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BEFORE THE PUBLIC UTILITIES COMMISSION OF THE STATE OF CALIFORNIA Application of SOUTHERN CALIFORNIA EDISON COMPANY (U 338-E, a California Corporation, to Open a 2015 Safety Model Assessment Proceeding Application No. A.15-05-005 (Filed May 1, 2015 REPLY OF SOUTHERN CALIFORNIA EDISON COMPANY (U 338-E TO THE PROTESTS BY MUSSEY GRADE ROAD ALLIANCE, THE UTILITY REFORM NETWORK, AND THE UTILITY CONSUMERS ACTION NETWORK Pursuant to Rule 2.6(e of the Commission s Rules of Practice and Procedure, Southern California Edison Company (SCE 1 respectfully submits this Reply to the protests submitted by Mussey Grade Road Alliance (Mussey Grade, The Utility Reform Network (TURN, and the Utility Consumer s Action Network (UCAN. On May 1, 2015, SCE filed its Safety Model Assessment Proceeding (SMAP application, which appeared on the Commission s Daily Calendar on May 8, 2015. Protests or responses were due 30 days later on June 8. Mussey Grade, TURN, and UCAN each timely filed a protest. While SCE disagrees with certain contentions made in the protests, this reply does not address all of the issues raised in the protests. SCE expects these issues to be addressed more fully in workshops. SCE looks forward to that process. 1 SCE and PG&E are submitting substantively identical reply briefs to the protests by Mussey Grade, TURN, and UCAN. Because the various SMAP applications were not consolidated at the time SCE and PG&E filed their replies, they were unable to submit their replies as a single, joint brief. 1

1. The Focus of the SMAP Should be on Analyzing Each Utility s Current Risk Assessment Methodologies in the Context of Its Unique Circumstances. While SCE agrees that adopting common standards and guidelines is laudable, the protesting parties put undue emphasis on finding common risk assessment models for all utilities. 2 Overly prescriptive requirements at this juncture would impede the utilities from improving their risk models as they gain experience with the process and analytics. The SMAP should first focus on the risk assessment methodologies, processes, and tools each utility has already developed to accommodate the unique circumstances and risks each faces. Indeed, a review of the utilities SMAP applications reveals that the utilities differ in their specific assets, asset conditions, data maturity, and data modeling capabilities, and it is therefore appropriate that a variety of risk assessment methods are used by each company. Through time and experience, each utility s risk models will evolve. Through that evolution in future SMAPs, common standards may be practicable. But at this point, the SMAP should focus on analyzing each utility s approach to managing risk in the context of its particular risk profile. Similarly, the focus of the SMAP should not be on whether each utility s risk-assessment tools produce particular results. Mussey Grade criticizes SCE s Risk Evaluation Tools (RETs because Mussey Grade disagrees with the apparent results of the tools. 3 Mussey Grade s understanding of the RET and what it produces is incomplete. First, some of the data provided in this proceeding is illustrative and not intended to indicate a final determination of each risk s relative severity. Second, the purpose of SMAP is to examine, understand, and comment on the models that the energy utilities plan to use to prioritize risks and to mitigate risks. 4 Therefore, the focus now should not be on the output or results of the utilities models but rather on how each utility assesses the risks to safety associated with its system and services, and the tools or activities that it plans to use to manage, mitigate, and minimize such risks. 5 2 UCAN Protest, p. 3; TURN Protest, p. 2; Mussey Grade Protest, p. 3. 3 See generally Mussey Grade Protest, pp. 4-7. 4 D.14-12-025, p. 21 (emphasis added. 5 Id. at 29 (emphasis added. 2

2. The SMAP Should be Categorized as Quasi-Legislative. TURN s arguments that this proceeding should be categorized as ratesetting misconstrue the Public Utilities Code and the Rules of Practice and Procedure. First, the Legislature defined quasi-legislative proceedings as those that establish policy, including, but not limited to, rulemakings and investigations which may establish rules affecting an entire industry. 6 During the SMAP, the Commission will examine the various models and methodologies that the energy utilities will be using to prioritize safety in their GRC proceedings. 7 TURN agrees that the various utility applications should be consolidated and filed the same comments on each of them. Second, ratesetting proceedings are those in which the Commission sets or investigates rates for a specifically named utility (or utilities, or establishes a mechanism that in turn sets the rates for a specifically named utility (or utilities. 8 Nothing in the SMAP will set rates, investigate rates, or establish a mechanism for setting rates. Instead, the purpose of this proceeding is to allow the Commission and parties to examine, understand, and comment on the models that the energy utilities plan to use to prioritize risks and to mitigate risks. 9 Indeed, TURN acknowledges that this proceeding will not, in itself, change rates. 10 Nevertheless, TURN argues that the SMAP should be categorized as ratesetting because it will lead to the setting of rates. 11 Such a broad interpretation would render the definition of ratesetting nearly meaningless since virtually any proceeding could eventually lead to some ratesetting. For these reasons, the Commission should categorize this proceeding as quasilegislative. 12 6 Cal. Pub. Util. Code 1701.1(c(1 (emphasis added. 7 D.14-12-025, p. 24 (emphasis added. 8 Rule 1.3(e. 9 D.14-12-025, p. 21 (emphasis added. 10 TURN Protest, p. 5. 11 Id. (emphasis added. 12 There appears to be a typographical error in the Resolution making preliminary determinations of the categorizations of the SMAP for SDG&E and SoCalGas. The Resolution states that SDG&E and SoCalGas proposed in their applications that the SMAP be deemed a ratesetting proceeding. 3

