2015 General Rate Case

Transcription

1 Application No.: Exhibit No.: Witnesses: SCE-1 J. P. Shotwell (U -E) 01 General Rate Case Testimony Regarding Accessibility Issues Developed Jointly By SCE and Center for Accessible Technology Before the Public Utilities Commission of the State of California Rosemead, California November 01

2 SCE-1: Testimony Regarding Accessibility Issues Developed Jointly By SCE and Center for Accessible Technology Table Of Contents Section Page Witness INTRODUCTION...1 J. P. Shotwell A. Background...1 B. The Structure Of The Proposed Resolution Level Of Spending.... Annual Reporting.... New Coordinator For Accessibility Issues.... Consultation With Interested Parties.... Term And Effectiveness... C. Eligible Activies Under The Proposed Resolution... D. Ratemaking... E. Conclusion... Appendix A Witness Qualifications... -i-

3 INTRODUCTION Southern California Edison Company (SCE) and the Center for Accessible Technology (CforAT) have jointly developed this testimony to outline their proposed resolution to address accessibility issues tied to SCE s role as a public utility and its community of customers with disabilities for the 01 General Rate Case (GRC) cycle. The proposed resolution calls for SCE to spend or incur costs of $1. million on average per year during the 01 GRC cycle to improve accessibility in SCE s customer communications and utility operations. The proposed funding set forth below is intended to be incremental and address accessibility issues detailed below. It would not fund new programs or actions taken in compliance with specific orders arising out of other Commission proceedings. The testimony on the proposed resolution provides: details concerning the relevant background (Section A), structure of the proposed resolution (Section B), a description of eligible accessibility improvements (Section C), a discussion of the ratemaking associated with the proposed resolution (Section D), and a brief conclusion (Section E). A. Background In connection with SCE s 00 and 01 GRCs, SCE and Disability Rights Advocates (DisabRA) entered into two consecutive settlement agreements (collectively, the Prior Settlement Agreements ) to address accessibility issues. 1 The Prior Settlement Agreements covered accessibility issues relating to a number of SCE s activities, including: (1) accessibility at Authorized Payment Agencies (APAs) and the customer service spaces within SCE s rural Service Centers; () accessibility of SCE s website; () accessibility of communications for medical baseline and lifeline customers; () pedestrian access around temporary construction sites; () pedestrian right-of-way issues tied to SCE s utility poles and undergrounding projects; and () accessibility of SCE s bill formats and notices. The Prior Settlement Agreements were adopted by the Commission in the final decisions in SCE s 00 and 01 GRCs. 1 Since the Settlement Agreement in the 01 GRC was reached, lead counsel for DisabRA moved to CforAT, which has taken over DisabRA s former role as the leading intervening party before the California Public Utilities Commission advocating on behalf of customers with disabilities in SCE s service territories. Subsequent to the adoption of the Settlement Agreement in SCE s 01 GRC, DisabRA retained CforAT to serve as its outside counsel in connection with monitoring SCE s compliance with its terms. Notably, CforAT has also intervened on behalf of customers with disabilities in the 01 GRC of San Diego Gas & Electric and Southern California Gas Company and the 01 GRC of Pacific Gas & Electric Company. 1

4 In accordance with the terms of the Prior Settlement Agreements, SCE has (1) remediated all of its rural Service Centers and continues to have an outside consultant periodically assess randomly selected Service Centers to identify any issues, () completed surveys of SCE s APAs and confirmed all are compliant, except where accessibility improvements were unfeasible and exceptions were granted by DisabRA; () made accessibility-related changes to SCE s website in accordance with audits conducted by an outside consultant and remediated third party sites and certain PDF materials; () conducted targeted outreach to medical baseline ( MBL ) customers, identified their preferred modes of communication and implemented systems to contact MBL customers using their preferred modes of communication; () completed surveys of SCE s utility poles and temporary construction sites to address pedestrian right-of-way issues and instituted programs to address accessibility issues in connection with utility poles and temporary construction sites; and () instituted programs to provide enlarged bill formats and, by 01, will offer Braille bill option to customers with vision disabilities upon request. B. The Structure Of The Proposed Resolution SCE and CforAT have discussed issues of common interest regarding accessibility and developed the proposed resolution set forth below. While SCE has made great strides towards improving the accessibility of its customer communications and utility operations, SCE and CforAT feel this proposed resolution represents a significant advancement over the Prior Settlement Agreements in addressing accessibility issues for individuals with disabilities. This proposed resolution is intended to reinforce SCE s commitment to provide safe and reliable electrical service for individuals with disabilities in and around its service territories. 1. Level Of Spending SCE would spend or incur costs of $1. million on average per year during the 01 GRC cycle on activities to improve accessibility (Accessibility Budget). Eligible activities would include those activities set forth in Section D of this chapter.. Annual Reporting SCE would prepare and distribute to CforAT an annual report on its activities and spending to promote accessibility. The annual report would, among other things, address whether SCE s spending has met the level set forth above and to what accessibility-related activities the funds were applied. If SCE s spending has not met the target level, the annual report shall articulate the

