirements and regulatory guidance. Many parties filed opening briefs

supporting SCE’s proposed standard-review programs.4 In this reply brief, SCE responds to the

critiques raised by certain parties’ opening briefs. As this reply demonstrates, no party provides

sufficient evidence to demonstrate that SCE’s proposals fail to meet the applicable statutory

requirements or regulatory guidance. Therefore, the Commission should promptly approve

SCE’s proposed standard-review programs, as modified by the stipulations on record in this

proceeding, without further modification.

I.

PG&E SMART CHARGE DCFC MAKE READY PROGRAM

This reply brief addresses only SCE’s proposed standard-review projects. SCE has no

comments on PG&E’s proposed program.

2. Public Utilities (“P.U.”) Code § 740.12(a)(2). 3. P.U. Code § 740.12(a)(1)(E). 4 See, e.g., CALSTART Brief, ChargePoint Brief, CTA Brief, EYCEJ Brief, GPI/CEC Brief,

Greenlining Brief, NRDC et al. Brief, Tesla Brief.

3

II.

SCE AND PG&E MEDIUM- AND HEAVY-DUTY VEHICLE CHARGING PROGRAMS

A. Introduction and SB 350 Transportation Electrification Policy, Goals and Benefits

1. PG&E

This reply brief addresses only SCE’s proposed standard-review projects. SCE

has no comments on PG&E’s proposed program.

2. SCE

a) SCE’s Proposed Program Will Accelerate Widespread TE, Reduce

Dependence on Petroleum, Improve Air Quality, and Reduce GHG

Emissions, Consistent with SB 350’s Mandates

California has determined that widespread transportation electrification is

essential to achieving the state’s ambitious goals to reduce petroleum use, meet air quality

standards, improve public health, and reduce greenhouse gas (“GHG”) emissions.5 SCE shares

California’s goals and its sense of urgency. With the state’s first climate milestone (reducing

GHG emissions to 40 percent below 1990 levels by 2030)6 only 12 years away, and two air

basins served by SCE in severe non-attainment status for ozone,7 it is essential to facilitate

widespread TE immediately. No party’s opening briefs disputed the importance of these

problems or urgency of addressing them.

SCE’s Medium- and Heavy-Duty Vehicle Charging Infrastructure

Program (“Proposed Program”) and New EV Rate Design, as described in SCE’s testimony and

modified by the stipulations entered into the record of this proceeding, satisfy all statutory

requirements and regulatory guidance, and should be approved without further modification.

Reducing the scope, size, or scale of the Proposed Program or phasing its implementation will

send a negative signal to the nascent market and jeopardize SCE’s ability to support California’s 5 P.U. Code § 740.12(a)(1)(A), (B), (D), and § 740.12(a)(2). 6 Health & Safety Code § 38566. 7 Exhibit SCE-01, pp. 11-14.

4

goals and provide much-needed benefits to customers suffering from the health and

environmental impacts of fossil-fueled transportation, particularly in disadvantaged

communities.

B. Scope of Projects

Many parties support the scope and scale of SCE’s Proposed Program.8 CALSTART

emphasized that not only the full size, but also the full five-year duration of the Program is

essential because any shortening of the Program commitments would undermine the stability

needed to encourage fleets to invest in electrification.9 EYCEJ agreed that the scope of the

Proposed Program is reasonable and necessary to provide important air quality benefits.10 As

demonstrated in its opening brief, the scope of SCE’s Proposed Program is reasonable, consistent

with the ACR, the minimum necessary to provide a clear and certain market signal, appropriately

scaled to address GHG emissions, and consistent with the near-term investment necessary to

support California’s goals.11

1. Reducing the Scope or Phasing SCE’s Proposed Program Would Not Satisfy

the Goals of SB 350

TURN, ORA, and CEFC recommend that the Commission reject SCE’s Proposed

Program and instead propose significantly scaled-down pilots. ORA proposes a $55.4 million,

one-year Phase 1.12 TURN proposes an $81 million, four-year Phase 1 with specific minimum

site requirements and budgets for particular sectors.13 CEFC proposes a $20 million pilot.14

8 See, e.g., CALSTART Brief, p. 6; ChargePoint Brief, p. 18; CTA Brief, p. 6; EYCEJ, p. 5; NRDC et

al. Brief, pp. 27-28, 33-34; Tesla Brief, p. 4. 9 CALSTART Brief, p. 6. 10 EYCEJ Brief, p. 9. 11 SCE Brief, pp. 13-14. 12 ORA Brief, p. 43. 13 TURN Brief, p. 28. 14 CEFC Brief, p. 35.

5

These proposals, however, are not consistent with SB 350’s goals to accelerate widespread TE.

ORA’s witness Gariffo admitted that ORA’s proposed pilot would not itself support the SB 350

goal of accelerating transportation electrification.15

Phasing can create a gap, as seen in SCE’s Charge Ready program.16 ORA’s

witness Gariffo admitted so.17 This problem is exacerbated in the medium- and heavy-duty

market, where vehicle acquisition and operational changes require long lead times.18 A shorter

program, or a program with a significantly reduced budget, will not provide customers with the

certainty they need to invest in electrification.19 This could also jeopardize customers’ ability to

leverage incentive programs for vehicle acquisition.20 Mr. Gariffo admitted “[t]hat a time gap

could result in changing the EV purchasing decision of a potential participant” considering fleet

electrification21 and acknowledged that the lack of availability of an infrastructure program could

affect customers’ purchasing decisions for electric vehicles.22 As SCE’s witness Renger

explained, even with a potential for bridge funding, any gap between phases would not provide

the necessary certainty to customers looking to electrify.23

15 ORA, Gariffo, Tr. 10/1373-1374. 16 Pursuant to D-16-01-023, Ordering Paragraph (OP) 9, SCE cannot submit an application for the

second phase of the Charge Ready program before reaching certain milestones and filing a pilot report. Charge Ready pilot enrollment closed in January 2107. SCE plans to file the pilot report and an application for Phase 2 in 2018. Considering the regulatory review that will follow, a significant gap will likely occur until the Commission authorizes SCE to enroll new customers in Phase 2 of the program.

17 ORA, Gariffo, Tr. 10/1353-1354. 18 Exhibit SCE-02, pp. 3-4. 19 Id. 20 Id., p. 4. 21 ORA, Gariffo, Tr. 10/1357. 22 ORA, Gariffo, Tr. 10/1359. 23 SCE, Renger, Tr. 4/464.

