:runsdshuv · 2019. 8. 30. · 6 refer to wp sce-02, vol. 01, pt. 2, pp. 4-9 – memo of...

(U 338-E)

2021 General Rate Case A.19-08-

Workpapers

Distribution Grid SCE-02 Volume 01, Part 02

August 2019

Workpaper – Southern California Edison / 2021 General Rate Case

Exhibit No. SCE-02 Vol.01 Pt. 02 Witnesses: T. Ohanian

1

I. 1

INTRODUCTION 2

A. Content and Organization of Distribution Inspections & Maintenance and Capital-Related 3

Testimony 4

This testimony includes analyses for the Distribution Inspections & Maintenance Business 5

Planning Element (BPE) of: (1) O&M and capital funding authorized in the 2018 General Rate Case 6

(GRC) compared to recorded amounts in 2018; (2) the 2021 O&M test year forecast; and (3) the 2019 – 7

2023 capital expenditures forecast. This testimony also includes a section to describe SCE’s Safety and 8

Reliability Investment Incentive Mechanism (SRIIM). Certain of these forecasts will be updated 9

pursuant to the discussion in Chapter IV.A in the Application. 10

B. Summary of O&M and Capital Request 11

SCE forecasts $161.284 million in O&M expenses and $509.932 million in capital expenditures 12

in test year 2021 for Distribution Inspections & Maintenance and Capital-Related expense activities. 13

Included in those totals are forecasts for SCE’s Streetlight Operations, Inspections and Maintenance 14

program. 15

SCE’s total request for the Distribution Grid BPG is presented in Figure I-1 and Figure I-2 16

below. 17

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2

Figure I-1 Distribution Grid Part 2 O&M Expenses 2021 Forecast

(Total Company Constant 2018 $Million)

2



3

Figure I-2 Distribution Grid Part 2 Capital Expenditures 2019-2023

(Total Company -Nominal $Million)

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4

II. 1

INSPECTIONS & MAINTENANCE 2

In this chapter, SCE discusses its Inspections & Maintenance Business Planning Element, an 3

element within SCE’s Distribution Grid Business Planning Group. The inspections and maintenance 4

activities discussed in this chapter are performed on SCE’s distribution lines and equipment located 5

outside of a substation. Maintenance work includes both expense repairs and capital replacements 6

performed on the distribution grid. The most common types of distribution electrical equipment include 7

transformers, switches, cable, and conductor which typically operate at line voltages of 4kV, 12kV, 8

16kV and less frequently at 33kV. SCE also discusses the streetlight inspection and maintenance 9

program including the Light Emitting Diode (LED) upgrade program. 10

A. Overview 11

The majority of planned work discussed in this chapter is performed to satisfy maintenance and 12

inspection requirements placed upon SCE by the California Public Utilities Commission (CPUC) and 13

various city and county agencies. 14

The electrical equipment and structures in SCE’s distribution grid undergo planned and 15

unplanned inspections and maintenance. Required maintenance is identified through the following 16

sources: 17

Scheduled inspections driven by specific regulatory requirements; 18

Field inspections by personnel while performing other work; 19

Inspections performed after emergencies or in-service failures of equipment; and 20

Initiation of new or changes in existing programs.1 21

These inspections drive three categories of maintenance: 1) repairs made by inspectors, 2) repairs 22

made by line crews; and 3) replacements made by line crews. 23

In addition to inspection and maintenance activities, this chapter also includes the costs to 24

support the following distribution construction and maintenance activities: patrolling and locating 25

trouble on the distribution system; inspecting, maintaining, and replacing streetlight fixtures and lights; 26

conversion of existing streetlights to LED technology; and repairing third party damages to the 27

distribution grid. 28

1 An example includes a change to General Order (GO) 95 which requires Priority 3 items to be scheduled and

completed where previously they were repaired only in conjunction with other work on the same structure.

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5

This chapter will begin with a description of the risk, safety, and reliability factors impacted by 1

Inspections & Maintenance; the regulatory and policy drivers of the work; regulatory compliance 2

requirements; and a comparison of 2018 GRC request, authorized, and recorded for activities included in 3

this chapter. Next, this chapter will present SCE’s Inspection & Maintenance O&M request followed by 4

SCE’s capital request. 5

1. Risk Factors, Safety, Reliability and Connection with Risk Assessment Mitigation 6

Phase (RAMP) 7

SCE’s Underground Detailed Inspections (UDI) and Underground Preventive 8

Maintenance, as well as the Overhead Detailed Inspections (ODI), Apparatus Inspections, and 9

Preventive Maintenance and Distribution Apparatus Maintenance are activities included in SCE’s 10

Distribution Inspection and Maintenance Program (DIMP). These inspection and maintenance 11

compliance activities help mitigate the safety and reliability impacts associated with equipment failure 12

throughout SCE’s distribution system. 13

In SCE’s 2018 RAMP report, which evaluated SCE’s top safety risks and the mitigations 14

most effective to address them, SCE identified two risks applicable to these inspection and maintenance 15

activities. First, the “Contact with Energized Equipment” RAMP risk evaluated the risks associated with 16

distribution overhead conductor wire down events, as well as the risks associated with human contact 17

with intact conductor.2 For this risk, SCE identified SCE’s ODI, Apparatus Inspections, and 18

Preventative Maintenance activities within the DIMP as compliance activities that help address the risk. 19

Second, the “Underground Equipment Failure” RAMP risk evaluated the risk to SCE, its electrical 20

system, and the public resulting from underground electrical equipment failure. SCE identified the UDI 21

program as a compliance activity that helps to address this risk.3 Table II-1 below shows the mapping of 22

GRC activities in this testimony to the applicable RAMP control and risk within SCE’s 2018 RAMP 23

report. 24

2 See Chapter 5 of SCE’s 2018 RAMP Report (I.18-11-006) for additional information on SCE’s Contact with

Energized Equipment RAMP risk.

3 See Chapter 11 of SCE’s 2018 RAMP Report (I.18-11-006) for additional information on SCE’s Underground Equipment Failure RAMP risk.

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6

Table II-1 Distribution Inspections and Maintenance Compliance Activities

Included in SCE’s 2018 RAMP Filing

GRC Activity RAMP Compliance Activity Name

RAMP ID Risk Addressed

Distribution Underground Detailed Inspections

Underground Detailed Inspections (UDI) and Underground Preventive

Maintenance CM1

Underground Equipment Failure

Distribution Overhead Detailed Inspections

Overhead Detailed Inspection, Apparatus Inspections, and Preventive Maintenance

CM3 Contact with Energized Equipment

Distribution Apparatus Inspections and Maintenance

2. Regulatory Background/Policies Driving SCE’s Request 1

Many regulatory requirements drive distribution inspection and maintenance activities. 2

SCE’s DIMP addresses both these requirements and SCE’s internal standards that supplement or exceed 3

minimum regulatory requirements. The goal of DIMP is to meet the requirements of General Orders 4

(GO or GOs) 95, 128, and 165 in a way that: (1) follows sound maintenance practices; (2) enhances 5

public and worker safety and maintains system reliability; and (3) delivers overall greater safety value 6

for each dollar spent by allowing SCE to focus its resources on higher priority tasks. 7

B. 2018 Decision 8

1. Comparison of Authorized 2018 to Recorded 9

Figure II-3 shows the 2018 request, authorized, and recorded costs for O&M activities 10

included in this chapter. 11

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7

Figure II-3 Distribution Inspection and Maintenance O&M Expenses4

Comparison of 2018 Authorized to Recorded (Total Company – Nominal $000)

Distribution Preventive and Breakdown O&M Maintenance was $21.508 million below 1

authorized in 2018 due to SCE’s wildfire prevention efforts. SCE redirected its workforce to perform 2

enhanced overhead inspections of the distribution grid in high fire areas. The underrun was offset by 3

slight increases in other areas reflected in the figure above. 4

Figure II-4 shows the 2018 request, authorized, and recorded costs for capital activities 5


4 Refer to WP SCE-07, Vol. 01 - Authorized vs Recorded.

($21,508) ($740)

$121 $446

$2,289 $979

$145,717 $145,712

$127,298

0

20,000

40,000

60,000

80,000

100,000

120,000

140,000

160,000

2018 Request 2018Authorized

Apparatus I&M OH Det Insp Prev & BrkdnMtnce

UG Det Insp Patrol & Locate StLite Ops,I&M

2018 Recorded

Apparatus I&M OH Det Insp Prev & Brkdn Mtnce UG Det Insp Patrol & Locate StLite Ops, I&M

