BEFORE THE PUBLIC UTILITIES COMMISSION OF THE STATE OF CALIFORNIA

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1 BEFORE THE PUBLIC UTILITIES COMMISSION OF THE STATE OF CALIFORNIA Order Instituting Rulemaking to Implement Electric Utility Wildfire Mitigation Plans Pursuant to Senate Bill 901 (2018). R (Filed October 25, 2018) JOINT COMMENTS OF SOUTHERN CALIFORNIA EDISON COMPANY (U 338-E), PACIFIC GAS AND ELECTRIC COMPANY (U 39-E) AND SAN DIEGO GAS & ELECTRIC COMPANY (U 902-E) ON THE OCTOBER 25, 2018 ORDER INSTITUTING RULEMAKING TO IMPLEMENT ELECTRIC UTILITY WILDFIRE MITIGATION PLANS PURSUANT TO SENATE BILL 901 (2018) FADIA RAFEEDIE KHOURY RUSSELL A. ARCHER MARGARITA GEVONDYAN Southern California Edison Company 2244 Walnut Grove Avenue Post Office Box 800 Rosemead, CA Telephone: (626) Facsimile: (626) Attorneys for SOUTHERN CALIFORNIA EDISON COMPANY LISE JORDAN ALYSSA KOO Pacific Gas and Electric Company 77 Beale Street, B30A San Francisco, CA Telephone: (415) Facsimile: (415) Attorneys for PACIFIC GAS AND ELECTRIC COMPANY KEITH MELVILLE San Diego Gas & Electric Company 8330 Century Park Court, #CP32D San Diego, CA Telephone: (858) Fax: (619) Attorney for SAN DIEGO GAS & ELECTRIC COMPANY Dated: November 5, 2018

2 BEFORE THE PUBLIC UTILITIES COMMISSION OF THE STATE OF CALIFORNIA Order Instituting Rulemaking to Implement Electric Utility Wildfire Mitigation Plans Pursuant to Senate Bill 901 (2018). R (Filed October 25, 2018) JOINT COMMENTS OF SOUTHERN CALIFORNIA EDISON COMPANY (U 338-E), PACIFIC GAS AND ELECTRIC COMPANY (U 39-E) AND SAN DIEGO GAS & ELECTRIC COMPANY (U 902-E) ON THE OCTOBER 25, 2018 ORDER INSTITUTING RULEMAKING TO IMPLEMENT ELECTRIC UTILITY WILDFIRE MITIGATION PLANS PURSUANT TO SENATE BILL 901 (2018) In accordance with Rule 6.2 of the Rules of Practice and Procedure of the California Public Utilities Commission (CPUC or Commission) and Ordering Paragraph 9 of the Order Instituting Rulemaking (OIR) issued on October 25, 2018 in the above-captioned proceeding, Southern California Edison Company (SCE), Pacific Gas and Electric Company (PG&E) and San Diego Gas & Electric Company (SDG&E) (collectively, the Joint Utilities) 1 hereby submit the following comments addressing, among other items, the Commission s proposed scope and schedule for this proceeding. I. INTRODUCTION The Joint Utilities commend the Commission for acting to expeditiously implement the provisions of Senate Bill (SB) related to electric utility wildfire mitigation plans (Wildfire 1 Pursuant to Commission Rules of Practice and Procedure 1.8(d), counsel for PG&E and SDG&E have authorized counsel for SCE to file these comments on behalf of all three Joint Utilities. 2 Stats. 2018, Ch

3 Mitigation Plans). California s wildfires have grown larger and more intense over the last several decades 3 due to climate change, historic state-wide drought conditions, the growing wildlandurban interface, the significant buildup of fuel on federal and state forest lands, and other factors. Fire prevention and mitigation have been an integral part of the Joint Utilities operational practices for many years, and each utility has several programs already in place that directly manage and reduce wildfire risk. Additionally, the Commission has historically taken steps to reduce and manage this risk by, for example, adopting rules and standards to improve electric utility emergency preparedness and reduce fire hazards associated with electric utility infrastructure. While all of these efforts have assisted in reducing fire hazards associated with electric utility infrastructure, the Joint Utilities agree with Governor Brown, California Department of Forestry and Fire Protection (CalFire) officials, and others that more is required, including even greater investments in wildfire-related safety enhancements. Accordingly, the Joint Utilities support this OIR and look forward to submitting their responsive Wildfire Mitigation Plans consistent with the requirements of Public Utilities Code (PUC) Section 8386 pursuant to the schedule the assigned Commissioner and Administrative Law Judge (ALJ) ultimately adopt in this proceeding. A. The Proposed Scope and Schedule Are Both Appropriate And Necessary To Enable The Commission To Approve The Electric Utilities Wildfire Mitigation Plans As Close To The Beginning Of Summer 2019 As Possible. The Joint Utilities support the proposed schedule set forth in the OIR (at p. 7) and agree with the OIR (at p. 4) that the scope of this proceeding should be limited to the required Wildfire Mitigation Plan elements provided in PUC Section 8386, as modified by SB Limiting the scope of this OIR to the required Wildfire Mitigation Plan elements will provide the Commission 3 OIR at p PUC Section 8386(c), for example, sets forth the requirements to be included in the Wildfire Mitigation Plans, which covers a wide range of areas such as risk, preventive strategies and programs, emergency preparedness and response, customer support in emergencies, and metrics and monitoring. Following the submission of the Wildfire Mitigation Plans, PUC Section 8386(d) allows interested parties to submit comments on the Wildfire Mitigation Plans. 2