6

TURN’s proposal to impose sectoral budget caps, site criteria, and program

design features24 will further limit the ability of SCE’s Proposed Program to meet the goals of

SB 350. As SCE explained in its rebuttal testimony, TURN’s proposal will lead to customer

confusion and compromise SCE’s market-neutral approach of providing electrical infrastructure

to support widespread TE acceleration in the entire medium- and heavy-duty market.25 Instead,

TURN’s approach would select and favor particular TE technologies and segments, regardless of

the demand that may materialize in each segment over the duration of the Program.26 It would

also limit customer participation and choice, by arbitrarily preventing customers from

participating in a segment that happens to be fully subscribed, even if Program funding is still

available.27 Furthermore, TURN’s one-size-fits-all approach fails to consider differences

between SCE’s and PG&E’s service territories. SCE serves a greater percentage of goods-

movement-related industrial customers, including the Port of Long Beach, warehouses,

distribution centers, and intermodal facilities along highways in the Los Angeles Basin,

Riverside County, and San Bernardino County.28 The fact that SCE serves the only two air

basins in the country that are in extreme non-attainment for ozone further supports an increased

and immediate need for electrification in SCE’s service territory.29

2. The Commission Should Reject CEFC’s Arguments

The Commission should reject CEFC’s arguments, as CEFC relies on testimony

that was prepared by a witness, Mr. Couch, who admitted that he had not even reviewed SCE’s

proposals in this proceeding.30 CEFC’s other witness, Mr. Jensen, admitted that he was trained

24 TURN Brief, p. 43. 25 Exhibit SCE-02, p. 8. 26 Id. 27 Id. 28 Exhibit SCE-02, p. 9. 29 Id. 30 CEFC, Couch, Tr. 10/1293.

7

and practicing as an attorney, and has no experience owning or operating electric vehicle fleets.31

Further, Mr. Jensen agreed that the amount of electrification that SCE proposes to support in the

next five years is not a large portion of the heavy-duty market.32 Mr. Couch cautions against

“overreliance” on a particular technology, but when asked whether the amount of heavy-duty

vehicles that SCE expects to electrify as part of the Proposed Program would represent

“overreliance,” he admits, “I don’t believe that the deployment of 572 electric vehicles is

meaningful in the broader transportation market.”33 Mr. Couch further clarifies that “572 heavy-

duty vehicles is a very small fraction of the heavy-duty market in California. I don’t believe that

572 vehicles is going to fundamentally make or break the transportation market.”34 Mr. Couch

also states that “the context of overreliance has to be taken with respect to the goals of the

specific program. If the specific program relies entirely on any one technology, that to me raises

concerns of overreliance.”35 But Mr. Couch admits that SCE’s program was designed to support

the goals of SB 350.36 As discussed above and admitted by Mr. Jensen,37 SB 350 mandates

widespread transportation electrification, so the Commission should reject CEFC’s cautions

about “overreliance” on transportation electrification.

3. SoCalGas’s Request to Exclude Heavy-Duty Vehicles is Contrary to Statute

and Regulatory Guidance

SoCalGas recommends that the Commission exclude heavy-duty vehicles to the

extent that they displace heavy-duty “near zero” natural gas vehicles that are currently providing

31 CEFC, Jensen, Tr. 9/1175-1176, 1200. 32 CEFC, Jensen, Tr. 9/1212. 33 CEFC, Couch, Tr. 10/1293-1294. 34 CEFC, Couch, Tr. 10/1294. 35 Id. 36 CEFC, Couch, Tr. 10/1297-1298. 37 CEFC, Jensen, Tr. 9/1202, stating that “the legislature has spoken in SB 350. The legislature wants

the Public Utilities Commission to accelerate TE, make more TE available.”

8

equal or superior benefits when compared to electric alternatives.38 The Legislature and

Commission have clearly addressed the need for utility investments in all sectors to facilitate

widespread transportation electrification. SB 350 states that “[w]idespread transportation

electrification is needed” and “requires electrical corporations to increase access to the use of

electricity as a transportation fuel.”39 Additionally, the ACR states that there is value in TE

proposals in all market segments.40 The Legislature and Commission could have, but did not,

order the utilities to submit applications for proposals only in market segments where no

alternative fuels currently exist. Instead, the ACR explicitly identifies transit buses as an

example of possible “projects and investments that provide the biggest impact for the amount of

money spent,”41 even though natural gas transit buses exist in today’s market.42 Furthermore, as

discussed above, SCE’s Proposed Program will serve only a small fraction of the heavy-duty

market, so SoCalGas’s claims about stranding natural gas assets are unfounded.

SoCalGas’s arguments comparing electric and natural gas fuels are irrelevant and

outside the scope of this proceeding. SoCalGas claims that electric vehicles are inferior to

natural gas-fueled heavy duty vehicles. However, SoCalGas has not presented any record

evidence to support this claim. The Ramboll Environ “LA Metro” study referenced in

SoCalGas’s testimony shows that electric buses in fact have lower emissions than CNG buses.43

Additionally, in written data request responses, SoCalGas failed to support its GHG reduction

claims because it could not determine where biomethane injected onto its system was sourced.44

The Commission should reject SoCalGas’s unsupported argument that using electric vehicles

38 SoCalGas Brief, p. 5. 39 P.U. Code § 740.12(a)(1)(B) and (E). 40 ACR, p. 21. 41 Id. 42 Exhibit SCE-02, p. 14. 43 SCG-1, Appendix B. 44 Exhibit SCE-02, pp. A-5, A-6, A-7, A-9.

9

harms customers by displacing “superior” technologies because it is out of scope and contrary to

SoCalGas’s own testimony.

C. Implementation of Projects

1. Program Design

a) PG&E

SCE has no comments on PG&E’s proposed program.

b) SCE

ORA argues that SCE does not adequately account for changing medium-

and heavy-duty charging technologies.45 In fact, SCE’s proposal to provide make-ready

infrastructure is ideally designed to accommodate changes in charging technology. The

infrastructure deployed as part of SCE’s Proposed Program should accommodate a customer that

decides to adopt a different type of charging equipment at some point in the future, or a new

customer that moves onto a site and installs a different type of charging equipment.46 Customers

will also be able to select the type of equipment that works best for their charging needs,

minimizing the risk that the equipment will not be used.47 Rather than selecting a “one-size-fits-

all” approach, SCE’s Proposed Program is flexible and will accommodate changing technologies

over the course of the Program.48 ORA acknowledges that the “make-ready stubs … could serve

a large selection of different EVSEs now and for years to come.”49 ORA’s concern appears to be

that there is a risk of a particular charging station breaking or becoming technologically

obsolete.50 As ORA and CEFC state, however, the make-ready infrastructure could support a

45 ORA Brief, p. 27. 46 See Exhibit SCE-01, p. 99; SCE, Renger, Tr. 4/419-420. 47 Id., p. 97. 48 Id., p. 99. 49 ORA Brief, p. 27. 50 Id.

10

variety of different replacement charging stations in that event.51

ORA also criticizes SCE’s Proposed Program for not providing evidence

that it “will lead to more than one MD/HD EV per site or that eligible sites will be cost-effective

and/or produce the greatest environmental benefits.”52 But SCE is not required to demonstrate

the number of vehicles that will be adopted per site or the cost-effectiveness of eligible sites or

that individual sites will produced the greatest benefits. SCE’s Program complies with the

requirements in SB 350 and the regulatory guidance set forth in the ACR, and SCE demonstrated

how the Proposed Program will support California’s goals and provide health, environmental,

and ratepayer benefits.53

CEFC also argues that SCE has not quantified the expected GHG

emissions from the Proposed Program.54 CEFC is incorrect. SCE analyzed GHG reductions

from EVs in Appendix D of its testimony.55 CEFC also states that to the extent SCE identified

other benefits, they are not quantified.56 But CEFC does not cite any requirement to quantify any

of these benefits. As discussed above, SCE’s Proposed Program complies with SB 350 and the

ACR, and SCE demonstrated many health, environmental, and ratepayer benefits that will accrue

from the Program.57

ChargePoint generally supports SCE’s program design, but requests

additional details on SCE’s charging equipment qualification process in a compliance filing and

opposes SCE’s proposed base cost methodology.58 As stated in SCE’s testimony, SCE intends to

51 Id. 52 ORA Brief, p. 30. 53 SCE Opening Brief, pp. 7-13. 54 CEFC Brief, p. 9. 55 Exhibit SCE-01, Appendix D, pp. D-7 to D-9. 56 CEFC Brief, p. 9. 57 SCE Opening Brief, pp. 7-13. 58 ChargePoint Brief, p. 19.