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8

Figure II-4 Distribution Inspection and Maintenance Capital5


Distribution Preventive and Breakdown Capital Maintenance was $20.321 million below 1

authorized in 2018 due to SCE’s wildfire prevention efforts. SCE redirected its workforce to perform 2

enhanced overhead inspections of the distribution grid in high fire areas. This underrun was partially 3

offset by Distribution Claims as shown in the figure. 4

C. Distribution Inspection and Maintenance Program (DIMP) 5

1. DIMP Overview 6

SCE’s DIMP addresses regulatory requirements and SCE’s internal standards that 7

supplement or exceed minimum regulatory requirements. DIMP allows SCE to prioritize work based on 8

the condition of each facility or piece of equipment and its potential safety and reliability impacts, 9

considering various factors. These factors may include such things as the voltage, location, accessibility, 10

and climate in which the equipment operates. DIMP enables SCE to prioritize resource allocation to 11

higher value activities (i.e., activities with a more significant safety and reliability impact) and deploy its 12

resources more effectively and efficiently to remediate conditions that potentially pose higher risks. This 13

5 Refer to WP SCE-07, Vol. 01 - Authorized vs Recorded.

(Continued)

($20,231)

$7,446$305,922 $305,922

$293,047

0

50,000

100,000

150,000

200,000

250,000

300,000

350,000

2018 Request 2018 Authorized Preventive & BreakdownMaintenance

Distribution Claim 2018 Recorded

Preventive & Breakdown Maintenance Distribution Claim

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approach follows the Commission’s direction under GOs 95, 128, and 165 and a memorandum of 1

understanding6 between SCE and the CPUC’s Safety and Enforcement Division. 2

DIMP has three maintenance priority levels. Highest priority items requiring immediate 3

action are assigned Priority 1. Priority Level 27 is a non-immediate risk to safety or reliability. Priority 1 4

and Priority 2 items may be fully repaired or temporarily repaired and potentially reclassified to a lower 5

priority item. Priority 3 items are all items identified as low potential impact to safety or reliability. 6

While Priority 3 items do not require immediate action, they do require corrective action within 60 7

months.8 8

2. DIMP Activities 9

a) Distribution Overhead Detailed Inspections (ODI) 10

The recorded and forecast expenses for ODI are shown in Figure II-5. The 11

forecast for 2019-2021 includes a proposed reduction that will occur with the approval of SCE’s EOI 12

program, described in detail in the following sections. 13

6 Refer to WP SCE-02, Vol. 01, Pt. 2, pp. 4-9 – Memo of Understanding.

7 Priority 2 maintenance items require corrective action within 0-24 months for non-HFAs and 0-12 months for HFAs.

8 See D.18-05-042 for the decision to amend Rule 18 of GO 95 requiring Priority 3 maintenance items to be corrected within 60 months effective June 30, 2019.

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10

Figure II-5 Distribution Overhead Detailed Inspections O&M Expenses9,10

Recorded (2014-2018)/Forecast (2019-2021) (Constant 2018 $000)

(1) Work Description and Need for Activity 1

As required by GO 165, inspections of the overhead distribution system 2

include annual grid patrols and overhead detailed inspections. GO 165 requires detailed inspection of 3

overhead distribution equipment every five years. In any given year where SCE does not perform an 4

overhead detailed inspection, a grid patrol will be performed. These activities include costs for 5

inspecting SCE’s overhead distribution electrical system under GO 165 and SCE’s DIMP. The 6

inspections and patrols are performed by SCE’s Electrical System Inspectors (ESIs). In addition, SCE’s 7

Wireless Technology Rate (WTR), which is an inspection related to third-party attachments (e.g., cable 8

television/internet and telecommunications) to distribution poles, is included in this activity. 9

Annual grid patrols and overhead detailed inspections are performed 10

across SCE’s distribution system using a geographical grid-based approach. SCE’s service territory is 11

segmented into geographical areas, or grids, which contain overhead and underground facilities on 12

9 Refer to WP SCE-02, Vol. 1, Pt. 2, pp. 10-11 - Overhead Detailed Inspections – 2021.

10 Refer to WP SCE-02, Vol. 1, Pt. 2, pp. 12-18 – O&M detail for Distribution Overhead Detailed Inspections.

2014 2015 2016 2017 2018 2019 2020 2021

Labor $4,585 $4,676 $5,013 $5,224 $4,709 $3,462 $3,462 $3,462Non-Labor $2,856 $3,281 $2,256 $1,988 $3,319 $1,483 $1,483 $1,483

OtherTotal Expenses $7,442 $7,957 $7,269 $7,213 $8,027 $4,945 $4,945 $4,945

Ratio of Labor to Total 62% 59% 69% 72% 59% 70% 70% 70%

Recorded Forecast

$1,000

$2,000

$3,000

$4,000

$5,000

$6,000

$7,000

$8,000

$9,000

2014 2015 2016 2017 2018 2019 2020 2021

Labor Non-Labor Other

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11

SCE’s distribution electrical system. The number of grids and population of the grids change over time 1

as electrical facilities are added or removed from the system. 2

The purpose of the ODI program is to perform a close-proximity, in-depth 3

evaluation of SCE’s overhead electrical facilities such as poles, capacitors, switches, transformers, 4

conductors, guy wires, and risers to: 5

Identify hazardous conditions or non-conformances with GO 95 that 6

require corrective action. Examples include leaking transformers, 7

broken or damaged equipment, encroachment of line clearances, 8

deteriorated cross arms, and missing or damaged high voltage signs; 9

Determine what corrective action is required and prioritize follow-up 10

corrective action under DIMP; 11

Perform minor repairs at the public level while at the location. 12

Inspectors commonly perform repairs such as replacing damaged 13

ground molding at the public level, installing guy guards, removing 14

unauthorized attachments (if appropriate), and installing pole tags; 15

Document inspection findings, including pending and completed 16

repairs; and 17

Validate equipment records and identify corrections as needed. 18

Identified maintenance items discovered during annual grid patrols or ODI 19

are repaired by the inspector at the time of the inspection or prioritized for follow-up corrective action 20

under SCE’s DIMP program. 21

SCE performs biannual inspections to the WTR equipment in order to 22

verify that third parties with attachments on distribution poles comply with SCE contractual agreements, 23

as well as GO 95 and GO 128. 24

(2) Scope and Forecast Analysis 25

(a) Historical Variance Analysis 26

The recorded costs for ODI have fluctuated during the 2014-2018 27

period due to the number of inspections required and performed in each year. SCE has utilized a 28

combination of SCE and contracted resources to perform the inspections. The labor and non-labor 29

recorded costs fluctuated due to the variation of internal or contracted resources used in each year. In 30

2018, recorded costs for ODI increased by approximately $1.5 million due to infrared inspections 31

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performed on SCE’s distribution grid to assess fire risk in both high-fire and non-high fire areas. This 1

added inspection technique increased spending between 2017 and 2018. 2

(b) Basis for O&M Cost Forecast 3

The test year forecast for ODI, without EOI reduction, is based on 4

2018 recorded costs reduced by $1.476 million for one-time infrared inspections performed in 2018. The 5

recorded and forecast costs for each sub-activity included in the ODI activity is shown in Table II-2. 6

Table II-2 Distribution Overhead Detailed Inspections O&M Expenses without EOI


If SCE’s Enhanced Overhead Inspection, as proposed in Exhibit 7

SCE-04, Volume 5, is not fully funded, SCE will need to restore the funding to last year recorded for 8

both Overhead Detailed Inspections and Annual Grid Patrols, as shown in Table II-2. This funding will 9

be necessary to continue to perform required inspections across SCE’s entire distribution grid. 10

b) Distribution Underground Detailed Inspections 11

The recorded and forecast expenses for UDI are shown in Figure II-6. 12

2014 2015 2016 2017 2018 2019 2020 2021Overhead Detailed Inspections 5,754$ 6,267$ 5,502$ 5,646$ 5,188$ 5,188$ 5,188$ 5,188$ Annual Grid Patrol 1,393 1,467 1,515 1,349 1,237 1,237 1,237 1,237 Infrared Inspections - - - - 1,476 - - - Wireless Technology Rate 295 223 253 218 126 126 126 126 Total Overhead Detailed Inspections 7,442$ 7,957$ 7,269$ 7,213$ 8,027$ 6,551$ 6,551$ 6,551$

Recorded Forecast

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13

Figure II-6 Distribution Underground Detailed Inspections O&M Expenses11


(1) Work Description and Need for Activity 1

This activity includes inspecting SCE’s underground distribution electrical 2

system under GO 165 and SCE’s DIMP. UDI provides close-proximity examination of underground and 3

pad-mounted distribution equipment. Inspectors assess subsurface and pad-mounted equipment 4

including structures, switches, transformers, visible cables, and associated components to identify safety 5

hazards and non-conformances with GO 128. Vault and manhole structures containing only cables are 6

also inspected. Like the ODI inspectors, the UDI inspectors document safety and reliability hazards and 7

prioritize corrective actions under SCE’s DIMP. When possible, they perform routine maintenance or 8

make repairs during the inspection.12 UDI activities are performed by a two-person crew, which includes 9

11 Refer to WP SCE-02, Vol. 02, Pt. 1, pp. 19-25 – O&M detail for Distribution Underground Detailed

Inspections.