5 reasons therefore. The annual report would be due to CforAT by the end of April for the preceding calendar year. The annual report would also be provided to other interested parties upon request.. New Coordinator For Accessibility Issues SCE would hire or designate an employee to serve as a full time Accessibility Coordinator. The Accessibility Coordinator would be responsible for coordinating and shaping Company-wide strategies to improve accessibility and oversee expenditures and accessibility improvements funded by the Accessibility Budget. If SCE were unable to fill the Accessibility Coordinator position, SCE would explain in detail in the annual report to CforAT the efforts that were undertaken toward these objectives. Additionally, if SCE, after gaining a reasonable period of experience with the role of the Accessibility Coordinator, which period shall not be less than one year, concludes that the individual in the position could assume additional responsibilities without impairing the expectations for the position in the accessibility area, SCE may assign such additional responsibilities to such individual after good faith consultation with CforAT. CforAT maintains the establishment of the Accessibility Coordinator position within SCE is an essential aspect of the Proposed Resolution since it designates a specific SCE employee dedicated to addressing accessibility issues for SCE and monitoring accessibility improvements by SCE.. Consultation With Interested Parties Prior to the start of each calendar year, SCE would meet with CforAT, and any other interested parties, to discuss planned accessibility spending for the upcoming calendar year. Such meetings would typically take place during the fourth quarter of each calendar year. The first such meeting would take place during the fourth quarter of 01 or within three months of a final decision in SCE s 01 GRC, whichever occurs later.. Term And Effectiveness The commitments in this proposed resolution would apply only to the 01 GRC cycle and would only become enforceable upon the Commission s issuance of a final decision in SCE s 01 GRC that specifically approves and funds the provisions of this proposed resolution. In the event of a material delay in the Commission s issuance of a final decision in SCE s 01 GRC or the Commission s failure to approve this proposed resolution unconditionally and without modification, the parties shall meet and confer to discuss modifications to the proposed resolution, including, without limitation, reasonable extensions of deadlines and revisions to address Commission-ordered changes.

6 C. Eligible Activities Under The Proposed Resolution The following types of costs associated with accessibility improvements would be eligible for accounting toward the target spending level of $1. million on average per year. Accessibility Coordinator and Related Work Costs associated with the Accessibility Coordinator, including compensation (base salary and incentives) and benefits (health insurance, 01(K), etc.) Costs associated with the preparation of the annual report and consultation with CforAT and any other interested parties. Rural Service Centers Costs associated with follow-up inspections at rural service centers to identify existing or emergent accessibility issues. Costs associated with ongoing training for local office personnel in improving accessibility (including preparation and publication of training materials.) Authorized Payment Agencies Costs associated with monitoring accessibility issues at APAs, including internal audits. Costs associated with identifying new accessible APA locations. Costs associated with the ongoing publication of accessible APA locations at SCE s website. Temporary Construction Sites Costs associated with ongoing training of SCE personnel and contractors regarding accessibility issues and compliance with SCE s Pedestrian Traffic Control Manual. Costs of accessibility-related equipment acquisition/maintenance/replacement for use at temporary construction sites. Costs associated with the continued monitoring of compliance with SCE s Pedestrian Traffic Control Manual, including internal audits. Costs for further investigation of the feasibility of audible alert devices at SCE construction sites. Utility Poles Costs for continued coordination with local governments regarding accessibility issues arising out of the placement of utility poles and undergrounding projects.