11

follow a transparent approach similar to its Charge Ready Pilot Program to qualify vendors and

charging equipment.59 For Charge Ready, SCE worked closely with the program’s advisory

board (of which ChargePoint was a member and active participant) and the Energy Division,

reviewing its technical requirements60 and keeping the board informed of any changes in the

qualification process. SCE also provided frequent updates on qualified equipment. SCE agrees

with ChargePoint that “[t]he range of MDHD vehicles and charging technologies is broad and

diverse, and will be expanding and changing during the period covered by SCE’s proposed

program.”61 This is precisely why a compliance filing is inappropriate to administer the

qualification process and why SCE should, instead, work with and report to the Program

Advisory Council and the Energy Division about its technical requirements and qualification

process. In addition, ChargePoint’s proposal to modify the proposed base cost methodology will

cause an increase in rebate amounts distributed by the program without any demonstrated

increased benefits, as the proposal requires using the average cost of charging equipment by

technology to determine the base cost, instead of the best value criterion. Finally, ChargePoint’s

proposal will not reduce operational complexities because SCE would still have to gather data

and evaluate a broad range of charging equipment, similar to SCE’s proposed methodology.

2. Disadvantaged Communities

a) PG&E


b) SCE

As demonstrated in its opening brief, SCE’s Proposed Program will

provide significant benefits to disadvantaged communities.62 EYCEJ’s brief further details the

59 Exhibit SCE-01, p. 97. 60 As directed by D-16-01-023, p. 45. 61 ChargePoint Brief, p. 21. 62 SCE Opening Brief, pp. 15-17.

12

benefits that will accrue to disadvantaged communities from SCE’s Proposed Program.63 Most

parties support SCE’s commitment to disadvantaged communities,64 and no party recommends

that SCE commit more than a minimum of 40 percent of its Program funds to installations in

disadvantaged communities. SCE will reserve 40 percent of its Program funds for deployment in

disadvantaged communities and transit agencies, which disproportionately benefit lower-income

individuals.65 SCE’s commitment exceeds the minimum requested by some parties, including

ORA, which only requested that SCE commit 10 percent of program funds to disadvantaged

communities.66 The agreement reached between SCE and the Joint Parties, including

Greenlining, allows SCE to release any unused funds remaining in the reserve at the halfway

point of the Program so that sites interested in participating are not excluded in the unlikely event

that there is insufficient demand in disadvantaged communities.67

SCE’s proposal is a reasonable approach to serving disadvantaged

communities while not excluding sites that are willing and able to participate and provide

benefits to all customers, including those in disadvantaged communities. TURN and ORA

acknowledge that installations do not necessarily have to be located in disadvantaged

communities to provide benefits to those communities.68 Despite this, TURN argues that SCE’s

proposal to release funds at the halfway point is insufficient, relying on a statement by SCE’s

witness Renger.69 TURN fails to note, however, that Ms. Renger corrected this statement on

redirect. Ms. Renger clarified that releasing the funds at the Program’s halfway point would not

63 EYCEJ Brief, pp. 11-14. 64 See, e.g., EDF Brief, p. 6; EYCEJ Brief, p. 14; Greelining Brief, pp. 17-18; NRDC et al. Brief, pp.

29-30. 65 Exhibit Joint-11. 66 ORA Brief, p. 30. 67 Exhibit Joint-11. 68 TURN Brief, p. 56; see also ORA, Gariffo, Tr. 10/1378-1380. 69 TURN Brief, p. 57.

13

prevent sites in disadvantaged communities from being served if the Program is approved as

proposed, serving 100 percent of the anticipated market demand.70 The concern that TURN

raises would only materialize if the Commission adopts recommendations by TURN and a few

other parties to reduce the size and scope of SCE’s Proposed Program.

ORA recommends that SCE not be allowed to release any funds until year

four of the five-year Program to ensure that funds are not prematurely released when customers

in disadvantaged communities could still participate.71 ChargePoint also recommends that SCE

adjust its programs rather than releasing funds if the reserved budget is not being used.72 For the

reasons discussed above, SCE recommends that the Commission reject these proposals, which

could prevent SCE from serving sites that are ready to electrify and begin providing benefits to

disadvantaged communities and all other customers. SCE has committed to prioritizing

disadvantaged communities, and will work with its advisory board and community-based

organizations to maximize participation by customers located in disadvantaged communities.73

3. Customer Marketing, Education and Outreach

a) PG&E


b) SCE

GPI and SBUA recommend specific marketing, education, and outreach

(“ME&O”) budgets and targets.74 SCE’s rebuttal testimony responded to GPI’s recommendation

that SCE commit 10 percent, or approximately $55 million, of its budget to ME&O.75 GPI’s

70 SCE, Renger, Tr. 4/471-472. 71 ORA Brief, p. 31. 72 ChargePoint Brief, p. 24. 73 See Exhibit Joint-11, p. 3; Exhibit SCE-01, pp. 58-59. 74 GPI Brief, p. 18; SBUA Brief, p. 13. 75 Exhibit SCE-02, pp. 10-11.

14

brief now calls for SCE to commit at least four percent of its budget to ME&O.76 SBUA

recommends that SCE commit at least 15 percent of its ME&O budget to small businesses.77

Neither GPI nor SBUA provide any record evidence to support their arguments that SCE’s

proposed ME&O is insufficient or to justify their proposed levels and allocations. SCE’s

rebuttal testimony demonstrated that it already implemented TE Advisory Services and a broad

market education campaign in progress (funded through SCE’s Charge Ready proceeding),

which it is not currently allowed to scale up or expand.78 SCE also demonstrated that its $1

million forecast is an appropriate budget for ME&O targeted to participation in the Proposed

Program.79

4. Data Collection, Reporting, Performance Metrics, Collaboration and

Advisory Council

a) PG&E


b) SCE

TURN recommends substantial, detailed data collection that should be

done as part of a Phase 1 program.80 SCE’s rebuttal testimony addressed these proposals in more

detail.81 TURN correctly notes that SCE is not opposed to gathering some of the data

recommended by TURN during the course of the Program.82 SCE’s primary concern, however,

is that reducing the scope and phasing its Proposed Program to allow completion of this data

collection prior to implementing a full Phase 2 program would significantly delay the full

76 GPI Brief, p. 18. 77 SBUA Brief, p. 13. 78 Exhibit SCE-02, p. 10. 79 Id., pp. 10-11. 80 TURN Brief, pp. 58-61. 81 Exhibit SCE-02, pp. 11-13. 82 TURN Brief, pp. 63-64.