12 Minor repairs are charged to the inspection activity and more complex repairs are charged to maintenance.

2014 2015 2016 2017 2018 2019 2020 2021Labor $4,321 $3,345 $4,273 $5,930 $5,945 $4,990 $5,363 $5,414

Non-Labor $1,109 $1,610 $1,816 $1,084 $817 $686 $737 $744Other

Total Expenses $5,431 $4,955 $6,089 $7,014 $6,762 $5,676 $6,101 $6,158


Recorded Forecast

$1,000

$2,000

$3,000

$4,000

$5,000

$6,000

$7,000

$8,000

2014 2015 2016 2017 2018 2019 2020 2021


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14

a journeyman lineman and a groundman, who are trained and qualified to work in underground vaults 1

and in proximity to energized high voltage equipment. 2

In some instances, UDI results will require an additional evaluation 3

regarding the condition of an underground structure. This additional evaluation, or Field Inspection (FI), 4

is performed on underground vaults or manholes where deterioration of the structure exceeds acceptable 5

levels. The FI is performed by a licensed structural engineer who evaluates the condition of the structure 6

and recommends actions needed to correct the structural deficiency. The actions may include replacing 7

the entire structure, shoring, or making repairs.13 8

(2) Scope and Forecast Analysis 9

(a) Historical Variance Analysis 10

Figure II-6 shows the recorded expenses and Table II-3 shows the 11

number of completed inspections from 2014-2018. The number of underground detailed inspections 12

includes each individual piece of equipment within the structure, as well as the structure. For example, if 13

a structure has four pieces of equipment, the recorded count will be five – representing inspections on 14

four pieces of equipment plus one structure. 15

Table II-3 Underground Detailed Inspections 2014-2018 Completed Inspections

The historical variances are caused by several factors that impact 16

the time required to perform the inspection and document the results so that repairs can be scheduled 17

and performed. In general, a UDI requires as few as fifteen minutes or up to three hours for a vault. 18

Gaining access can be difficult as some customers either take a while to respond or are suspicious of 19

providing access to their property to SCE personnel. In some instances, when customers are unavailable, 20

13 Replacement of underground structures and shoring is presented in Distribution Infrastructure Replacement.

2014 2015 2016 2017 2018

Underground Detailed Inspections 172,045 150,495 172,172 173,999 161,090Field Investigations

Vaults n/a 462 593 254 321Manholes n/a 110 79 27 62

Total Field Investigations n/a 572 672 281 383Total Inspections 172,045 151,067 172,844 174,280 161,473

Completed UDI Counts

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15

SCE personnel will leave a door hanger and return the next day. Some structures are covered with 1

vegetation which requires removal before the inspection can be performed. In other instances, customers 2

have installed hardscaping or other barriers that need to be removed before the inspection can be 3

performed. If these barriers are permanent, SCE will have to work with the property owner to have the 4

obstruction removed to allow for the inspection. 5

Once the inspection is completed, SCE personnel will document 6

the results of the inspection. If a repair is required, a notification will be created, and the inspector will 7

attach four or more pictures of the area or equipment needing repair. 8

These various factors drive the year-over-year variance for UDI as 9

inspectors face varying levels of difficulty in accessing or clearing structures in order to perform the 10

inspection. As described in the following section, this variability is included in the development of the 11

forecast for UDI in the test year. 12

(b) Basis for O&M Cost Forecast 13

The number of UDIs forecast for 2019-2023, shown in Table II-4, 14

is based on the number of inspections due each year, as required by GO 165 and SCE’s DIMP. The 15

number of FIs is based on a forecast failure, or referral rate, of 3.5% for vaults and manholes. 16

Table II-4 Underground Detailed Inspection Forecast

Inspection Count Forecast

As shown in Table II-5, SCE used a five-year average unit rate to 17

develop the cost forecast.14 The unit rate was calculated by dividing the annual recorded costs for each 18

year, 2014-2018, by the total number of inspections completed in each year, and then calculating a five-19

14 Refer to WP SCE-02, Vol. 02, Pt. 1, pp. 26-27 –Distribution Underground Detailed Inspections – 2021.

2019 2020 2021 2022 2023

Underground Detailed Inspections 155,842 167,519 167,111 166,214 173,982Field Investigations

Vaults 280 280 280 280 280Manholes 60 60 60 60 60

Total Field Investigations 340 340 340 340 340Total Inspections 156,182 167,859 167,451 166,554 174,322

Forecast UDI Counts

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year average of the annual unit rates. To develop the labor and non-labor forecasts, a five-year average 1

of recorded costs for labor and non-labor was used. 2

Table II-5 Underground Detailed Inspection Forecast

Unit Rate Forecast

The use of a five-year average for the UDI unit rate is appropriate 3

because it takes into consideration the annual variances that occur in UDI. As described above, the time 4

required to perform an inspection can vary from fifteen minutes to three hours, depending on the 5

complexity, accessibility, and installed equipment. This funding will allow SCE to continue to perform 6

UDI on its underground system as required by the Commission’s GOs and SCE’s DIMP. 7

c) Distribution Preventive and Breakdown Maintenance 8

Distribution Preventive and Breakdown Maintenance is necessary to maintain a 9

safe and reliable distribution system. Distribution maintenance is performed on either a planned basis or 10

an unplanned basis and includes both capital and O&M replacements and repairs. 11

Planned maintenance work is comprised of repairs to SCE’s equipment and 12

structures recorded as Priority 2 and Priority 3 items, primarily driven from inspection activities. These 13

repairs can be performed by inspectors or qualified electrical workers. SCE also refers to planned work 14

as preventive maintenance. 15

Unplanned activities, also referred to as breakdown maintenance, include the 16

repair of SCE equipment and structures that are damaged, compromised, or have failed in service. These 17

items are typically identified as Priority 1 conditions under SCE’s DIMP. Breakdown maintenance is 18

typically performed in response to damage caused by equipment failures, degradation, metallic balloons, 19

squirrels, rodents, birds, or other causes. 20

Under DIMP, inspectors identify and prioritize deteriorated components or 21

conditions found during inspections for follow up repair or replacement. Every item is evaluated based 22

2014 2015 2016 2017 2018 Average PercentLabor 4,321$ 3,345$ 4,273$ 5,930$ 5,945$ 4,763$ 79%Non-Labor 1,109$ 1,610$ 1,816$ 1,084$ 817$ 1,287$ 21%Total 5,431$ 4,955$ 6,089$ 7,014$ 6,762$ 6,050$ 100%

Total Inspections 172,045 151,067 172,844 174,280 161,473Inspection Unit Rate 32$ 33$ 35$ 40$ 42$ 36$

Recorded 2018 Constant $000 5-Year

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on the specifics for that condition, considering several factors, such as the equipment’s voltage, location, 1

accessibility, or climate. Inspection programs driving these activities include UDI, apparatus 2

inspections, and ODI, described previously. In addition, when field crews observe problems while 3

performing other work or responding to trouble calls, they perform necessary maintenance which also 4

records to this activity. 5

Maintenance activities can include the repair, replacement, or relocation of 6

facilities; replacement of signs and cross-arms; repair or relocation of conduit; repair or replacement of 7

conductor or cable, equipment, or pole fixtures; re-fusing line cutouts; repairing grounds; and replacing 8

transformers. These maintenance activities are performed by electrical crew foremen, linemen, 9

apprentice linemen, groundmen, and contract crews who work for SCE’s Distribution Construction and 10

Maintenance organization. Post-construction, SCE performs quality control inspections to validate that 11

the work meets SCE standards for construction and quality. Finally, field accountants record all the 12

material and cost information, and record the costs as either O&M expenses or capital expenditures. 13

(1) Distribution Preventive and Breakdown O&M Maintenance 14

Recorded and forecast expenses for Distribution Preventive and 15

Breakdown O&M Maintenance are shown in Figure II-7. The forecast for 2019-2021 includes a 16

proposed reduction that will occur with the approval of SCE’s EOI program, as described in detail in the 17

following sections. 18

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18

Figure II-7 Distribution Preventive and Breakdown O&M Maintenance Expenses15


(a) Work Description and Need for Activity 1

Distribution Preventive and Breakdown O&M Maintenance 2

includes the costs to make repairs to distribution equipment identified through SCE’s DIMP. These 3

repairs follow the Commission’s direction under GOs 95, 128, and 165 for maintenance of distribution 4

assets. 5

(b) Scope and Forecast Analysis 6

(i) Historical Variance Analysis 7

The annual costs vary from year-to-year based on the 8

volume of breakdown and maintenance items found during inspections. In 2018, SCE’s recorded 9

expenses were $13.9 million lower than 2017 due to a one-time, temporary change in maintenance 10

repair scheduling. This temporary change was implemented to accommodate the Enhanced Overhead 11

15 Refer to WP SCE-02, Vol. 02, Pt. 1, pp. 28-34 – O&M detail for Distribution Preventive and Breakdown

O&M Maintenance.