4 the greatest assurance that electric utilities Wildfire Mitigation Plans can be approved and in place as close to the beginning of summer 2019 as possible. The Commission has also preliminarily identified the categorization of this proceeding as ratesetting, that no hearings are needed, and that there may be a potential need for workshops and public meetings. 5 The Joint Utilities support these preliminary determinations supplemented by the recommendations discussed below. While reasonableness review of the Joint Parties costs to implement the Wildfire Mitigation Plans is not in scope in this proceeding, the Joint Utilities need to track and ultimately seek recovery of their reasonable wildfire mitigation costs that are incurred prior to the utilities next General Rate Cases (GRCs). 6 Pursuant to SB 901, the tracking may occur in the memorandum accounts listed in PUC Sections 8386(e) and (j). Unique to SCE, its Grid Safety and Resiliency Program (GS&RP) Application contains many elements that will form the basis of its Wildfire Mitigation Plan; therefore, SCE urges the Commission to act promptly on its memorandum account request in that proceeding, and that its request not be delayed by consideration of the Wildfire Mitigation Plans. Given the expansive requirements in SB 901 and the broad circulation of this OIR, 7 it is highly likely that various local and state agencies, groups and organizations will participate and become parties. The Joint Utilities fully support engagement of local and state stakeholders in this essential proceeding and look forward to their participation. However, should parties recommend changes to the proposed schedule and/or limited scope, the Commission should ensure the final adopted scope and schedule meet the requirements of SB 901. Additionally, should the Commission schedule workshops and/or public meetings, the Joint Utilities recommend that they be conducted after the utilities submit their respective Wildfire Mitigation Plans. 5 OIR at p Here, the anticipated costs related to the implementation of the Wildfire Mitigation Plans are not yet recoverable in a GRC, may be substantial, and are not speculative. See D at p. 7 (approving PG&E s request to establish a Wildfire Expense Memorandum Account). 7 OIR at pp

5 B. There Are Several Proceedings That Overlap With The Adoption of Wildfire Mitigation Plans Ordering Paragraph 9 of the OIR requests that comments address this proceeding s interaction with other related proceedings. There are several proceedings before the Commission that overlap with wildfire prevention and mitigation. Public Utilities Code Section 8386(c)(10) requires the Joint Utilities to include in their Wildfire Mitigation Plans the risk information contained in the Safety Model Assessment Proceeding (S-MAP) and Risk Assessment Mitigation Phase (RAMP) proceedings. In addition, Section (c)(16) of Public Utilities Code Section 8386 (effective January 1, 2019) will require the Joint Utilities to describe how their Wildfire Mitigation Plans are consistent with the electrical corporation s disaster and emergency preparedness plans prepared pursuant to PU Code Section Furthermore, the statute s requirements for the Wildfire Mitigation Plans include information already contained in the utilities Fire Prevention Plans currently required by General Order (GO) 166. Given that the PUC Section 8386 Wildfire Mitigation Plans require the inclusion of information that is also contained in the GO 166 Fire Prevention Plans, the Joint Utilities request that the Commission consider reducing and/or eliminating such requirements to provide redundant or duplicate information. In other words, if there is an existing requirement pursuant to other Commission decisions and orders to provide information that will be a part of the Wildfire Mitigation Plans, the Commission should address the redundancy by subsuming the redundant or duplicate requirement into the Wildfire Mitigation Plans. The Joint Utilities will address these and any other related proceedings in their Wildfire Mitigation Plan submissions. II. CONCLUSION The Joint Utilities support the Commission s issuance of this OIR and its goal of approving electric utilities Wildfire Mitigation Plans as close to the beginning of summer 2019 as possible. To ensure the Commission meets its goal, the Joint Utilities respectfully request that 4