15

implementation and send a negative signal to the market, as discussed above. For these reasons,

SCE opposes requiring the collection and analysis of data as a prerequisite for implementation of

the full program.

TURN also argues that the Commission should impose a minimum dollar-

per-GHG-emissions-avoided metric to serve as a performance accountability measure for SCE’s

Proposed Program.83 TURN proposes that the Energy Division determine the metric using data

from one to two years of Phase 1 data and that SCE refund all or a portion of the return on equity

it earns if it fails to achieve this metric.84 TURN’s proposal, however, would lead to significant

operational complexity. Also, as stated by PG&E, focusing exclusively on this metric could

limit the utility’s ability to work with sites that would provide significant air quality, rather than

GHG, benefits and limit the utility’s ability to work with sites on long-term electrification

planning.85 Further, imposing strict performance accountability measures could discourage

utilities from investing in transportation electrification, thereby thwarting a key goal of SB 350,

accelerating widespread transportation electrification.

5. Other Project-Specific Details

a) PG&E


b) SCE

SCE has not identified any additional project-specific details that are not

addressed elsewhere in this reply brief.

D. Budgets, Cost Recovery and Ratemaking

1. PG&E


83 TURN Brief, p. 65. 84 Id. 85 Exhibit PGE-2, p. 1-18.

16

2. SCE

SCE’s budget, cost recovery, and ratemaking is reasonable, consistent with

statutory requirements and regulatory guidance, and should be approved.

a) SCE’s Proposed Contingency is Reasonable

ORA argues that SCE’s contingency for the Proposed Program should be

reduced from 35 percent to 10 percent.86 ORA provides no record support for why the arbitrarily

selected 10 percent would be an appropriate contingency level, but simply states that it is

consistent with Commission precedent of 10 to 15 percent contingencies.87 ORA, however,

provides no citations to these Commission precedents, so SCE is unable to determine whether

these contingency levels were approved for projects of similar sizes and in similar stages of

design and implementation to SCE’s Proposed Program. Further, a 10 percent contingency

would be well below the range recommended for projects in this stage of design, according to the

Association for Advancement of Cost Engineering (“AACE”). SCE’s witness Renger testified

that SCE’s proposed 35 percent contingency is in the middle of the AACE-recommended range

of 20 to 50 percent for projects in Class 4.88 ORA’s proposed 10 percent contingency, however,

would be significantly below the lowest end of the range.

TURN also recommends reducing SCE’s proposed contingency, but does

not recommend a more appropriate contingency level.89 TURN emphasizes that costs could be

35 percent lower than estimated, instead of 35 percent higher than estimated,90 but SCE’s

proposed one-way balancing account will correct for any potential cost underruns, should they

occur. For example, if SCE’s costs are less than forecast, those costs would be returned to

customers when the balancing account is trued up annually. On the other hand, if SCE’s costs

86 ORA Brief, p. 49. 87 Id. 88 SCE, Renger, Tr. 3/379. 89 TURN Brief, pp. 68-69. 90 TURN Brief, p. 68.

17

are higher than forecast, the capped balancing account would not allow SCE to collect funds

beyond what the Commission authorizes.

SCE provided evidence demonstrating that its proposed contingency is

appropriate for the stage of planning for the Proposed Program. SCE has appropriately forecast

costs for each element, but does not yet know which sites will apply and be selected to

participate in the Proposed Program. Therefore, SCE’s proposed 35 percent contingency is

reasonable and consistent with AACE and Electric Power Research Institute (“EPRI”)

contingency standards.91

For these reasons, the proposed contingency is a reasonable method for

forecasting costs at this stage of project planning. The Commission should reject the

unsupported arguments by ORA and TURN to reduce SCE’s proposed 35 percent contingency.

b) SCE’s Proposal to Capitalize the Rebates is Appropriate Accounting and

Equitable Ratemaking

TURN, ORA, and GPI argue that the rebates proposed as part of the

Proposed Program should be treated as expenses rather than capitalized as regulatory assets.92

These parties do not present compelling evidence to counter SCE’s proposal. Expensing the

rebates would cause customers today to be burdened by the full cost of rebates necessary for

developing a market whose benefits will accrue to future customers. SCE’s proposal to

capitalize the rebates, on the other hand, would allocate the costs of the charging stations over

their ten-year useful lives, ensuring that customers receiving the benefits of those assets bear an

appropriate portion of their costs. SCE’s proposed approach equitably allocates these costs to

customers who will be receiving their benefits, and is consistent with longstanding principles of

cost recovery for assets that provide benefits for many years. It would not be just or reasonable

91 Exhibit SCE-02, p. 7. 92 TURN Brief, p. 79; ORA Brief, p. 47; GPI Brief, p. 15.

18

for customers in year one to pay the full costs of the rebates, while customers in years two

through ten will receive the benefits of that investment at no cost.

TURN argues that SCE’s proposal is “especially concerning because SCE

proposes to only require participants to maintain and use the charging stations for 5 years but

will capitalize and recover the costs of the rebates over a 10 year period.”93 As SCE explained,

the Program’s participation requirement is separate from its proposal to depreciate the charging

station rebates over the full ten-year useful life of the regulatory asset. However, if the

Commission shares TURN’s concern about the risk of an asset being removed in years six

through ten before the cost of the rebates are fully recovered, the appropriate solution would be

to accelerate the recovery over the five-year period that customers are required to maintain and

use the assets. This would ensure that the costs of the rebates are at least equitably allocated

among the customers receiving the benefits of the regulatory assets during the required

participation period. Although SCE’s proposal to recover the costs of the rebates over the ten-

year useful life of the charging stations is consistent with depreciation accounting, this

alternative is more equitable than forcing customers to pay the full costs in year one of an asset’s

ten-year useful life.

TURN acknowledges that that the accounting treatment approved for

SCE’s Charge Ready pilot was the result of a settlement and non-precedential.94 TURN instead

argues that the Commission should apply D.16-12-065 regarding PG&E’s EV infrastructure pilot

to SCE’s proposal in this case.95 TURN fails to note, however, that this decision also did not

analyze the merits of the proposal to capitalize rebates for charging stations as a regulatory asset.

In fact, the decision clarified that the parties in that proceeding did not contemplate an EVSE

rebate and did not provide specific suggestions on how the rebates should be treated for

93 TURN Brief, p. 79. 94 TURN Brief, p. 79. 95 TURN Brief, pp. 79-80.

19

ratemaking purposes. Without input from parties, the Commission deferred to SCE’s Charge

Ready settlement as a basis for how to recover the costs of the rebates.96 SCE’s proposal in this

proceeding is distinguishable, because the issue was litigated and SCE provided sufficient

evidence for the Commission to decide on the merits that capitalizing the costs of the rebates as a

regulatory asset is reasonable ratemaking consistent with cost recovery principles.97

A more appropriate precedent, as SCE has argued, is the mobile home

park decision, which determined that it was appropriate for utility costs for work done beyond

the meter to be recovered as a regulatory asset earning a full rate of return.98 TURN and ORA

argue that the mobile home park decision is distinguishable because it focused on “whether and

how ratepayer funding should be used to support broad public purposes intertwined with basic

utility service.”99 This is exactly what the Commission must do in this proceeding. The rebates

are part of SCE’s proposal to support the broad public purposes established by SB 350, which

are intertwined with the basic utility service of providing electricity and electrical infrastructure,

in this case to be used as fuel for electric vehicles providing ratepayer and environmental

benefits.