(Continued)

2014 2015 2016 2017 2018 2019 2020 2021

Labor $47,810 $48,299 $50,038 $48,336 $44,442 $41,651 $35,818 $41,481Non-Labor $70,959 $55,828 $49,570 $44,562 $33,772 $49,386 $45,057 $52,540



Recorded Forecast

$20,000

$40,000

$60,000

$80,000

$100,000

$120,000

$140,000

2014 2015 2016 2017 2018 2019 2020 2021


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Inspection (EOI)16 activity. To perform the EOI, SCE reassigned personnel responsible for performing 1

preventive O&M maintenance activities. This resulted in a reduction to the recorded cost for 2018. 2

(ii) Basis for O&M Cost Forecast 3

Distribution Preventive and Breakdown O&M Maintenance 4

costs vary year-to-year based on the required number of preventive and breakdown maintenance items 5

that need to be repaired in each year. The complexity of each repair also contributes to the variance in 6

year-to-year costs. For example, the repair of a missing down-guy shield costs less to repair than 7

replacing a broken cross-arm. 8

SCE forecasts its 2021 test year request using a four-year 9

average of 2014 to 2017 recorded costs. 2018 was not a normal operating year because, as described 10

previously, in the last quarter of 2018, SCE initiated its EOI, which required use of personnel who 11

would normally perform O&M maintenance work. Required maintenance work previously scheduled for 12

completion in 2018 was rescheduled to early 2019. As such, SCE is excluding 2018 recorded costs from 13

the average. In addition to this four-year average, SCE is adding $9 million to the test year to perform 14

the Priority 3 maintenance items required by recent changes to GO 95.17 SCE’s is proposing to reduce 15

this forecast for work that will be performed under the EOI program. To calculate the EOI portion of 16

Distribution Preventive and Breakdown O&M Maintenance performed in HFAs, SCE uses the 17

percentage of this work performed on the overhead system (47%) and the percentage of circuit miles in 18

HFAs (25%).18 SCE then normalizes its forecast for ratemaking purposes for 2021 through 2023. 19

If SCE’s Enhanced Overhead Inspection, as proposed in 20

SCE-04, Volume 5, is not fully funded SCE will need to restore the funding to the four-year recorded 21

average (2014-2017) plus priority 3 maintenance items for both Distribution Preventive and Breakdown 22

O&M Maintenance, as shown in Table II-6. This funding will be necessary to continue to perform 23

required maintenance activities across SCE’s entire distribution grid. 24

16 Please see SCE-04, Vol. 05 – Wildfire Management for a detailed description of SCE’s EOI activity.

17 See D.18-05-042 for the decision to amend Rule 18 of GO 95 requiring Priority 3 maintenance items to be corrected within 60 months, effective June 30, 2019. SCE’s forecast includes a level work plan that starts prior to the first due date to ensure compliance.

18 Refer to WP SCE-02, Vol. 02, Pt. 1, pp. 35-37 –Distribution Preventive and Breakdown O&M Maintenance – 2021.

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20

Table II-6 Distribution Preventive and Breakdown O&M Maintenance

Forecast Calculations for Priority 3 and EOI (Constant 2018 $000)

(2) Distribution Preventive and Breakdown Capital Maintenance 1

The recorded costs for 2014 through 2018 and forecast for 2019 through 2

2023 are shown in Figure II-8. The forecast for 2019-2021 includes a proposed reduction that will occur 3

with the approval of SCE’s EOI program, described in detail in the following sections. 4

2014 2015 2016 2017 2018 Preventive and Breakdown O&M Maintenance 118,770$ 104,127$ 99,608$ 92,898$ 78,215$

2019 2020 2021 2022 2023 Preventive and Breakdown O&M Maintenance 103,828$ 103,828$ 103,828$ 103,828$ 103,828$

Priority 3 Maintenance Items - 3,000 9,000 18,000 27,000 Total Preventive & Breakdown O&M Maintenance 103,828$ 106,828$ 112,828$ 121,828$ 130,828$

Reduction for EOI Performed in HFA (12,791) (25,953) (26,695) (27,807) (28,920) Preventive & Breakdown O&M Maintenance with EOI Funded 91,037$ 80,875$ 86,133$ 94,021$ 101,909$

2021 Normalized 94,021$

Recorded

Forecast

20



21

Figure II-8 Distribution Preventive and Breakdown Capital Maintenance19

Multiple CWBS Elements20 Recorded (2014-2018)/Forecast (2019-2023)

(Total Company - Nominal $000)

(a) Program Description and Need for Activity 1

Distribution Preventive and Breakdown Capital Maintenance 2

includes the costs to replace distribution equipment identified through SCE’s DIMP. These replacements 3

follow the Commission’s direction under GOs 95, 128, and 165 for maintenance of distribution assets.4

19 Refer to WP SCE-02, Vol. 02, Pt. 1, pp. 38-41 – capital detail for Distribution Preventive and Breakdown

Capital Maintenance.

20 Distribution Preventive and Breakdown Capital Maintenance includes CWBS Elements CET-PD-BM-BD, CET-PD-BM-EP, CET-PD-CR-IF, CET-PD-IR-EP, CET-PD-IR-NP, CET-PD-IR-PM, AND CET-PD-IR-SB.

2014 2015 2016 2017 2018 2019 2020 2021 2022 2023

Nominal $218,710 $256,177 $277,712 $280,098 $255,748 $280,120 $278,006 $286,850 $295,147 $303,636

$50,000

$100,000

$150,000

$200,000

$250,000

$300,000

$350,000

Forecast

21



22

(b) Basis for Capital Expenditure Forecast 1

SCE uses a four-year average (2014-2017) to develop the 2019-2

2023 forecast. The annual costs vary from year-to-year based on the volume of preventive and 3

breakdown maintenance items found during inspections, as well as the complexity of the required repair. 4

In the last quarter of 2018, SCE accelerated wildfire mitigation 5

efforts that impacted capital maintenance work performed by both SCE and contractor personnel. Some 6

work previously scheduled to be complete in 2018 was rescheduled to 2019. Since 2018 does not reflect 7

a normal operating year, 2018 was not included in this activity’s forecast. SCE then calculated a 8

reduction to Distribution Preventive and Breakdown Capital Maintenance for work that is forecast to be 9

performed as part of SCE’s proposed EOI program. This reduction is based on two calculations. The 10

first calculates the work performed on the overhead system using a 2014-2017 four-year average, 34%.21 11

The second calculation applies the percentage of SCE’s circuit miles located in HFAs, 25%.22 12

Table II-7 Distribution Preventive and Breakdown Capital Maintenance

Forecast Calculations for EOI (Nominal $000)

If SCE’s Enhanced Overhead Inspection program, as proposed in 13

Exhibit SCE-04, Volume 5, is not fully funded SCE will need to restore the funding to the four-year 14

recorded average (2014-2017) for Distribution Preventive and Breakdown Capital Maintenance, as 15

21 For both O&M and capital Distribution Preventive and Breakdown Maintenance activities, EOI work

performed in HFAs is assumed to impact only overhead equipment. For CWBS Element Remove Idle Facilities, SCE assumed 75% of work in this category is performed on the overhead system.

22 Refer to WP SCE-02, Vol. 02, Pt. 1, pp. 42-43 – Distribution Preventive and Breakdown Capital Maintenance – 2021.

2014 2015 2016 2017 2018 Preventive and Breakdown Capital Maintenance 218,710$ 256,177$ 277,712$ 280,098$ 255,748$

2019 2020 2021 2022 2023 Preventive and Breakdown Capital Maintenance 293,175$ 304,533$ 314,221$ 323,309$ 332,609$

Reduction for EOI Performed in HFA (12,911) (25,953) (26,695) (27,807) (28,920) Preventive & Breakdown Capital Maintenance with EOI Funded 280,264$ 278,579$ 287,526$ 295,502$ 303,689$

Recorded

Forecast

22



23

shown in Table II-7. This funding will be necessary to continue to perform required maintenance 1

activities across SCE’s entire distribution grid. 2

D. Other O&M Activities 3

1. Patrolling and Locating Trouble 4

The recorded and forecast expenses for Patrolling and Locating Trouble are shown in 5

Figure II-9. 6

Figure II-9 Patrolling and Locating Trouble O&M Expenses23


a) Work Description and Need for Activity 7

Patrolling and Locating Trouble is performed by troublemen, who serve as SCE’s 8

first responders, providing around-the-clock coverage for electrical-service problems resulting from a 9

wide range of events on the distribution system. These employees come from the journeyman lineman 10

23 Refer to WP SCE-02, Vol. 02, Pt. 1, pp. 44-50 – O&M detail for Patrolling and Locating Trouble O&M

Expenses.