6 the Commission limit the scope of issues to the statutory requirements of PUC Section 8386, as modified by SB 901, related to the Wildfire Mitigation Plans, and maintain the proposed schedule, with any additional steps to be completed after the Wildfire Mitigation Plans are submitted. Respectfully submitted on behalf of the Joint Utilities, FADIA RAFEEDIE KHOURY RUSSELL A. ARCHER MARGARITA GEVONDYAN /s/ Margarita Gevondyan By: Margarita Gevondyan Attorneys for SOUTHERN CALIFORNIA EDISON COMPANY 2244 Walnut Grove Avenue Post Office Box 800 Rosemead, California Telephone: (626) Facsimile: (626) November 5,

7 BEFORE THE PUBLIC UTILITIES COMMISSION OF THE STATE OF CALIFORNIA Order Instituting Rulemaking to Implement Electric Utility Wildfire Mitigation Plans Pursuant to Senate Bill 901 (2018). R (Filed October 25, 2018) 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 the JOINT COMMENTS OF SOUTHERN CALIFORNIA EDISON COMPANY (U 338-E), PACIFIC GAS AND ELECTRIC COMPANY (U 39-E) AND SAN DIEGO GAS & ELECTRIC COMPANY (U 902-E) ON THE OCTOBER 25, 2018 ORDER INSTITUTING RULEMAKING TO IMPLEMENT ELECTRIC UTILITY WILDFIRE MITIGATION PLANS PURSUANT TO SENATE BILL 901 (2018), on all parties identified on the attached service list for R Service was effected by one or more means indicated below: Transmitting the copies via to all parties who have provided an address. Placing the copies in sealed envelopes and causing such envelopes to be delivered by U.S. Mail to the offices of the Commissioner(s) or other addressee(s). ALJ Sarah R. Thomas CPUC- Division of ALJs 505 Van Ness Ave., Room 5033 San Francisco, CA ALJ Peter V. Allen CPUC- Division of ALJs 505 Van Ness Ave., Room 5017 San Francisco, CA Executed on November 5, 2018, at Rosemead, California. /s/ Angelica Gamboa Angelica Gamboa, Legal Administrative Assistant SOUTHERN CALIFORNIA EDISON COMPANY 2244 Walnut Grove Avenue Post Office Box 800 Rosemead, California 91770

8 CPUC - Service Lists - R Page 1 of 4 11/5/2018 CPUC Home CALIFORNIA PUBLIC UTILITIES COMMISSION Service Lists PROCEEDING: R OIR WILDLIFE MITIGAT FILER: CPUC LIST NAME: LIST LAST CHANGED: NOVEMBER 5, 2018 Download the Comma-delimited File About Comma-delimited Files Back to Service Lists Index Parties RUSSELL G. WORDEN KEITH SWITZER DIR - REGULATORY OPERS. BEAR VALLEY ELECTRIC SERVICE SOUTHERN CALIFORNIA EDISON COMPANY 630 EAST FOOTHILL BLVD RUSH STREET / PO BOX 800 SAN DIMAS, CA ROSEMEAD, CA FOR: BEAR VALLEY ELECTRIC SERVICE, DIV FOR: SOUTHERN CALIFORNIA EDISON COMPANY OF GOLDEN STATE WATER COMPANY KIRSTIE C. RAAGAS ERIK B. JACOBSON REGULATORY COUNSEL REGULATORY RELATIONS SAN DIEGO GAS & ELECTRIC COMPANY PACIFIC GAS AND ELECTRIC COMPANY 8330 CENTURY PARK COURT, CP32F 77 BEALE ST., MC B23A SAN DIEGO, CA SAN FRANCISCO, CA FOR: SAN DIEGO GAS & ELECTRIC COMPANY FOR: PACIFIC GAS AND ELECTRIC COMPANY DANIEL MARSH CYNTHIA HANSEN MIFSUD MGR - RATES & REGULATORY AFFAIRS ASSIST. GEN. COUNSEL LIBERTY UTILITIES (CALPECO ELECTRIC) LLC PACIFICORP 933 ELOISE AVENUE 825 NE MULTNOMAH ST., STE SOUTH LAKE TAHOE, CA PORTLAND, OR FOR: LIBERTY UTILITIES (CALPECOELECTRIC) FOR: PACIFIC POWER, A DIV OF PACIFICORP Information Only JESSIE CROZIER JOAN WEBER LUMINUS MANAGEMENT 1700 BROADWAY, 26TH FL. OFFICE OF THE SAFETY ADVOCATE NEW YORK, NY West 4th Street Suite 500

