BEFORE THE PUBLIC UTILITIES COMMISSION OF …

1 BEFORE THE PUBLIC UTILITIES COMMISSION OF THE STATE OF CALIFORNIA Application of San Diego Gas & electric company (U902M) for Approval to Extend the Mobilehome Park Utility Upgrade Program. (Filed May 5, 2017) SOUTHERN CALIFORNIA EDISON company S (U 338-E) PREHEARING CONFERENCE STATEMENT FADIA RAFEEDIE KHOURY Attorneys for SOUTHERN CALIFORNIA EDISON company 2244 Walnut Grove Avenue Post Office Box 800 Rosemead, California 91770 Telephone: (626) 302-6008 Facsimile: (626) 302-3990 E-mail.

2 July 17, 2017 1 BEFORE THE PUBLIC UTILITIES COMMISSION OF THE STATE OF CALIFORNIA Application of San Diego Gas & electric company (U902M) for Approval to Extend the Mobilehome Park Utility Upgrade Program. (Filed May 5, 2017) SOUTHERN CALIFORNIA EDISON company S (U 338-E) PREHEARING CONFERENCE STATEMENT I. INTRODUCTION Pursuant to Rule of the California PUBLIC UTILITIES COMMISSION s ( COMMISSION ) Rules of Practice and Procedure, and in accordance with the June 23, 2017 Administrative Law Judge s ( ALJ s ) Ruling Setting Prehearing Conference ( PHC ) and Requesting PHC Statements ( Ruling ), Southern California Edison company ( SCE ) respectfully submits its PHC Statement in connection with Application 17-05-008 ( Application ).

3 In the Application, San Diego Gas & electric company ( SDG&E ) seeks to expand and make changes to its Mobilehome Park Utility Upgrade Program ( Program ) initially authorized in Decision (D.) 14-03-021, issued on March 14, 2014 ( Decision ). This Statement addresses the following issues: A. Responses to ALJ s Questions in the Ruling; B. Procedural schedule; C. Scope of issues to be included in (or excluded from) the proceeding; D. Need for evidentiary hearings; E. Appropriate category for this proceeding; and F.

4 Discovery issues. 2 II. DISCUSSION A. Response to ALJ s Questions in the Ruling In the Ruling, the ALJ requested PHC Statements from the parties on two specific questions. 1. Is it appropriate for the COMMISSION to consider expansion of the Program through the applications of two utility Program participants, or should the COMMISSION address this issue through a broader rulemaking process? SCE has become a party to this proceeding to monitor the questions raised and to preserve SCE s interest because SCE also administers the Program in its service territory.

5 While SCE believes that at least some of the Program changes proposed in the Application may be advisable in the long term, SCE has elected to continue its Program without major modifications, as permitted by the Decision, until the end of the pilot Although SCE intends to continue its Program without significant changes during the pilot period, SCE does not object to SDG&E s request to make Program changes now, as long as SCE s interests are not negatively affected. Thus, SCE does not take a position at present regarding whether it is appropriate to consider modifications of SDG&E s Program in the context of a more narrowly-applicable application, rather than through a rulemaking.

6 However, any changes to the Program approved through this application should apply only to SDG&E, unless and until other parties request the same changes to their respective programs or until such program features are adopted through a generally-applicable rulemaking. 1 See Decision, at Ordering Paragraph (OP) 13; see also SCE s Advice 3576-E, Continuation of the Mobilehome Park Utility Upgrade Program Pursuant to Decision 14-03-021. 3 2. Is it appropriate to address Program expansion through a Tier 2 advice letter, or should the advice letter process be used solely to address extension of the existing program and goals?

7 As noted above, the Decision clearly permits the Program to be extended without major modification via a Tier 2 advice letter. SCE, and several other UTILITIES , have filed Tier 2 advice letters in compliance with the Decision to extend existing Programs. However, the Decision also suggests that any recommendations for significant revisions to the Program be decided in a manner other than through a Tier 2 advice letter, such as through an application or B. Procedural Schedule While SCE does not take a specific position on the procedural schedule, SCE does object to SDG&E s proposed procedural schedule as filed.

8 The prehearing conference will take place on July 25, 2017, rather than June 26, 2017, the date proposed in the Application. Accordingly, SCE respectfully recommends that all of the proposed due dates in the Application be pushed back at least 30 days. C. Scope of Issues to be Included in (or Excluded from) the Proceeding In addition to the issues raised by the ALJ and addressed above, the scope of issues to be included in this proceeding are set forth in SDG&E s Should SCE identify issues that would affect its program, it will serve testimony to preserve its rights.

9 D. Need for Evidentiary Hearings The need for evidentiary hearings in this proceeding, and the issues to be considered in such hearings, depends in large part on the issues ultimately included in the scope of the proceeding. If the COMMISSION determines that it will consider making major modifications to 2 See Decision, Finding of Fact 41, at p. 71. 3 Application, at p. 6. 4 the Program, the parties may need evidentiary hearings. The need for hearings will ultimately be determined by the assigned Administrative Law Judge.

10 E. Appropriate Category for this Proceeding The appropriate category for this proceeding is ratesetting. F. Discovery Issues SCE has no position on discovery issues at this time. G. List and description of other matters the parties wish to address at the PHC SCE has no other matters to list. III. CONCLUSION SCE appreciates the opportunity to submit this PHC statement. Respectfully submitted, FADIA RAFEEDIE KHOURY /s/ Fadia Rafeedie Khoury By: Fadia Rafeedie Khoury Attorneys for SOUTHERN CALIFORNIA EDISON company 2244 Walnut Grove Avenue Post Office Box 800 Rosemead, California 91770 Telephone: (626) 302-6008 Facsimile: (626) 302-3990 E-mail.