2014 2015 2016 2017 2018 2019 2020 2021

Labor $15,837 $17,472 $16,982 $18,187 $18,833 $18,833 $18,833 $18,833Non-Labor $3,433 $3,071 $3,037 $3,324 $3,196 $3,196 $3,196 $3,196



Recorded Forecast

$5,000

$10,000

$15,000

$20,000

$25,000

2014 2015 2016 2017 2018 2019 2020 2021


23



24

ranks and are highly skilled in troubleshooting the electrical grid, switching, and emergency scene 1

control. 2

Troublemen must respond efficiently and safely during emergency situations and 3

in their interactions with customers. SCE’s troublemen respond to incidents such as outages, partial 4

lights, damaged equipment (e.g., downed wires and failed transformers), and voltage fluctuation issues. 5

Troublemen are notified through a Distribution Operations Center (DOC) or a switching center to locate 6

an identified or reported problem and to take expedited action to mitigate the potential impacts of the 7

problem. To do so, dispatched troublemen must first locate the source of the problem. This may be as 8

simple as responding to a location identified by a customer or emergency personnel, or it may require 9

patrolling a circuit, including isolating and testing sections of the circuit to determine the cause of the 10

line relay or loss of power. 11

Once the troubleman has located the source of the problem, corrective action is 12

taken. If possible and safe to do so, the troubleman will act alone and correct the problem without 13

interrupting service to customers. More complex problems may require the troubleman to electrically 14

sectionalize a portion of circuit to isolate the problem, restore service to as many customers as possible, 15

and perform repairs to return the distribution system to safe operating conditions.24 16

To isolate a problem, a troubleman will coordinate with system operators to open 17

switches to isolate a section of the grid or close switches to pick up load on an alternate circuit. Switches 18

may be operated manually by troublemen in the field or, sometimes, remotely by a system operator. In 19

performing a switching procedure to isolate a section of a circuit, the troubleman’s goal is to protect 20

himself, other employees working on the grid, and the public. In doing so, the troubleman can safely 21

restore service to customers. 22

Based on the work necessary to restore power and remediate the problem, the 23

troubleman may not be able to perform the work alone. In these situations, the troubleman will request 24

additional assistance from either another troubleman or a field crew. 25

b) Scope and Forecast Analysis 26

(1) Historical Variance Analysis 27

The labor expenses are the costs for SCE troublemen performing patrols 28

and locating trouble. The non-labor expenses include costs for materials, vehicles, and other related 29

24 Repairs are recorded under Distribution Preventive and Breakdown Maintenance.

24



25

charges. The recorded costs vary slightly year-over-year depending on the volume of trouble calls. At 1

the end of 2016, SCE hired four additional troublemen for its Rural region. The need for these resources 2

was described in SCE’s 2018 GRC.25 This increase in troublemen resources results in the increase in 3

recorded costs for 2017 and 2018. 4

(2) Basis for O&M Cost Forecast 5

SCE proposes 2018 recorded costs as its 2021 test year forecast for 6

Patrolling and Locating Trouble. SCE plans to maintain its current staffing level through the test year 7

period and 2018 recorded includes all costs for this required staffing level. SCE’s staffing level is based 8

on providing a consistent response time to reported outages. The current staffing level will allow SCE to 9

continue to respond to reported outages at the historical levels. Timely response to outages is critical to 10

maintaining the safety and reliability of the electrical grid for customers, employees, and the public. This 11

request will provide SCE with the funding necessary to provide patrolling and locating trouble at current 12

levels. 13

2. Distribution Apparatus Inspections and Maintenance 14

The recorded and forecast expenses for Distribution Apparatus Inspections and 15

Maintenance are shown in Figure II-10. 16

25 See D.16-09-001, SCE-02, Vol. 5.

25



26

Figure II-10 Distribution Apparatus Inspections and Maintenance O&M Expenses26



This activity includes the costs associated with the inspection, testing, and 2

maintenance of overhead and underground distribution apparatus used for remote monitoring and 3

control. Examples of distribution apparatus include capacitors, regulators, network protectors, fault 4

interrupters, and automatic re-closing switches used for line protection and sectionalizing. Both the 5

inspection and resulting maintenance performed by the apparatus crews is included in this activity. 6

Apparatus crews with specialized training in automated equipment perform these inspections, including 7

technical diagnostic testing to ensure proper functioning of the equipment. SCE’s apparatus inspection 8

and maintenance program is designed to support SCE’s commitment to providing a safe and reliable 9

electrical distribution system by maintaining proper functionality and operation of the apparatus 10

equipment. 11

26 Refer to WP SCE-02, Vol. 01, Pt. 2, pp. 51-57 – O&M detail for Distribution Apparatus Inspection and

Maintenance.

2014 2015 2016 2017 2018 2019 2020 2021

Labor $4,300 $4,527 $5,084 $5,260 $5,092 $5,092 $5,092 $5,092Non-Labor $815 $1,056 $787 $616 $605 $605 $605 $605



Recorded Forecast

$1,000

$2,000

$3,000

$4,000

$5,000

$6,000

$7,000

2014 2015 2016 2017 2018 2019 2020 2021


26



27



The recorded costs for Distribution Apparatus Inspection and Maintenance 3

has consistently increased during the historical period. This increase is driven by the installation of more 4

automated distribution apparatus on the system as part of on-going capital programs. As a result of the 5

increase in equipment, SCE has had to perform a larger volume of inspections and a related increase in 6

the maintenance work resulting from these inspections. To address this increase in work, SCE has hired 7

additional apparatus personnel to perform the required inspection and maintenance of the equipment 8

installed on SCE’s system. 9


SCE proposes 2018 recorded costs for the 2021 test year forecast for 11

Apparatus Inspection and Maintenance Activities. The costs recorded in 2018 represent SCE’s most 12

accurate estimate of the costs SCE will incur in the future periods in order to adequately inspect and 13

maintain the distribution apparatus installed on SCE’s distribution grid. This funding will provide SCE 14

with the necessary resources to perform required inspection and maintenance activities on its 15

distribution apparatus. 16

E. Distribution Claim 17

1. Capital Forecast 18

The recorded costs for 2014 through 2018 and forecast for 2019 through 2023 are shown 19

in Figure II-3Figure II-11. 20

27



28

Figure II-11 Distribution Claim27,28

CWBS Element CET-PD-CL-DC Recorded (2014-2018)/Forecast (2019-2023)


2. Program Description and Need for Activity 1

Distribution Claim includes the costs incurred by SCE to repair damage to the 2

distribution system caused by another party. In cases where SCE is able to identify the party responsible 3

for the damage, SCE pursues recovery of the costs to repair the damage. The most common cause of 4

damage to SCE’s system occurs when a vehicle collides with a distribution pole or other above ground 5

equipment. This resulting damage is most often downed wires, poles and pole-mounted equipment, and 6

damaged ground level transformers and equipment. 7

Damages that result in downed wires, poles, and other electrical equipment require 8

immediate response from SCE personnel. This damage to SCE’s equipment is frequently due to 9

vehicular accidents in or adjacent to roadways, sidewalks, businesses, and homes and may pose a public 10

safety hazard. In addition, damaged equipment might lead to customer outages. Often, calls from police 11

or fire departments at the scene of the accident inform SCE of the damage. Timely response is critical to 12

27 Refer to WP SCE-02, Vol. 01, Pt. 2, pp. 58-59 – capital detail for Distribution Claim.

28 Refer to WP SCE-02, Vol. 01, Pt. 2, pp. 60-61 – Distribution Claim – 2021.

2014 2015 2016 2017 2018 2019 2020 2021 2022 2023

Nominal $28,290 $30,823 $37,318 $40,853 $37,299 $38,879 $40,385 $41,670 $42,875 $44,108