The mobile home park decision is also relevant because it was a situation

where the regulatory treatment of costs dictated that they be treated as a regulatory asset under

Generally Accepted Accounting Principles (“GAAP”).100 In fact, TURN’s opening brief

recognizes that the mobile home park decision did not follow GAAP.101

96 D.16-12-065, pp. 64-65. 97 See Exhibit SCE-01, pp. 106-107; Exhibit SCE-02, pp. 24-27. 98 See D.14-03-021, p. 55, Finding of Fact 36, pp. 69-70, OP 8, p. 77. 99 TURN Brief, p. 81; ORA Brief, p. 47. 100 Exhibit SCE-02, pp. 24-25, including p. 24, fn. 80. 101 TURN Brief, p. 81.

20

c) After-the-Fact Reasonableness Review is Not Required

TURN clarifies that it is not currently proposing an after-the-fact

reasonableness review of cost spending, but rather is recommending that the Commission not

foreclose the option of conducting a future reasonableness review.102 TURN also acknowledges

that after-the-fact reasonableness reviews are rare.103 Given that SCE has agreed to a one-way

balancing account and will need to appropriately manage its budget within a set cap, a hindsight

review tied to outcomes would be subjective, onerous, and unfair. The Commission recently

issued a proposed decision on SCE’s priority-review projects in this proceeding that would, if

adopted, approve SCE’s cost-recovery proposal without requiring after-the-fact reasonableness

review. The proposed decision states that “[c]osts incurred for each project up to the authorized

level will be considered per se reasonable subject only to the utility’s prudent administration of

the project.”104 The Commission should adopt this same rationale to the costs for SCE’s

proposed medium- and heavy-duty EV infrastructure program.

d) SCE’s Proposal Appropriately Allocates Costs to Distribution Rates

TURN recommends that SCE collect all revenues not directly related to

distribution hardware through the Public Purpose Programs (“PPP”) charge.105 TURN argues

that this is appropriate because the “main focus of the TE proceeding is the support of

transportation electrification in order to facilitate State policy goals.”106 Although SCE agrees

with TURN’s characterization of this proceeding, it does not change the fact that distribution

assets should be recovered based on the distribution allocator. The precedents cited by TURN

102 Id., p. 75. 103 Id., p. 76. 104 November 22, 2017 Proposed Decision on the Transportation Electrification Priority Review Projects

in A.17-01-020 et al, p. 76. SCE recognizes that the Proposed Decision does not have legal effect unless and until it is approved by the Commission, but submits that it is germane to the decision that the Commission will be making on the standard-review proposals in this proceeding.

105 TURN Brief, p. 72. 106 Id.

21

(the Electric Program Investment Charge (“EPIC”) and the Self Generation Incentive Program

(“SGIP”)),107 are not analogous, as those programs do not involve traditional distribution assets.

EPIC costs are associated with research projects that span a spectrum of energy-related issues,

often falling outside of the distribution function. Examples include research into renewable

energy technologies, deployment of advanced energy communities, and evaluation

methodologies for EPCI projects. Because the research is in the general interest of energy use

and delivery, the recovery of EPIC cost is properly placed in the Public Purpose Charge.

Similarly, SGIP funds are used for purposes outside of the distribution function, despite the fact

that SCE currently recovers SGIP through a distribution charge.108 SGIP funds are used for the

deployment of behind-the-meter generation and storage technologies, which serve to alleviate

generation capacity constraints pursuant to the program’s original charter. TURN’s analogy is

not relevant for allocating cost that clearly fall within the distribution cost function. TURN’s

accounting of distribution-related costs fails to recognize all of the costs associated with SCE TE

programs are directly related to distribution assets. As SCE’s rebuttal testimony explained,

revenue allocation is conducted at the functionalized system level prior to the rate design

process, and the pension and benefits costs for all programs are forecast in SCE’s general rate

case and accounted for in two-way balancing accounts.109 TURN’s brief fails to provide

sufficient record evidence to justify deviating from the Commission’s long-standing policy

regarding cost causation in revenue allocation and rate setting.

E. Rate Design

1. PG&E


107 Id., p. 73. 108 D.01-03-073, p. 11. 109 Exhibit SCE-02, p. 34.

22

2. SCE

CALSTART and SBUA question the timeline of the proposed EV rate

implementation. CALSTART claims the demand charge phase-in should be contingent on

readiness, and that there is significant uncertainty with respect to how the industry will be

prepared to manage demand charges.110 SBUA questions the ability of customers to transition

from an energy rate to a rate with both energy and a demand charge following a five-year period

with an energy-only rate.111 SCE supports the timeline for the EV rate implementation described

in the Stipulation entered with ORA, NRDC, EDF, Siemens, Sierra Club, and CUE.112 The

stipulated terms reflect reasonable modifications to SCE’s testimony regarding proposed EV rate

design.

SCE’s rate and phase-in proposals seek to strike a balance between the goal of

providing a meaningful incentive to encourage transportation electrification, and reducing the

revenue shift and rate complexity that would otherwise be experienced by non-participating and

participating customers alike. The recommendation made by CALSTART and SBUA would not

achieve this balance. In establishing the original time line, SCE recognized that opening the

initial five-year, energy-only period should coincide with market emergence to provide the

greatest benefit. As stated in SCE’s opening testimony,113 SCE will assess the time it will take to

market the new rates to potential customers through customized rate comparisons and projected

bill savings to facilitate informed decision-making with a goal to begin offering the rates within a

reasonable timeframe after the Commission’s decision. Thus, SCE intends to determine

potential deployments to best time the beginning of the phase-in period. Furthermore, the

Commission has a long-standing policy of encouraging customers to manage demand, with the

110 CALSTART Brief, p. 9. 111 SBUA Brief, p. 17. 112 Exhibit Joint-12. 113 Exhibit SCE-01, p. 62.

23

goals of reducing overall cost of service and ensuring a stable and reliable grid.114 Demand

charges, at some level, have been an effective tool for sending price signals that encourage

demand management. The Commission should reject the proposal made by CALSTART and

SBUA to extend the five–year, energy-only period. Delaying the phase-in of demand charges

would only have the effect of delaying the point when customers seriously consider load

management. Phasing in demand charges over five years was designed to be gradual, to the

point where the rates in years six and seven are not significantly different than the energy-only

rates, however still provide some exposure to a demand charge rate.115 The agreement reached

in the rate design stipulation116 encompasses multiple interests and viewpoints, and thus

represents an equitable and fair resolution.