9 CPUC - Service Lists - R Page 2 of 4 11/5/2018 Los Angeles, CA HANS LAETZ JANE TERJUNG GENERAL MGR. TOPANGA COMMUNITY ALLIANCE ZUMA BEACH FM BROADCASTERS 1639 OAK DRIVE RADIO MALIBU 99.1 FM KBUU TOPANGA, CA SURFSIDE WAY MALIBU, CA FRED G. YANNEY CASE ADMINISTRATION ATTORNEY SOUTHERN CALIFORNIA EDISON COMPANY YANNEY LAW OFFICE 8631 RUSH STREET MARQUARDT AVE. UNIT C-4 ROSEMEAD, CA CERRITOS, CA MARGARITA GEVONDYAN RYAN STEVENSON SR. ATTORNEY PRINCIPAL ADVISOR / REG - POLICY SOUTHERN CALIFORNIA EDISON COMPANY SOUTHERN CALIFORNIA EDISON COMPANY 2244 WALNUT GROVE AVE / PO BOX RUSH ST., GEN. OFFICE 4 ROSEMEAD, CA ROSEMEAD, CA DIANE CONKLIN JOSEPH W. MITCHELL, PH.D SPOKESPERSON M-BAR TECHNOLOGIES AND CONSULTING, LLC MUSSEY GRADE ROAD ALLIANCE KIMBALL VALLEY RD. PO BOX 683 RAMONA, CA RAMONA, CA CHUCK MANZUK JAMIE K. YORK DIR - GRC & REVENUE REQUIREMENTS GRC PROGRAM MGR. SAN DIEGO GAS & ELECTRIC COMPANY SAN DIEGO GAS & ELECTRIC COMPANY 8330 CENTURY PARK COURT 8330 CENTURY PARK COURT, CP32D SAN DIEGO, CA SAN DIEGO, CA KEITH MELVILLE ERIC CARDELLA SR. COUNSEL SUPERVISOR, ENGINEERING & PLANNING SAN DIEGO GAS & ELECTIRIC COMPANY BEAR VALLEY ELECTRIC SERVICE 8330 CENTURY PARK CT., CP-32D GARSTIN DRIVE / PO BOX 1547 SAN DIEGO, CA BIG BEAR LAKE, CA PAUL MARCONI MILES MAURINO DIRECTOR ADAMS BROADWELL JOSEPH & CARDOZO BEAR VALLEY ELECTRIC SERVICE 601 GATEWAY BLVD., STE GRASTIN DRIVE / PO BOX 1547 SOUTH SAN FRANCISCO, CA BIG BEAR LAKE, CA CHRISTOPHER PARKES FRANZ CHENG OFFICE OF THE SAFETY ADVOCATE MARKET STRUCTURE, COSTS AND NATURAL GAS AREA 2-D AREA 4-A 505 VAN NESS AVENUE 505 VAN NESS AVENUE SAN FRANCISCO, CA SAN FRANCISCO, CA JULIA ENDE PETER V. ALLEN