$5,000

$10,000

$15,000

$20,000

$25,000

$30,000

$35,000

$40,000

$45,000

$50,000

Forecast

28



29

ensuring the hazardous conditions are corrected, power is restored to affected customers, and to identify 1

the party who caused the damage to improve chances of recovering the costs. 2

3. Basis for Capital Expenditure Forecast 3

The costs to repair damages recorded to Distribution Claim vary from year-to-year and 4

the events that drive the costs are random and beyond the control of the utility. SCE uses a five-year 5

average to forecast the test year expenditures for Distribution Claim. This forecast methodology has 6

been proposed in SCE’s previous GRCs and has been adopted by Commission. A five-year average is 7

the most appropriate method to forecast costs for damage claims which are both random and beyond the 8

control of the utility. 9

F. Streetlight Operations, Inspections, Maintenance, and LED Conversions 10

SCE owns and maintains an inventory of streetlights throughout its service territory. Beginning 11

in 2015 SCE offered cities and other agencies the opportunity to purchase streetlights within their 12

jurisdiction.29 To date, SCE has transferred or plans to transfer approximately 220,000 lights to outside 13

agencies. SCE’s current inventory of lights is approximately 640,000 and is projected to be 14

approximately 470,000 once all streetlight transfers are complete. 15

In addition to the transfer of streetlights, SCE is proactively converting current High Pressure 16

Sodium Vapor (HPSV)30 to LED technology as cities and agencies elect to take service under Tariff LS-17

1 Option E. 18

In the following sections, SCE will describe the status of the LS-1 Option E conversions, 19

streetlight sales, and efforts SCE is undertaking in compliance with its settlement agreement with the 20

California Streetlight Association (CALSLA). SCE will next discuss the forecast costs needed to 21

perform this work as well as the costs for the on-going maintenance of the street lighting system. 22

1. Status of Streetlight Sales, LED Conversions, and Smart City Sensors 23

SCE’s Business Customer Division (BCD) is responsible for developing policies and 24

interfacing with customers regarding SCE-owned streetlights. In this role, BCD coordinates streetlight 25

functions throughout SCE, including T&D, Finance, Regulatory Affairs, and Treasurers. BCD’s 26

Streetlight Team focuses on key work areas that impact streetlight customers and helps to implement 27

key technology shifts in the industry. BCD fields significant ad hoc requests in support of account 28

29 Only streetlights taking service under SCE’s LS-1 tariff were eligible for purchase.

30 HPSV is the predominant lighting technology on SCE’s system. Lights eligible for conversion to LED may include other, less common, lighting technologies.

29



30

managers, T&D, and Local Public Affairs team members to facilitate analysis, technical data, policy 1

reviews, technology, service requests, and general streetlight information. 2

a) Streetlight Sales to Customers 3

Prior to August 15, 2015, SCE offered LS-1 customers the option of purchasing 4

SCE-owned streetlights located within the customers’ geographic boundaries pursuant to Section 851 of 5

the California Public Utilities Code. The first step in the process for a customer to acquire SCE-owned 6

streetlights was to pay a deposit to offset the cost of SCE’s valuation of the streetlights to be sold. As of 7

June 30, 2016, eighty-two cities had paid the required deposit and were in the streetlight “sales queue.” 8

BCD manages the sales process through valuation, communication, contract development, Commission 9

approval, and asset transition. 10

On March 17, 2016, the Commission approved the sale of approximately 19,500 11

streetlights to the City of Lancaster, the first customer to complete the streetlight acquisition effort with 12

SCE. All streetlights within Lancaster that were available for sale31 are now owned and operated by the 13

City of Lancaster. As of June 1, 2019, forty customers have signed sales agreements with SCE and 14

twenty-five communities have completed the transition of streetlights, now owning and operating 15

streetlights in their communities. Fifteen communities are currently in transition and being completed 16

(the County of Los Angeles agreement is currently being prepared for submittal to the CPUC as an 17

application under Section 851). Forty-five communities received streetlight valuations but did not sign a 18

sales agreement or move forward in the process. The County of Los Angeles will be the final customer 19

to move through the streetlight acquisition process with SCE. 20

In June 2015, SCE notified customers of its intent to cease selling its streetlights 21

to customers who had not submitted a valuation deposit prior to August 15, 2015, the date SCE would 22

close the streetlight sales queue. SCE also placed a time limit for customers to execute the sales 23

agreement following receipt of the valuation. SCE has completed valuations for all participating 24

customers in the acquisition queue and has completed all sales agreements. SCE continues to work with 25

customers to transfer streetlights and expects to complete all in-queue transitions32 by the end of 2020. 26

All transfers of the streetlights to local governments have been approved by the Commission through 27

31 Streetlights installed on distribution or transmission poles are not available for sale. Series streetlights are also

not eligible for purchase due to the configuration of the lighting infrastructure.

32 LA County is purchasing streetlights pending approval of the application to the CPUC under Section 851. Due to the size of transactions, LA County streetlight transition from LS-1 to LS-2 may extend beyond 2020.

30



31

Section 851 filings. Newly acquired customer streetlights transition from LS-1 to LS-2B tariffs. The rate 1

transition often takes 90 to 120 days after assets have been paid for and transitioned to customer 2

ownership as SCE undertakes internal rate, billing, and mapping changes to finalize the transaction. 3

SCE expects to sell approximately 225,000 streetlights when the program is 4

completed. The final number is pending confirmation of inventory in communities currently moving 5

through transition as well as the final number that will be available for sale in LA County. 6

b) Assembly Bill (AB) 719 and SCE’s Streetlight Upgrade Efforts 7

On March 30, 2016, SCE filed Advice 3241-E-A, proposing the creation of LS-1 8

Option E. SCE customers who have already received replacements under the LS-1, Option E streetlight 9

replacement program are seeing monthly bill reductions of 76 cents for non-decorative fixtures, based 10

on an example using the most prevalent 100-watt HPSV fixture replacement, depending on the wattage. 11

As expected, there is significant customer demand for conversion from HPSV to the more efficient LED 12

streetlight fixtures. SCE is currently replacing fixtures at a pace of approximately 70,000 streetlights in 13

2019, serving streetlight customers in order through a queue as local government and other streetlight 14

customers sign-up for the Option E offering. 15

SCE expects replacement work will continue through the 2021 GRC cycle at a 16

rate of 50,000 each year with participation in LS-1 Option E tapering off after 2024. The operational and 17

financial implications of these conversions are described in SCE’s request for streetlight capital and SCE 18

respectfully requests continued support and funding to implement LED replacements through the 19

successful LS-1 Option E program at the proposed level. 20

c) Streetlight Sensor and Smart Community Technology 21

In support of customer demand and SCE’s focus on technology and efficiency 22

improvements, SCE is researching and evaluating the implementation of “Smart Streetlight Sensor” 23

technology. SCE is also reviewing significant customer demand to place customer owned attachments 24

on SCE owned (LS-1) and customer owned (LS-2/LS-3) streetlights for “Smart Community” technology 25

which facilitates public safety and public works applications through sensors, cameras, and various 26

monitoring devices. In alignment with customer interest and SCE’s desire to continually improve 27

service, outage response, and the facilitation of future technology applications, SCE is seeking the 28

ability to fund pilot level implementation of smart streetlight sensors. These smart sensors allow for real 29

time information to be relayed when an outage occurs and provide GPS infrastructure location 30

31



32

information. Both components will create quicker outage response with significant improvements to 1

location accuracy and overall inventory integrity. 2

SCE currently awaits customer notification of streetlight outages or finds outages 3

during annual patrols. If smart streetlights sensors are fully implemented in the future, this effort could 4

reduce or eliminate the need for annual streetlight patrols to find outages. As part of the pilot, SCE will 5

also investigate the use of smart streetlights sensors to facilitate individual metering of streetlights, 6

which may pave the way for metered rate and dimming opportunities. 7

SCE is currently working to develop, and submit for CPUC approval, a tariff that 8

will facilitate the use of smart community technology on customer owned LS-2 streetlights. In addition 9

to this tariff, SCE is also developing a dimmable-streetlight tariff that will be available for LS-2 10

streetlights. SCE is also reviewing the opportunity to reduce the energy component of LS-1 or LS-2 11

streetlights where smart streetlight sensor technology ramps up and down lighting at sunrise and sunset, 12

potentially positively impacting the energy component of flat metered streetlight rates. 13

2. Streetlight Operations, Inspections, and Maintenance O&M Expenses 14

The recorded and forecast costs for Streetlight Operations, Inspection, and Maintenance 15

are shown in Figure II-12. 16

32



33

Figure II-12 Streetlight Operations, Inspections, and Maintenance O&M Expenses33



Streetlight Operations, Inspections, and Maintenance O&M Expenses includes all 2

O&M expenses for SCE’s street lighting system. The specific work and activities included in operations, 3

inspections, and maintenance are described in the following section. 4

Streetlight Operations includes billing, mapping, and records maintenance for all 5

streetlights taking service under an SCE streetlight tariff. This includes streetlights that are owned and 6

maintained by SCE, customer owned streetlights receiving electrical service only, and lighting for 7

outdoor walkways or parking areas. Maintaining accurate records for all streetlights provides SCE with 8

the information necessary to accurately bill customers and to assign maintenance and inspection work to 9

repairmen and electrical crews. These records include information such as city or agency ownership, 10

geographical location, wattage, lighting technology, etc. These records require continual updating to 11

33 Refer to WP SCE-02, Vol. 01, Pt. 2, pp. 62-68 – O&M detail for Streetlight Operations, Inspections and

Maintenance.