GPI is highly supportive of SCE’s proposed rates and phase-in of demand

charges. GPI “…find[s] the proposal to eliminate demand charges for five years, then slowly

add them back in an incremental manner, to be reasonable and a good step toward reducing

barriers for electrifying transportation, while attracting off-peak load that helps lower overall

system costs.” The only specific change GPI proposes is to make the energy-only rate available

until 2025. Under SCE’s current proposed schedule, the new TE rates would become available

at the earliest in the first quarter of 2019, with the five-year, energy-only period ending in the

first quarter of 2024. SCE finds GPI’s proposal unnecessary given the short amount of time

between the GPI’s proposal and the earliest that the five-year period is expected to end.

114 State of California Energy Action Plan, available at

http://www.cpuc.ca.gov/uploadedFiles/CPUC_Public_Website/Content/Utilities_and_Industries/Energy_-_Electricity_and_Natural_Gas/2003%20Energy%20Action%20Plan.pdf ; State of California DER Action Plan, available at http://www.cpuc.ca.gov/uploadedFiles/CPUC_Public_Website/Content/About_Us/Organization/Commissioners/Michael_J._Picker/2016%20DER%20Action%20Plan%20FINAL.pdf

115 Exhibit ORA-11; Exhibit Joint-12 - Section 1: Facilities-Related Demand (FRD) Charges. 116 Exhibit Joint-12.

24

Additionally, the remaining uncertainty regarding the exact timing of the five-year, energy-only

period opening could mean the five-year period ends in 2025 or later.

SCVTA expresses concern that SCE’s rate proposal, with the energy-only

structure and gradual phase-in of demand charges, does not present an advantage to customers

who have already fully deployed their fleets, or are using charging strategies that result in higher

utilization rates.117 SCE’s proposed rate structure, however, is designed for customers with low

load factors, who are growing their fleets and learning how to manage load on rates with demand

charges. Targeting this segment of customers was the goal of this proposal. In SCE’s 2018

GRC Phase 2, SCE presents proposals for general service rates similar to those described in

SCVTA’s brief.118 The GRC Phase 2 rates incorporate the same TOU periods as the proposed

TE rates. Distribution costs are also recovered through grid and peak components, with one

option where the distribution peak component is recovered through a time-differentiated demand

charge. The same option also recovers generation cost through a combination of time variant

energy and demand charges.119 The Commission should reject SCVTA’s proposal, as rates with

the structures proposed by SCVTA will be litigated in SCE’s 2018 GRC Phase 2.

F. Competition Issues

1. PG&E


2. SCE

CEFC argues that behind-the-meter services should not be provided solely by the

utility.120 As CEFC acknowledges, customers could install infrastructure on their property to

117 SCVTA Brief, p. 8. 118 SCE 2018 GRC Phase 2 Vol. 4 Rate Design Proposals. 119 SCE 2018 GRC Phase 2 Vol. 4 Rate Design Proposals, pp. 10-11. 120 CEFC Brief, p. 30.

25

support EV charging.121 SCE’s Proposed Program would not prevent customers from continuing

to select this option. SCE’s Program, however, is designed to support California’s goal of

widespread transportation electrification.122 The Legislature recognizes that “[w]idespread

transportation electrification requires electrical corporations to increase access to the use of

electricity as a transportation fuel.”123 If the Legislature had wanted the utilities to continue

business as usual, simply supporting TE growth by providing utility-side infrastructure under

their existing obligation to serve new load, then it would not have ordered the Commission to

“direct the utilities to file applications for programs and investments to accelerate widespread

transportation electrification.”124 If the market for behind-the-meter services was robust enough

to accelerate TE and support California’s goals without utility involvement, then the Legislature

may have weighed the benefits of utility involvement differently. Instead, California recognizes

the utilities’ fundamental role in accelerating widespread TE, and SCE’s Proposed Program

supports the state’s goals in a market-neutral manner.

SBUA recommends that SCE set a nonbinding 30 percent goal for contract

procurement with small businesses.125 SBUA does not provide any record evidence to justify

this arbitrary target. SCE’s opening brief demonstrated that its market-neutral approach will

allow customers to select the equipment that works best for their charging needs and encourage

third-party market participants, of any size business, to provide a variety of technologies.126 The

Commission should reject SBUA’s unsupported recommendation, which could limit customer

choice and increase Program costs.

121 Id. 122 See P.U. Code § 740.12(a)(2). 123 P.U. Code § 740.12(a)(1)(E). 124 See P.U. Code § 740.12(b). 125 SBUA Brief, p. 18. 126 SCE Opening Brief, p. 22.

26

G. Other Issues

1. PG&E


2. SCE

a) Tesla’s Request to Use Existing Meters for the Proposed Program is

Infeasible and Inconsistent with the Stipulation Between SCE and the

Joint Parties

Tesla expresses concerns about separate metering, and argues that “the

Stipulation is not entirely clear as to whether the EV load could be billed to the same account and

on the same rate plan as the existing facility’s load.127 In fact, the Stipulation is clear that “SCE

will require a separate meter for the EV load at each participating site to calculate EV load

impact and offer EV rates and pricing options.”128 For a customer to receive service on an EV

rate, the EV load must be separately metered, and accurate load data must be collected to learn

from the Program.

b) ChargePoint’s Requested Workshop is Unnecessary and Will Delay

Implementation

ChargePoint requests that the Commission facilitate an additional

workshop prior to implementing the Proposed Program.129 As SCE explained in its rebuttal

testimony, this proposal would unnecessarily delay implementation of this important program

that ChargePoint acknowledges is important to achieve the widespread transportation

electrification necessary to support the state’s goals.

127 Tesla Brief, p.7. 128 Exhibit Joint-11. 129 ChargePoint Brief, p. 29.

27

c) SCE Complies with Affiliate Transaction Rules

TURN cautions that the Commission must ensure that SCE abides by the

affiliate transaction rules because a subsidiary of SCE’s parent company, Edison International,

owns a stake in electric bus manufacturer Proterra.130 SCE complies with all applicable affiliate

transaction rules, so TURN’s admonition is unnecessary, as well as being outside the scope of

this proceeding.

H. Conclusion

1. PG&E


2. SCE

For the foregoing reasons, SCE respectfully requests that the Commission

promptly approve SCE’s proposed medium- and heavy-duty EV infrastructure program and new

EV rate design, as modified by the stipulations on the record of this proceeding.

III.

SDG&E RESIDENTIAL CHARGING PROGRAM

This reply brief only addresses SCE’s proposed standard-review projects. SCE has no

comments on SDG&E’s proposed program.

130 TURN Brief, p. 83.

28

Respectfully submitted, Fadia R. Khoury Andrea L. Tozer

/s/ Andrea L. Tozer By: Andrea L. Tozer

Attorneys for SOUTHERN CALIFORNIA EDISON COMPANY

2244 Walnut Grove Avenue Post Office Box 800 Rosemead, California 91770 Telephone:(626) 302-6713 Facsimile: (626) 302-6693 E-mail: [email protected]

December 21, 2017


STATE OF CALIFORNIA



And Related Matters.