10 CPUC - Service Lists - R Page 3 of 4 11/5/2018 MARKET STRUCTURE, COSTS AND NATURAL GAS DIVISION OF ADMINISTRATIVE LAW JUDGES ROOM 4011 ROOM VAN NESS AVENUE 505 VAN NESS AVENUE SAN FRANCISCO, CA SAN FRANCISCO, CA SARAH R. THOMAS SEAN A. SIMON DIVISION OF ADMINISTRATIVE LAW JUDGES COMMISSIONER RECHTSCHAFFEN ROOM 5033 AREA 4-A 505 VAN NESS AVENUE 505 VAN NESS AVENUE SAN FRANCISCO, CA SAN FRANCISCO, CA WILLIAM K. SANDERS KATY MORSONY DEPUTY CITY ATTORNEY STAFF ATTORNEY CITY AND COUNTY OF SAN FRANCISCO THE UTILITY REFORM NETWORK (TURN) CITY HALL RM MARKET STREET, SUITE DR. CARLTON B. GOODLETT PLACE SAN FRANCISCO, CA SAN FRANCISCO, CA FOR: CITY AND COUNTY OF SAN FRANCISCO THOMAS LONG IVAN R. JIMENEZ LEGAL DIRECTOR REGULATORY ATTORNEY THE UTILITY REFORM NETWORK SMALL BUSINESS UTILITY ADVOCATES 785 MARKET ST., STE MARKET STREET, STE SAN FRANCISCO, CA SAN FRANCISCO, CA DAVID J. MILLER MICHELLE CHOO AVP - SR. LEGAL COUNSEL ASSISTANT AT&T SERVICES, INC. AT&T SERVICES, INC. 430 BUSH STREET, ROOM BUSH STREET, 3ND FL. SAN FRANCISCO, CA SAN FRANCISCO, CA FOR: AT&T JIM TOMLINSON MEGAN SOMOGYI DAVIS WRIGHT TREMAINE LLP ATTORNEY 505 MONTGOMERY STREET, SUITE 800 GOODIN, MACBRIDE, SQUERI, & DAY, LLP SAN FRANCISCO, CA SANSOME ST., STE. 900 SAN FRANCISCO, CA DAVIS WRIGHT TREMAINE LLP SUZANNE TOLLER 505 MONTGOMERY STREET, STE. 800 DAVIS WRIGHT TREMAINE LLP SAN FRANCISCO, CA MONTGOMERY STREET, SUITE 800 SAN FRANCISCO, CA MAVIS SCANLON CASE COORDINATION EDITOR PACIFIC GAS AND ELECTRIC COMPANY CALIFORNIA ENERGY MARKETS PO BOX ; MC B23A 425 DIVISADERO ST., STE 303 SAN FRANCISCO, CA SAN FRANCISCO, CA RACHEL JONES SAJI THOMAS PIERCE EAST BAY MUNICIPAL UTILITY DISTRICT EAST BAY MUNICIPAL UTILITY DISTRICT 375 ELEVENTH STREET TH STREET

11 CPUC - Service Lists - R Page 4 of 4 11/5/2018 OAKLAND, CA OAKLAND, CA GREGG MORRIS PAUL SCHULMAN DIRECTOR SR RESEARCH FELLOW THE GREEN POWER INSTITUTE CTR FOR CATASTROPHIC RISK MGNT 2039 SHATTUCK AVE., SUTE. 402 MILLS COLLEGE BERKELEY, CA UNIVERSITY OF CALIFORNIA BERKELEY, CA AMY WARSHAUER AUDRA HARTMANN MGR - GOV'T & EXTERNAL AFFAIRS PRINCIPAL FRONTIER COMMUNICATIONS SMITH, WATTS & HARTMANN 1201 K STREET, SUITE L STREET, SUITE 220 SACRAMENTO, CA SACRAMENTO, CA CHARLIE BORN NICK CRONENWETT FRONTIER COMMUNICATIONS LEGISLATIVE ANALYST 1201 K STREET, STE CALIFORNIA STATE ASSOC. OF COUNTIES SACRAMENTO, CA K STREET, STE 101 SACRAMENTO, CA STACI HEATON LYNN HAUG REGULATORY AFFAIRS ADVOCATE ATTORNEY REGIONAL COUNCIL OF RURAL COUNTIES ELLISON SCHNEIDER HARRIS & DONLAN LLP 1215 K ST., STE CAPITOL AVE., STE. 400 SACRAMENTO, CA SACRAMENTO, CA JOY MASTACHE KAREN NOREEN MILLS SR. ATTORNEY - OFF. OF GEN. COUNSEL SR. ATTORNEY SACRAMENTO MUNICIPAL UTILITY DISTRICT CALIFORNIA FARM BUREAU FEDERATION 6301 S STREET, MS A RIVER PLAZA DRIVE SACRAMENTO, CA SACRAMENTO, CA SARBJIT BAGRI CATHIE ALLEN DIRECTOR, REGULATORY AFFAIRS OFFICE OF THE SAFETY ADVOCATE PACIFICORP 180 Promenade Circle, Suite N. E. MULTNOMAH, SUITE 300 Sacramento, CA PORTLAND, OR HEIDEMARIE CASWELL PACIFICORP 825 NE MULTNOMAH, STE PORTLAND, OR TOP OF PAGE BACK TO INDEX OF SERVICE LISTS

BEFORE THE PUBLIC UTILITIES COMMISSION OF THE STATE OF CALIFORNIA SOUTHERN CALIFORNIA EDISON COMPANY'S (U 338-E) NOTICE OF COMMUNICATION

BEFORE THE PUBLIC UTILITIES COMMISSION OF THE STATE OF CALIFORNIA Order Instituting Investigation into the November 2018 Submission of Southern California Edison Risk Assessment and Mitigation Phase. I.18-11-006