Southern California Edison Company 2021 GRC

A. 19-08-013

TURN HEARING EXHIBIT

TURN-070

SCE Response to TURN-SCE DR 60, Question 17

SCE Response to TURN-SCE DR 86, Questions 3,4,7

SCE Response to TURN-SCE DR Verbal 8, Question 1

Southern California Edison

A.19-08-013 – SCE 2021 GRC    

DATA REQUEST SET T U R N - S C E - 0 6 0

To: TURN Prepared by: Jake Huttner

Job Title: Sr. Manager Received Date: 7/6/2020

Response Date: 7/7/2020

Question 17 Revised 2: Regarding SCE03V1A Billing and Payments (all page references are for SCE03V1A unless otherwise noted) Page 48 of Supplemental Workpapers provides adjustments to the uncollectible rate as a result of D.18-12-013. Please provide justification and documentation regarding how the impacts of $128K (elderly and medically vulnerable) and $1.870 million (definition change of extreme weather) were determined. Response to Question 17 Revised 2: The tables below, also attached as “TURN-SCE-060-Q17-Revised.xlsx,” provide the assumptions and calculations SCE used to determine the $128,000 (elderly and medically vulnerable) and $616,187 (definition change of extreme weather) adjustments to the uncollectible rate as a result of the measures adopted in D.18-12-013.

TURN‐SCE‐060:  17 Revised 2 Page 2 of 3 

  

The table below, also shown in the tab titled “Weather Revised” attached in “TURN-SCE-060-Q17-Revised.xlsx,” provides the assumptions and calculations SCE used to determine the $616,187 (definition change of extreme weather) adjustment to the uncollectible rate as a result of the measures adopted in D.18-12-013. To arrive at the Disconnection OIR adjustment forecast, SCE used January 2019 to June 2019 Recorded data as presented below.

TURN‐SCE‐060:  17 Revised 2 Page 3 of 3 

  

SCE’s Disconnection OIR adjustment analysis uses January 2019 to June 2019 Recorded data of 35,528 Total Account Eligible but Not Disconnected (A) and 3,295 Total Accounts Written-Off (B) to Arrive at a 0.93 9.3 percent Account Write-Off Percent (C) (3,295/35,528). The Account Write-Off Percent represents the number of Total Accounts Eligible for Disconnection and Not Disconnected that eventually closed and the unpaid arrearages were written-off. The January 2019 to June 2019 Average Account Write-off Percent was used to determine the July 2019 to December 2019 accounts (D and E), since July 2019 to December 2019 Recorded is not yet available due to the lag in time between Disconnection and Actual Recorded Write-Off. The average bills (F and G) was then used to estimate the Potential Write-Off amount (H and I). This results in a Total Potential Write-Off forecast (J) of $616,187.

Southern California Edison

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

DATA REQUEST SET T U R N - S C E - 0 8 6

To: TURN Prepared by: Jake Huttner

Job Title: Manager Received Date: 6/17/2020

Response Date: 6/23/2020

Question 03: (Page 11) SCE states, “Specifically, NEM 2.0, TOU and CCA customer bills require calculations based on Over The Air (OTA) reads for approximately 2,880 intervals per month. This additional complexity is in stark contrast to standard domestic tiered rate customer accounts, where interval data is not required for customer bill calculations.” Is SCE saying that all CCA customers are TOU customers and not on tiered rates? If not, please explain why a CCA customer on tiered rate would require more interval calculations than a SCE customer on tiered rate Response to Question 03: SCE clarifies, currently all CCA customers are not TOU rate customers.

A CCA customer on a tiered rate does not require more interval calculations than an SCE customer on a tiered rate. However, as SCE stated in testimony (SCE-14, p. 11, lines 16-19) CCA customers add additional complexity to the billing process due to the requirement to provide interval usage data with the CCAs (specifically, the CCA’s back office provider) for the purposes of calculating CCA charges separately.

Southern California Edison

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

DATA REQUEST SET T U R N - S C E - 0 8 6

To: TURNTURN Prepared by: Jake Huttner

Job Title: Manager Received Date: 6/17/2020

Response Date: 6/24/2020

Question 04: (Page 11) Please confirm or deny that SCE collects and processes interval data for customers on tiered rates. Response to Question 04: SCE confirms that it collects and processes interval data for customers on tiered rates.

In SCE Rebuttal Testimony, page 11, SCE states, “This additional complexity is in stark contrast to standard domestic tiered rate customer accounts, where interval data is not required for customer bill calculations.” SCE clarifies that interval data is not required to calculate bills for customers on tiered rates. However, SCE’s billing system checks the interval data collected against a set of pre-defined data validations to ensure accuracy and completeness of the data. Any validation that fails in this process can lead to exceptions which require manual intervention. These pre-defined data validations include confirmation of regular interval data reads from meters.

Additionally, while interval data is not utilized to calculate bills for customers on tiered rates, the collection and processing of interval data for customer on tiered rates is also used for the purpose of providing customer service features such as providing hourly usage charts on sce.com, supporting the Budget Assistant program and enabling the Rate Analyzer tool.

Southern California Edison

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

DATA REQUEST SET T U R N - S C E - 0 8 6

To: TURN Prepared by: Jake Huttner

Job Title: Manager Received Date: 6/17/2020

Response Date: 6/24/2020

Question 07: (Page 18) Please provide the recorded volume mix for Credit and Payment Services work channels for 2014-2019. Response to Question 07:

SCE is providing available recorded data on both Completed and Incoming work volume for Credit and Payment Services by work channel below and in the attached file “TURN-086-Q7.xlsx”.