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 BRIEF OF SOUTHERN CALIFORNIA EDISON COMPANY (U 338-E) ON THE STANDARD REVIEW TRANSPORTATION ELECTRIFICATION PROPOSALS FROM SAN DIEGO GAS & ELECTRIC COMPANY, SOUTHERN CALIFORNIA EDISON COMPANY, AND PACIFIC GAS AND ELECTRIC COMPANY on all parties identified on the attached service list(s) for A.17-01-020, 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.

Transmitting a copy via email to ALJ Michelle Cooke at [email protected] as she has requested no paper copies.

Placing the copies in sealed envelopes and causing such envelopes to be delivered by US Mail to the offices of the Commissioners(s) or other addresses(s).

ALJ Sasha Goldberg CPUC 505 Van Ness Avenue San Francisco, CA 94102

Executed December 21, 2017, at Rosemead, California.

/s/ Sandra Sedano Sandra Sedano Legal Administrative Assistant SOUTHERN CALIFORNIA EDISON COMPANY

2244 Walnut Grove Avenue Post Office Box 800 Rosemead, California 91770

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JAY FRIEDLAND NORMAN HAJJA ZERO MOTORCYCLES RECARGO, INC. EMAIL ONLY EMAIL ONLY EMAIL ONLY, CA 00000 EMAIL ONLY, CA 00000 FOR: ZERO MOTORCYCLES FOR: REGARCO, INC.

JOE HALSO EDWARD L. HSU ASSOCIATE ATTORNEY SR COUNSEL SIERRA CLUB SOUTHERN CALIFORNIA GAS COMPANY 1536 WYNKOOP ST., STE. 312 555 WEST 5TH STREET, GT14E7 DENVER, CO 80202 LOS ANGELES, CA 90013 FOR: SIERRA CLUB FOR: SOUTHERN CALIFORNIA GAS COMPANY

ADRIANO MARTINEZ THOMAS ASHLEY ATTORNEY AT LAW SR. DIR - GOVN'T AFFAIRS & PUBLIC POLICY EARTHJUSTICE GREENLOTS 800 WILSHIRE BLVD., SUITE 1000 925 N. LA BREA AVENUE, 6TH FLOOR LOS ANGELES, CA 90017 LOS ANGELES, CA 90038 FOR: EAST YARD COMMUNITIES FOR FOR: GREENLOTS ENVIRONMENTAL JUSTICE AND CENTER FOR COMMUNITY ACTION AND ENVIRONMENTAL JUSTICE

KATHERINE STAINKEN DEMETRA J. MCBRIDE POLICY DIR. ENVIRONMENTAL INITIATIVES DIVISION MGR PLUG IN AMERICA COUNTY OF LOS ANGELES 6380 WILSHIRE BLVD., STE. 1010 1100 NORTH EASTERN AVENUE LOS ANGELES, CA 90048 LOS ANGELES, CA 90063-3200

Page 1 of 11CPUC - Service Lists - A1701020

12/21/2017https://ia.cpuc.ca.gov/servicelists/A1701020_84073.htm

FOR: PLUG IN AMERICA FOR: COUNTY OF LOS ANGELES (LA COUNTY)

TERRY O'DAY JESSALYN ISHIGO VP ENVIRONMENTAL BUSINESS DEVELOPMENT OFF. EVGO SERVICES LLC AMERICAN HONDA MOTOR CO., INC. 11390 WEST OLYMPIC BLVD 1919 TORRANCE BLVD. LOS ANGELES, CA 90064 TORRANCE, CA 90501 FOR: EVGO SERVICES LLC FOR: AMERICAN HONDA MOTOR CO., INC.

MAX BAUMHEFNER WAYNE NASTRI LEGAL FELLOW EO - MANAGEMENT DISTRICT NATURAL RESOURCES DEFENSE COUNCIL SOUTH COAST AIR QUALITY 111 SUTTER ST., 21ST FLOOR 21865 COPLEY DRIVE SAN FRANCISCO, CA 91404 DIAMOND BAR, CA 91765-0940 FOR: NATURAL RESOURCES DEFENSE COUNCIL FOR: SOUTH COAST AIR QUALITY MANAGEMENT DISTRICT

ANDREA TOZER DONALD KELLY SR. ATTORNEY EXE. DIRECTOR SOUTHERN CALIFORNIA EDISON COMPANY UTILITY CONSUMERS' ACTION NETWORK 2244 WALNUT GROVE AVE / PO BOX 800 3405 KENYON ST., STE. 401 ROSEMEAD, CA 91770 SAN DIEGO, CA 92110 FOR: SOUTHERN CALIFORNIA EDISON COMPANY FOR: UTILITY CONSUMERS' ACTION NETWORK (UCAN)

LISA MCGHEE DESMOND WHEATLEY OPERATIONS MGR. CEO SAN DIEGO AIRPORT PARKING CO. ENVISION SOLAR INTRERNATIONAL, INC. 2771 KURTZ ST. 5660 EASTGATE DRIVE SAN DIEGO, CA 92110 SAN DIEGO, CA 92121 FOR: SAN DIEGO AIRPORT PARKING COMPANY FOR: ENVISION SOLAR INTERNATIONAL, INC.

JOHN W. LESLIE, ESQ JOHN A. PACHECO ATTORNEY ATTORNEY DENTONS US LLP SAN DIEGO GAS & ELECTRIC COMPANY EMAIL ONLY 8330 CENTURY PARK CT., CP32 EMAIL ONLY, CA 92121 SAN DIEGO, CA 92123 FOR: SHELL ENERGY NORTH AMERICA (US), FOR: SAN DIEGO GAS & ELECTRIC COMPANY L.P.

SACHU CONSTANTINE STEPHEN G. DAVIS DIR. OF POLICY CEO CENTER FOR SUSTAINABLE ENERGY OXYGEN INITIATIVE 9325 SKY PARK COURT, SUITE 100 65 ENTERPRISE SAN DIEGO, CA 92123 ALISO VIEJO, CA 92656 FOR: CENTER FOR SUSTAINABLE ENERGY (CSE) FOR: EXYGEN INITIATIVE (FORMERLY KNGRID)

MICHAEL CHIACOS TADASHI GONDAI ENERGY PROGRAM DIR. DIR OF LEGAL AFFAIRS COMMUNITY ENVIRONMENTAL COUNCIL NATIONAL ASIAN AMERICAN COALITION 26 W. ANAPAMU ST., 2ND FLR. 15 SOUTHGATE AVE., STE. 200 SANTA BARBARA, CA 93101 DALY CITY, CA 94015 FOR: COMMUNITY ENVIRONMENTAL COUNCIL FOR: THE NATIONAL ASIAN AMERICAN COALITION AND THE NATIONAL DIVERSITY COALITION



DAVID SCHLOSBERG MILA A. BUCKNER DIR - ENERGY MARKET OPER ATTORNEY EMOTORWERKS ADAMS BROADWELL JOSEPH & CARDOZO 846 BRANSTEN ROAD 601 GATEWAY BLVD., STE. 1000 SAN CARLOS, CA 94070 SOUTH SAN FRANCISCO, CA 94080 FOR: ELECTRIC MOTORWERKS, INC. FOR: COALITION OF CALIFORNIA UTILITY EMPLOYEES