3. Workshops Will Provide the Best Forum for Discussing the Issues Presented in the Applications and Protests. SCE proposed in its application the topics to discuss at workshops. SCE plans to bring to the Prehearing Conference a joint utility proposal for workshop topics that will appropriately encompass the various issues raised by the protesting parties. Respectfully submitted, ALLAN D. JOHNSON ROBERT F. LeMOINE June 18, 2015 /s/ Allan D. Johnson By: Attorneys for SOUTHERN CALIFORNIA EDISON COMPANY 2244 Walnut Grove Avenue Post Office Box 800 Rosemead, California 91770 Telephone: (626 302-6735 Facsimile: (626 302-7440 E-mail: allan.johnson@sce.com Resolution ALJ 176-3357 (05/21/15. But SDG&E s and SoCalGas s applications both propose that the SMAP be categorized as quasi-legislative. See SDG&E s SMAP Application (A.15-05-002 at p. 4; SoCalGas s SMAP Application (A.15-05-004 at p.4. 4

BEFORE THE PUBLIC UTILITIES COMMISSION OF THE STATE OF CALIFORNIA Application of SOUTHERN CALIFORNIA EDISON COMPANY (U 338-E, a California Corporation, to Open a 2015 Safety Model Assessment Proceeding Application No. A.15-05-005 (Filed May 1, 2015 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 OF SOUTHERN CALIFORNIA EDISON COMPANY (U 338-E TO THE PROTESTS BY MUSSEY GRADE ROAD ALLIANCE, THE UTILITY REFORM NETWORK, AND THE UTILITY CONSUMERS ACTION NETWORK on all parties identified on the attached service list(s A.15-05-002 et al. Service was effected by one or more means indicated below: Transmitting the copies via e-mail to all parties who have provided an e-mail address. Placing the copies in sealed envelopes and causing such envelopes to be delivered by hand or by overnight courier to the offices of the Assigned ALJ(s or other addressee(s. ALJ Colette Kersten CPUC 505 Van Ness Ave. San Francisco, CA 94102 Executed July 14, 2015, at Rosemead, California. /S/ Laura Velarde Laura Velarde SOUTHERN CALIFORNIA EDISON COMPANY 2244 Walnut Grove Avenue Post Office Box 800 Rosemead, California 91770

CPUC - Service Lists - A1505002 http://www.cpuc.ca.gov/service_lists/a1505002_83111.htm Page 1 of 3 7/14/2015 CPUC Home CALIFORNIA PUBLIC UTILITIES COMMISSION Service Lists PROCEEDING: A1505002 - SDG&E FOR REVIEW O FILER: SAN DIEGO GAS & ELECTRIC COMPANY LIST NAME: LIST LAST CHANGED: JULY 14, 2015 Download the Comma-delimited File About Comma-delimited Files Back to Service Lists Index Parties SHARON YANG ALLAN D. JOHNSON SENIOR COUNSEL SOUTHERN CALIFORNIA EDISON COMPANY SOUTHERN CALIFORNIA GAS COMPANY PO BOX 800 555 WEST FIFTH ST., STE. 1400, GT-14E7 2244 WALNUT GROVE AVE. LOS ANGELES, CA 90013 ROSEMEAD, CA 91770 FOR: SOUTHERN CALIFORNIA GAS COMPANY FOR: SOUTHERN CALIFORNIA EDISON COMPANY DIANE CONKLIN DONALD KELLY SPOKESPERSON EXE. DIRECTOR MUSSEY GRADE ROAD ALLIANCE UTILITY CONSUMERS' ACTION NETWORK PO BOX 683 3405 KENYON ST., STE. 401 RAMONA, CA 92065 SAN DIEGO, CA 92110 FOR: MUSSEY GRADE ROAD ALLIANCE FOR: UTILITY CONSUMERS' ACTION NETWORK JAMIE K. YORK THOMAS LONG REGULATORY CASE ADMIN. LEGAL DIR. SAN DIEGO GAS & ELECTRIC COMPANY THE UTILITY REFORM NETWORK 8330 CENTURY PARK COURT, CP32D 785 MARKET ST., STE. 1400 SAN DIEGO, CA 92123 SAN FRANCISCO, CA 94103 FOR: SAN DIEGO GAS & ELECRIC COMPANY FOR: THE UTILITY REFORM NETWORK STEVEN W. FRANK WILLIAM JULIAN II LAW DEPARTMENT UTILITY WORKERS UNION OF AMERICA PACIFIC GAS AND ELECTRIC COMPANY 43556 ALMOND LANE PO BOXX 7442 DAVIS, CA 95618 SAN FRANCISCO, CA 94120 FOR: UTILITY WORKERS UNION OF AMERICA FOR: PACIFIC GAS AND ELECTRIC COMPANY Information Only ALICIA AGUILAR CASE COORDINATION LEGAL SECRETARY/PARALEGAL PACIFIC GAS AND ELECTRIC COMPANY HANNA AND MORTON LLP, CA 00000