* Completed Work data for 2014 is not provided because data collection was limited to a few work functions and is insufficient as comparison data.

** In 2017, SCE implemented a new reporting system. As a result, the 2017 Completed Work data is incomplete.

*** SCE began Incoming Work volume reporting in 2018. Active Collections 2018 Incoming Work volume is understated due to data missing in Q1 as data capture and reporting came online.

Recorded Work VolumeCompleted Work 2014* 2015 2016 2017** 2018 2019Active Collections - 283,099 276,000 284,551 390,289 345,145Payment Management - 50,086 48,170 48,303 51,054 65,814Inactive Collections - 178,027 66,808 67,511 113,450 136,218Customer Risk & Bankruptcy - 35,491 39,764 35,340 49,731 82,874Total - 546,703 430,742 435,705 604,524 630,051

Incoming Work *** 2014 2015 2016 2017 2018 2019Active Collections - - - - 312,175 351,075Payment Management - - - - 86,197 65,814Inactive Collections - - - - 207,789 196,788Customer Risk & Bankruptcy - - - - 79,981 90,020Total - - - - 686,142 703,697

Southern California Edison

A.19-08-013 – SCE 2021 GRC    

DATA REQUEST SET T U R N - S C E - V e r b a l - 0 0 8

To: TURN Prepared by: Jake Huttner

Job Title: Sr. Advisor Received Date: 7/6/2020

Response Date: 7/7/2020

Question 01 Revised: Has SCE observed examples where all the customers affected by a delayed shutoff did not pay 100% of "additional" usage due to that delayed shutoff (e.g. due to credit moratorium)? If yes, please provide examples and explanations. Response to Question 01 Revised: SCE has not observed examples where all the customers affected by a delayed shutoff did not pay 100% of the additional usage. SCE clarifies that this was not an assumption included in SCE’s Disconnection OIR adjustment analysis. In its response to TURN-SCE-086, Question 8a, SCE describes the impact of its Payment Posting Priority policy, in which partial payments are applied to the customer’s oldest arrearage first. Again, as explained in that response, unless a customer fully pays all their oldest arrearage balance, they will not pay the charges incurred from the “additional” usage as described. Therefore, if some customers make a partial payment to avoid a disconnection, they will most likely accrue 1-month of additional energy usage prior to disconnection. SCE assumed that some customers will pay some of the new “additional” energy usage, and some will accrue more than the “additional” energy usage. Thus, SCE’s assumption of 1-month additional energy usage is reasonable for forecasting purposes. Further, in the process of responding to this request and re-examining the Disconnection OIR adjustment analysis, SCE discovered an error in its calculation of the number of customers impacted by the extreme weather protections with arrearages that were eventually written-off. In SCE’s forecast and the analysis presented in response to TURN-SCE-060, Question 17, SCE used 3 percent as the estimated number of customers with arrearages to be written-off from extreme weather disconnection deferment. The 3 percent estimate represented the accounts eligible for disconnection (previously estimated at 12,813 accounts in column B in the table on p. 2 of SCE’s response to TURN-SCE-060, Question 17) but did not accurately represent the number of accounts with arrearages which were eventually written-off, now estimated at 3,295 accounts using recorded data as shown in column B in the table below. To arrive at a more accurate Disconnection OIR adjustment forecast SCE corrected the Disconnection OIR adjustment analysis using January 2019 to June 2019 Recorded data that is now available as presented below (also attached as “TURN-SCE-V-008.xlsx”).

TURN‐SCE‐Verbal‐008:  01 Revised Page 2 of 4 

  

TURN‐SCE‐Verbal‐008:  01 Revised Page 3 of 4 

  

SCE’s updated Disconnection OIR adjustment analysis uses January 2019 to June 2019 Recorded data of 35,528 Total Account Eligible but Not Disconnected (A) and 3,295 Total Accounts Written-Off (B) to Arrive at an 0.93 9.3 percent Account Write-Off Percent (C) (3,295/35,528). The Account Write-Off Percent represents the number of Total Accounts Eligible for Disconnection and Not Disconnected that eventually closed and the unpaid arrearages were written-off. The January 2019 to June 2019 Average Account Write-off Percent was used to determine the July 2019 to December 2019 accounts (D and E), since July 2019 to December 2019 Recorded is not yet available due to the lag in time between Disconnection and Actual Recorded Write-Off. The average bills (F and G) was then used to estimate the Potential Write-Off amount (H and I). The updated analysis lowers the estimated Total Potential Write-Off forecast (J) from $1,870,263 to $616,187. SCE will correct this forecast amount in a future errata. SCE will also submit a revised response to TURN-SCE-060, Question 17 that will reflect the same corrected forecast amount. This corrected Disconnection OIR adjustment analysis lowers the Uncollectible Disconnect OIR Adjustment factor (shown below in the updated SCE-03, Vol. 1A WP p. 48) from 0.017 percent to 0.006 percent as shown below.

TURN‐SCE‐Verbal‐008:  01 Revised Page 4 of 4 

  

The errata to SCE-03A Workpapers is attached to this response as “WPSCE03V01A.Errata.p.48.pdf.”

(U 338-E)

2021 General Rate Case A.19-08-013

Workpapers

Billing & Payments SCE-03 Volume 01A

February 2020

Amended

Workpaper – Southern California Edison / 2021 General Rate Case

Exhibit No. SCE-03 Vol.01

A Witnesses: B. Anderson

SUPPLEMENTAL WORKPAPERS

Uncollectible Expenses

Uncollectible Disconnect OIR Adjustment

Discussed in SCE-03, Vol. 01

(in nominal 2018 $000)

4848