7 Communications Issues Costs associated with maintaining TTY and Telecommunications Relay Systems and training of customer service personnel at SCE s call centers. Costs associated with maintaining accessibility of SCE.com and other SCE-controlled customer-facing websites, including the following: o Continued remediation of documents in PDF form made available to SCE customers; o Addressing any newly identified web accessibility issues at customer-facing websites; and o Ongoing training and review of accessibility issues for SCE personnel who work on SCE s customer-facing websites. Costs associated with the ongoing efforts to provide key information in large print on outgoing customer communications. Costs to expand the provision of alternative formats for customer information. Costs associated with the expansion of efforts around outreach/education regarding customer accessibility issues. Costs for continued training of customer service personnel on communications issues. Costs associated with the identification of customers with disabilities and use of preferred formats. D. Ratemaking The Accessibility Budget ($1. million) has been included in the revenue requirement calculation through a high-level adjustment in SCE s Results of Operations (RO) Model. Specifically, the Accessibility Budget has been entered as an expense item in the Accessibility Budget line in the O&M section of the RO model. The amount is not included in the totals presented in the Safety, Security and Compliance (SS&C) exhibit. The forecast has been included as a high-level adjustment in the RO Model because several possible areas of activity in the proposed resolution extend beyond the purview of the SS&C exhibit, such as the work on website accessibility, utility pole placement and temporary construction site practices. To track the level of spending, SCE will create one or more internal orders specific to the work undertaken under the joint proposal. This will enable clear tracking and reporting of SCE s spending toward the target.

8 E. Conclusion SCE is pleased to present this joint proposal with CforAT and respectfully request the Commission s adoption of this joint proposal in its entirety. CforAT has informed SCE that it expressly supports the Commission s adoption of this joint proposal. Both parties believe that this proposed resolution is a significant advancement over the Prior Settlement Agreements in addressing accessibility issues for individuals with disabilities. This proposed resolution increases the scope of activities to be undertaken and takes important steps to institutionalize these improvements within SCE via SCE s establishment of the Accessibility Coordinator position within its Company. For these reasons and those described elsewhere in this chapter, SCE and CforAT jointly recommend the Commission s adoption of this proposed resolution. SCE acknowledges CforAT can, and may, raise accessibility issues in other Commission proceedings or venues of CforAT s choosing outside of SCE s 01 GRC proceeding.

9 Appendix A Witness Qualification

10 SOUTHERN CALIFORNIA EDISON COMPANY QUALIFICATIONS AND PREPARED TESTIMONY OF JAMES P. SCOTT SHOTWELL Q. Please state your name and business address for the record. A. My name is James P. Scott Shotwell, and my business address is Walnut Grove Avenue, Rosemead, California 10. Q. Briefly describe your present responsibilities at the Southern California Edison Company. A. I am the Director and Deputy Ethics & Compliance Officer. I am responsible for the implementation and operation of the Company s Compliance Management Program, along with the Records Management, Policy Management, and Privacy Compliance Programs. Q. Briefly describe your educational and professional background. A. I hold a Bachelor of Science (B.S.) degree in Economics from Arizona State University and a Juris Doctorate from the University of Arizona College of Law. I have worked for Southern California Edison for over years. Prior to accepting my current position in 00, I worked in Southern California Edison s Washington, D.C. office, where I served as the primary liaison between SCE and the Federal Energy Regulatory Commission. Previously, I was a Senior Attorney with the Company, practicing chiefly before the California Public Utilities Commission. Q. What is the purpose of your testimony in this proceeding? A. The purpose of my testimony in this proceeding is to sponsor Exhibit SCE-1, entitled Testimony Regarding Accessibility Issues Developed Jointly by SCE and Center for Accessible Technology, as identified in the Table of Contents thereto. Q. Was this material prepared by you or under your supervision? A. Yes, it was. Q. Insofar as this material is factual in nature, do you believe it to be correct? A. Yes, I do. A-1

11 Q. Insofar as this material is in the nature of opinion or judgment, does it represent your best judgment? A. Yes, it does. Q. Does this conclude your qualifications and prepared testimony? A. Yes, it does. A-