2014 2015 2016 2017 2018 2019 2020 2021

Labor $4,619 $3,990 $4,099 $4,905 $4,100 $4,100 $4,100 $4,100Non-Labor $4,125 $3,392 $2,187 $2,256 $2,475 $2,475 $2,475 $2,475



Recorded Forecast

$1,000

$2,000

$3,000

$4,000

$5,000

$6,000

$7,000

$8,000

$9,000

$10,000

2014 2015 2016 2017 2018 2019 2020 2021


33



34

reflect changes in ownership, additions to the system resulting from new construction, removals from 1

the system, and changes in lighting technology. 2

Streetlight Inspections are performed on an annual basis for urban areas and every 3

two years in rural areas in compliance with GO 95. These inspections are performed at night and 4

identify any streetlights that are not operating. SCE employs a contractor to perform these inspections in 5

the urban areas and SCE employees in the rural areas. Non-operating lights identified through the 6

inspections are repaired by SCE’s streetlight repairmen or by an SCE line crew. 7

Streetlight Maintenance includes the costs to replace burned out bulbs, failed 8

photocells or sensors, and other minor repairs to streetlights. These maintenance activities are identified 9

through routine streetlight inspections and from information reported to SCE through customers and 10

cities. For non-operating streetlights identified through inspections, SCE dispatches streetlight repairmen 11

to make the repairs. Similarly, when SCE is notified by customers or cities of a burned-out light, a light 12

on during the day, a flickering light, or other lighting malfunction, repair personnel are dispatched to 13

make the repair. The costs for these repairs are charged to this activity. 14



The recorded costs in 2015 decreased compared to 2014 as the result of a 17

reorganization which eliminated streetlight repairmen supervisors. In 2016, costs for streetlight system 18

maintenance declined by approximately $1M due to a reduction in the purchase of replacement bulbs 19

and parts for HPSV streetlights as SCE began to convert lights to LED technology. In 2017, labor 20

increased in response to account maintenance required as a result of tariff changes resulting from 21

changes in street lighting technology and ownership. In 2018, labor decreased to previous levels as work 22

stabilized. 23


In the short-term, SCE expects that streetlight sales and LED conversions 25

will not result in a decrease in operations and maintenance costs for streetlights. This is primarily due to 26

the duration of the transfer process. While SCE has entered into sales agreements with several cities, 27

SCE must continue to maintain the assets until ownership of the streetlights has been transferred. 28

Likewise, LED conversions have a limited impact on short-term O&M because the average bulb life of 29

an HPSV is between seven and fifteen years. The reduction in maintenance costs for LED lights is 30

34



35

limited to the bulb replacement because there is no other change to the electrical system serving the 1

streetlights, including the photocell. 2

SCE must continue to maintain asset and billing records on all streetlights 3

taking electrical service under an SCE streetlight tariff. Billing record maintenance is necessary to 4

accurately bill customers for electricity usage. Asset record maintenance is necessary because SCE 5

maintains ownership of the electrical infrastructure serving customer owned lights and relies on these 6

asset records to identify the location of equipment in need of repair or upgrade. As a result, streetlight 7

sales will not reduce the cost for maintaining streetlight records. 8

SCE forecasts test year expenses using 2018 recorded costs. The last 9

recorded year reflects cost reductions achieved through restructuring of the street lighting organization 10

and is necessary to continue to perform streetlight mapping, billing, inspections, and routine and 11

breakdown maintenance on streetlights within SCE’s service territory. 12

3. Streetlight Maintenance and LED Conversions 13

Streetlight Maintenance and LED Conversions recorded costs for 2014 through 2018 and 14

forecast for 2019 through 2023 are shown in Figure II-13. 15

35



36

Figure II-13 Streetlight Maintenance and LED Conversions

CWBS Element CET-PD-OT-SL34 Recorded (2014-2018)/Forecast (2019-2023)


a) Program Description and Need for Activity 1

Streetlights are raised fixtures typically mounted on concrete, wood, composite, 2

or steel poles to illuminate highways, roads, parkways, and sidewalks. The principal streetlight 3

components are illustrated in Figure II-14. SCE owns and maintains approximately 600,000 lights in its 4

service territory. Most streetlights on the system are concrete electroliers with HPSV luminaires; 5

however, since 2016 SCE been converting these lights to LEDs. Most streetlight poles have a single 6

luminaire or lamp, but sometimes an electrolier may have multiple luminaires or lamps and can be 7

served electrically through overhead or underground connections. SCE also owns and maintains outdoor 8

lighting installed in public walkways and parking lots. 9

As LED technology has matured, the cost of LED luminaires has declined, and 10

the expected useful life now exceeds that of HPSV street lighting technology. Driven by the potential for 11

34 Refer to WP SCE-02, Vol. 01, Pt. 2, pp. 69-71 – capital detail for Streetlight Maintenance and LED

Conversions.

2014 2015 2016 2017 2018 2019 2020 2021 2022 2023

Nominal $81,760 $48,518 $28,245 $34,118 $54,833 $52,984 $48,619 $50,342 $52,152 $53,372

$10,000

$20,000

$30,000

$40,000

$50,000

$60,000

$70,000

$80,000

$90,000

Forecast

36



37

energy and maintenance savings provided by LED technology, SCE expects customers to continue to 1

elect conversion to LED technology through its LS-1 Option E tariff. 2

Figure II-14 Streetlight Components

Street light capital expenditures include five main activities: (a) steel pole 3

replacements; (b) luminaire replacements; (c) conversion of HPSV to LED streetlights;35 (d) Smart 4

Sensor installation; and (e) minor capital maintenance. Expenditures for these activities are not tracked 5

separately in SCE’s accounting system. 6

(1) Steel Pole Replacement Program 7

For several years, SCE has had a program to replace deteriorated steel 8

streetlight poles with concrete streetlight electroliers. Currently, the inventory of steel poles is 9

approximately 28,000. Most of the steel streetlights were installed in the 1950s and 1960s and have 10

exceeded their useful life. 11

35 Conversions of HPSV to LED are discussed in SCE’s Rate Schedule LS-1E.

37



38

Typically, steel streetlights deteriorate in three ways: (1) the top of the 1

pole rusts out, (2) holes develop in the base of the pole caused by rust, or (3) the foundation anchor bolts 2

rust and eventually disintegrate. 3

The aging of steel streetlight poles and the continuing corrosion of these 4

assets leads to an ongoing need to replace steel streetlight poles. However, SCE has agreed to the 5

requests made by cities in the streetlight sales queue to defer steel pole replacements in their cities, 6

where possible, to minimize impacts to the sale valuation. Additionally, for cities in the sales queue or 7

that have elected to convert to LED under the LS-1 Option E tariff, SCE will work with these cities to 8

minimize replacing poles that might undergo conversion shortly thereafter. In this GRC, SCE estimates 9

replacing 10,750 steel streetlight poles from 2019 to 2023. 10

(2) Luminaire Replacement 11

SCE owns approximately 570,000 streetlight luminaires and over 24,000 12

area and outdoor walkway lights. From time to time, the luminaires in SCE’s system require 13

replacement. To maintain reliable streetlight service, SCE is requesting capital that will allow for the 14

replacement of 21,500 luminaires during 2019-2023, due to failure and malfunction. The forecast 15

replacement quantity is based on a 2% yearly luminaire failure rate. With pending streetlight sales and 16

on-going LED conversions, SCE’s luminaire replacement efforts will target remaining HPSV and 17

outdoor lighting fixtures. For this GRC request, SCE proposes to minimize like-for-like HPSV luminaire 18

replacement in expectation of new LED technology. HPSV, LPSV, and MH luminaires typically need to 19

be replaced after seven years of service because internal components fail. In prior years, SCE 20

proactively replaced aged fixtures at the end of their service life to minimize an additional repair trip 21

that might result from an old fixture failing shortly after a recent bulb replacement. Due to the 22

anticipated deployment of LED luminaires, SCE plans to minimize proactive fixture replacements of 23

non-LED luminaires in order to minimize situations where a recently installed non-LED luminaire is 24

replaced with an LED luminaire. 25

(3) LED Conversions 26

SCE is proposing to continue LED conversions initiated by AB719 and 27

offered to SCE customers under its LS-1 Option E tariff. SCE proposes spending approximately $115 28

million in 2019-2023 on LED conversions. Based on the forecast unit costs described in the following 29

section, SCE’s proposed capital expenditure would result in 286,300 luminaire conversions in 2019-30