CPUC - Service Lists - A1505002 http://www.cpuc.ca.gov/service_lists/a1505002_83111.htm Page 2 of 3 7/14/2015, CA 00000 FOR: SOUTHERN CALIFORNIA GENERATION COALITION EVELYN KAHL JAMIE L. MAULDIN COUNSEL ADAMS BROADWELL JOSEPH & CARDOZO, PC ALCANTAR & KAHL, CA 00000, CA 00000 KATY MORSONY MARC D. JOSEPH ALCANTAR & KAHL ADAMS BROADWELL JOSEPH & CARDOZO, CA 00000, CA 00000 MRW & ASSOCIATES, LLC KAREN TERRANOVA ALCANTAR & KAHL, CA 00000, CA 00000-0000 GREG HEALY NORMAN A. PEDERSEN SOUTHERN CALIFORNIA GAS COMPANY ATTORNEY AT LAW 555 W. FIFTH ST., GT14D6 HANNA AND MORTON LLP LOS ANGELES, CA 90013 444 S. FLOWER STREET, SUITE 1500 LOS ANGELES, CA 90071-2916 FOR: SOUTHERN CALIFORNIA GENERATION COALITION CASE ADMINISTRATION MICHAEL MARELLI SOUTHERN CALIFORNIA EDISON COMPANY SOUTHERN CALIFORNIA EDISON COMPANY LAW DEPT. PO BOX 800 / 2244 WALNUT GROVE AVENUE 2244 WALNUT GROVE AVE., RM 370 ROSEMEAD, CA 91770 ROSEMEAD, CA 91770 ROBERT LEMOINE CARL WOOD SOUTHERN CALIFORNIA EDISON COMPANY AFL-CIO, NATL REGULATORY AFFAIRS DIR. PO BOX 800 / 2244 WALNUT GROVE AVE. UTILITY WORKERS UNION OF AMERICA ROSEMEAD, CA 91770 2021 S. NEVADA ST OCEANSIDE, CA 92054 JOSEPH W. MITCHELL, PHD KEITH W. MELVILLE M-BAR TECHNOLOGIES AND CONSULTING SR. COUNSEL 19412 KIMBALL VALLEY RD. SAN DIEGO GAS & ELECTRIC COMPANY RAMONA, CA 92065 8330 CENTURY PARK CT., CP32 SAN DIEGO, CA 92123 KEITH W. MELVILLE CENTRAL FILES SO CAL GAS CO./ SEMPRA ENERGY SAN DIEGO GAS & ELECTRIC COMPANY 8330 CENTURY PARK CT., CP32 8330 CENTURY PARK CT, CP31-E SAN DIEGO, CA 92123 SAN DIEGO, CA 92123-1530 SHELLY J. SHARP MARTIN HOMEC SR. DIR PO BOX 4471 PACIFIC GAS AND ELECTRIC COMPANY DAVIS, CA 95617 77 BEALE ST., B9A SAN FRANCISCO, CA 94105 MIKE CADE ALCANTAR & KAHL 121 S.W. SALMON STREET, SUITE 1100 PORTLAND, OR 97204 State Service CHRISTINE HAMMOND MICHAEL COLVIN CPUC - LEGAL CPUC - SED, CA 00000, CA 00000 FOR: SED ARTHUR J. O'DONNELL CHARLES H. MAGEE GAS SAFETY AND RELIABILITY BRANCH GAS SAFETY AND RELIABILITY BRANCH

CPUC - Service Lists - A1505002 http://www.cpuc.ca.gov/service_lists/a1505002_83111.htm Page 3 of 3 7/14/2015 AREA ROOM 2106 505 VAN NESS AVENUE 505 VAN NESS AVENUE SAN FRANCISCO, CA 94102-3214 SAN FRANCISCO, CA 94102-3214 CHRISTOPHER PARKES COLETTE KERSTEN GAS SAFETY AND RELIABILITY BRANCH DIVISION OF ADMINISTRATIVE LAW JUDGES AREA 2-D ROOM 5101 505 VAN NESS AVENUE 505 VAN NESS AVENUE SAN FRANCISCO, CA 94102-3214 SAN FRANCISCO, CA 94102-3214 STEVEN K. HAINE GAS SAFETY AND RELIABILITY BRANCH ROOM 2106 505 VAN NESS AVENUE SAN FRANCISCO, CA 94102-3214 TOP OF PAGE BACK TO INDEX OF SERVICE LISTS