TOVAH TRIMMING AUSTIN M. YANG CALIF PUBLIC UTILITIES COMMISSION DEPUTY CITY ATTORNEY LEGAL DIVISION CITY AND COUNTY OF SAN FRANCISCO ROOM 4107 1 DR. CARLTON B. GOODLETT PL, RM 234 505 VAN NESS AVENUE SAN FRANCISCO, CA 94102-4682 SAN FRANCISCO, CA 94102-3214 FOR: CITY & COUNTY OF SAN FRANCISCO FOR: ORA

ELISE TORRES EVELYN KAHL STAFF ATTORNEY COUNSEL THE UTILITY REFORM NETWORK ALCANTAR & KAHL LLP 785 MARKET STREET, SUITE 1400 345 CALIFORNIA ST., STE. 2450 SAN FRANCISCO, CA 94103 SAN FRANCISCO, CA 94104 FOR: TURN FOR: CLEAN ENERGY FUELS

JAMES BIRKELUND CHRISTOPHER WARNER PRESIDENT PACIFIC GAS AND ELECTRIC COMPANY SMALL BUSINESS UTILITY ADVOCATES 77 BEALE STREET, B30A 548 MARKET STREET, SUITE 11200 SAN FRANCISCO, CA 94105 SAN FRANCISCO, CA 94104 FOR: PACIFIC GAS AND ELECTRIC COMPANY FOR: SMALL BUSINESS UTILITY ADVOCATES

LARISSA KOEHLER DANIEL T. ROCKEY SENIOR ATTORNEY ATTORNEY ENVIRONMENTAL DEFENSE FUND BRYAN CAVE LLP 123 MISSION STREET, 28TH FLOOR THREE EMBARCADERO CENTER, 7TH FLOOR SAN FRANCISCO, CA 94105 SAN FRANCISCO, CA 94111 FOR: ENVIRONMENTAL DEFENSE FUND FOR: LYFT, INC

HOWARD V. GOLUB IRENE K. MOOSEN ATTORNEY ATTORNEY AT LAW NIXON PEABODY LLP LAW OFFICE OF IRENE K. MOOSEN 1 EMBARCADERO CENTER, STE. 1800 53 SANTA YNEZ AVENUE SAN FRANCISCO, CA 94111 SAN FRANCISCO, CA 94112 FOR: CITY OF LONG BEACH CALIFORNIA, A FOR: LOCAL GOVERNMENT SUSTAINABLE MUNICIPAL CORPORATION, ACTING BY AND ENERGY COALITION (LGSEC) THROUGH ITS BOARD OF HARBOR COMMISSIONERS

BEAU WHITEMAN CHRIS KING SR. MGR., EV INFRASTRUCTURE GLOBAL CHIEF REGULATORY OFFICER TESLA MOTORS, INC. SIEMENS SMART GIRD SOLUTIONS 3500 DEER CREEK ROAD 4000 E 3RD AVE., STE. 400 PALSO ALTO, CA 94304 FOSTER CITY, CA 94404 FOR: TESLA, INC. FOR: SIEMENS



A J HOWARD JIMMY O'DEA, PH.D OLIVINE, INC. VEHICLES ANALYST 2010 CROW CANYON PLACE, STE. 100 UNION OF CONCERNED SCIENTISTS SAN RAMO, CA 94583 500 12TH STREET, STE. 340 FOR: OLIVINE, INC. OAKLAND, CA 94607 FOR: UNION OF CONCERNED SCIENTISTS

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GREGORY MORRIS RYAN SCHUCHARD DIRECTOR POLICY DIR. GREEN POWER INSTITUTE CALSTART 2039 SHATTUCK AVENUE, STE 402 501 CANAL BLVD., NO. G BERKELEY, CA 94704 RICHMOND, CA 94804 FOR: THE GREEN POWER INSTITUTE FOR: CALSTART

CHRISTINA JAWORSKI JAMES HALL SR. ENVIRONMENTAL PLANNER GENERAL MOTORS LLC SANTA CLARA VALLEY TRANSP. AUTHORITY 1115 11TH STREET 3331 NORTH FIRST ST., BLDG B-2 SACRAMENTO, CA 95814 SAN JOSE, CA 95134 FOR: GENERAL MOTORS LLC FOR: SANTA CLARA VALLEY TRANSPORTATION AUTHORITY (VTA)

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LAURA TAYLOR ATTORNEY



BRAUN BLAISING MCLAUGHLIN & SMITH, P.C. 915 L STREET, STE. 1480 SACRAMENTO, CA 95822 FOR: SILICON VALLEY CLEAN ENERGY AUTHORITY

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REGULATORY CLERK SEPHRA NINOW BRAUN BLAISING SMITH WYNNE, PC ASSOCIATE DIR - REGULATORY EMAIL ONLY CENTER SUSTAINABLE ENERGY EMAIL ONLY, CA 00000 EMAIL ONLY EMAIL ONLY, CA 00000

MRW & ASSOCIATES, LLC EDWARD LOVELACE, PH.D EMAIL ONLY CHIEF TECHNOLOGY OFFICER EMAIL ONLY, CA 00000 XL HYBRIDS 145 NEWTON STREET BOSTON, MA 02135

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GREGORY REISS JAMIESON WARD CENTENUS GLOBAL MANAGEMENT, LP CENTENUS GLOBAL MANAGEMENT, LP 437 MADISON AVENUE, SUITE 19B 437 MADISON AVENUE - SUITE 19B



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DAVID CROYLE JOE KAATZ EXECUTIVE DIRECTOR STAFF ATTORNEY UTILITY CONSUMERS' ACTION NETWORK UNIVERSITY OF SAN DIEGO SCHOOL OF LAW 3405 KENYON STREET, STE. 401 5998 ALCALA PARK SAN DIEGO, CA 92110 SAN DIEGO, CA 92110-2492

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RANDY SCHIMKA SUE MARA SAN DIEGO GAS & ELECTRIC COMPANY CONSULTANT



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JIN NOH C. C. SONG SR. CONSULTANT REGULATORY ANALYST STRATEGEN CONSULTING MARIN CLEAN ENERGY 2150 ALLSTON WAY, STE.210 1125 TAMALPAIS AVE. BERKELEY, CA 94709 SAN RAFAEL, CA 94901 FOR: MCE

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ETTA LOCKEY SR. COUNSEL PACIFICORP 825 NE MULTNOMAH ST., STE. 1500 PORTLAND, OR 97232

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QUANG PHAM RICK TSE CALIF PUBLIC UTILITIES COMMISSION CALIF PUBLIC UTILITIES COMMISSION COMMUNICATIONS AND WATER POLICY BRANCH ELECTRIC SAFETY AND RELIABILITY BRANCH AREA 2-D AREA 2-D 505 VAN NESS AVENUE 505 VAN NESS AVENUE SAN FRANCISCO, CA 94102-3214 SAN FRANCISCO, CA 94102-3214 FOR: ORA FOR: ORA

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TIM G. DREW NOEL CRISOSTOMO CALIF PUBLIC UTILITIES COMMISSION AIR POLUTION SPECIALIST



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