2023. 31

38



39

(4) Smart Sensors 1

In 2019, SCE expects to pilot 6,000 smart streetlight sensors in one 2

disadvantaged community at a cost of roughly $900,000. These smart sensor installations will be done in 3

concert with the LS-1 Option E LED Conversion program. In 2020, SCE plans to deploy 10,000 smart 4

streetlights sensors in another two to three communities at a cost of $1.5 million (targeting communities 5

closely tied to potential Olympic venues and/or disadvantaged communities). SCE will continue to 6

install smart sensors at the requested rate of $3 million in each of the GRC years, 2021, 2022, and 2023 7

to deploy 20,000 sensors each year. This will bring the total population to between 15 to 20 8

communities (out of more than 200 local governments in the SCE service territory) and 76,000 sensors 9

deployed. 10

SCE will continue to evaluate the deployment, benefits, and effectiveness 11

of the sensors as the installation expands and completes. SCE will utilize the LS-1 Option E team to 12

install and implement the sensors so there will be no additional installation cost associated with the 13

technology pilot and demonstration. 14

(5) Minor Capital Maintenance 15

Streetlight repairmen repair streetlights on a day-to-day basis. When a 16

streetlight repairman encounters problems he cannot fix on his own, the repairman will request the 17

assistance of a qualified electrical crew, which typically includes linemen and other distribution 18

maintenance personnel. These more complicated repairs may require a maintenance outage, significant 19

time on-site, additional manpower, or additional equipment. The most common streetlight problems 20

requiring qualified electrical workers are (1) conductor breakdowns, (2) structural damage to poles, or 21

(3) multiple, in-line streetlight outages. The volume of these repairs is not impacted by LED conversions 22

or streetlight sales. Because SCE has retained ownership of the electrical infrastructure serving customer 23

streetlights, these repairs will remain the responsibility of SCE. Additionally, a portion of this work is 24

related to streetlight systems that are configured in series and served by regulated output (R/O) 25

transformers. 26

39



40

b) Basis for Capital Expenditure Forecast 1

The forecast for Streetlight Maintenance and LED Conversions36 shown is Figure 2

II-13 includes the costs to perform each of the activities described in section II.F.3.a) above. In Table II-3

8 the cost forecast for each activity is shown. 4

Table II-8 Streetlight Maintenance and LED Conversions

Activity Forecast (Nominal $000)

Table II-9 shows the forecast number of units for each activity and the forecast 5

unit rate in 2018 constant dollars. 6

Table II-9 Streetlight Maintenance and LED Conversions

Activity Forecast Units ($2018 Constant)

(1) Steel Pole Replacements 7

SCE is forecasting to continue replacing steel streetlights. As described 8

previously, these steel streetlights were installed in the 1950s and 1960s and have exceeded their useful 9

life. SCE’s forecast of 10,750 steel streetlight replacements will allow SCE to continue to remove these 10

aged assets from the system and replace them with concrete streetlights. 11

36 Refer to WP SCE-02, Vol. 1, Pt. 2, pp. 72-73 – Streetlight Maintenance and LED Conversions – 2021.

2019 2020 2021 2022 2023Activity

Steel Pole Replacements 16,908$ 13,172$ 18,945$ 19,493$ 20,054$ Fixture Replacements 2,609 1,807 1,492 1,151 789 LED Conversions 29,079 28,609 22,262 22,906 23,565 Smart Sensors 935 1,618 3,339 3,436 3,535 Minor Capital Maintenance 3,453 3,414 4,302 5,154 5,420 Total 52,984$ 48,619$ 50,342$ 52,152$ 53,372$

2019 2020 2021 2022 2023Activity Unit Rate

Steel Pole Replacements 7,400$ 2,200 1,650 2,300 2,300 2,300 Fixture Replacements 335 7,500 5,000 4,000 3,000 2,000 LED Conversions 400 70,000 66,300 50,000 50,000 50,000 Smart Sensors 150 6,000 10,000 20,000 20,000 20,000

40



41

(2) Fixture Replacements 1

Streetlight fixtures fail at a rate of approximately 0.2% each year. SCE is 2

requesting funding to perform fixture replacements on its forecast of HPSV inventory of LS-1 3

streetlights. Because the new LED fixtures have an expected useful life of twenty years there is no 4

forecast for replacement of these fixtures in SCE’s request. 5

(3) LED Conversions 6

SCE is forecasting to continue to convert LS-1 streetlights to LED under 7

its LS-1 Option E tariff. The proposed forecast will leave less than 75,000 HPSV lights on SCE’s system 8

at the end of 2023. This funding will allow cities to convert to this lower-cost, more energy-efficient 9

lighting technology. 10

(4) Smart Sensors 11

As described in II.F.3.a)(4) SCE is proposing to install a modest number 12

of smart streetlight sensors over the next five years. These smart sensors will be installed on the 13

streetlight fixtures prior to installation resulting in no incremental cost for labor. The cost for the smart 14

sensor includes the cost to monitor the streetlight. This program will provide SCE’s streetlight 15

customers with information they desire regarding outages, electricity usage, location, and technology. 16

Customers will also have more control over their electricity usage through the smart sensor’s ability to 17

decrease or increase lighting intensity. 18

(5) Minor Capital Maintenance 19

SCE is requesting $21.745 million for streetlight maintenance during the 20

years 2019-2023. SCE’s street lighting system, especially its series streetlights, require on-going 21

maintenance to the electrical infrastructure serving streetlights. SCE is responsible for maintaining the 22

infrastructure that serves over 800,000 streetlights within its system, regardless of ownership of the 23

lights. SCE is requesting $16.662 million for 2019-2023 to perform this maintenance on the system. 24

SCE is requesting additional funding of $5.082 million over 2019-2023 to 25

rebuild its series street lighting systems. These systems were designed and constructed using R/O 26

transformers which provide the same level of voltage to each streetlight connected to it. This technology 27

is no longer supported by manufacturers and as a result SCE must rebuild these systems to current 28

standards. 29

41



42

III. 1

CAPITAL-RELATED EXPENSE & OTHER 2

This BPE includes costs necessary to support SCE’s distribution grid and personnel. These costs 3

are not charged to specific capital or O&M activities because they provide overall support to the entire 4

distribution organization and workforce. This testimony includes Distribution Support Activities, Tools 5

and Work Equipment, Prefabrication, and Distribution Transformers. 6

A. 2018 Decision 7

1. Comparison of Authorized 2018 to Recorded 8

Figure III-15 shows the 2018 request, authorized, and recorded costs for O&M activities 9


42



43

Figure III-15 Capital Related Expense & Other O&M Expenses37


Distribution Support Activities was $2.522 million above authorized in 2018 due to 1

SCE’s Electric Asset Record Accuracy (EARA) program focused on data validation of GIS equipment 2

data used in the inspection, maintenance, repair, and construction of distribution assets. 3

Figure III-16 shows the 2018 request, authorized, and recorded costs for O&M activities 4


37 Refer to WP SCE-07, Vol. 01 – Authorized to Recorded.

$15,759.2 $15,655.1

$18,176.9 $2,522

0

2,000

4,000

6,000

8,000

10,000

12,000

14,000

16,000

18,000

20,000

2018 Request 2018 Authorized Distribution SupportActivities

2018 Recorded

Distribution Support Activities

43



44

Figure III-16 Capital Related Expense & Other Capital38


Distribution Transformers was $9.396 million below authorized in 2018 due to lower 1

spend in capital activities requiring transformers. Prefabrication was over authorized by $2.230 million 2

due to increase in work requiring pre-assembling of materials. 3

B. O&M Forecast 4

1. Distribution Support Activities 5

The recorded and forecast expenses for Distribution Support Activities are shown in 6

Table III-10. 7

38 Refer to WP SCE-07, Vol. 01 – Authorized to Recorded.

($1,632)

($9,396 )

$2,230

$121,469 $115,653

$106,856

0

20,000

40,000

60,000

80,000

100,000

120,000

140,000

2018 Request 2018 Authorized Tools and WorkEquipment

Transformers Prefabrication 2018 Recorded

Tools and Work Equipment Transformers Prefabrication

44



45

Table III-10 Distribution Support Activities O&M Expenses39



Distribution Support Activities includes work activities that are necessary to 2

support SCE’s construction crews working on the distribution system. These costs are relatively varied 3

but all are more efficiently charged to expense rather than allocating to all work activities. These costs 4

include: Information Technology (IT) chargebacks; Field Accounting Organization (FAO) O&M 5

Activities; Distribution Analytics; Stand-by Time; Underground Civil Inspection O&M Activities; Real 6

Properties (RP) O&M Activities; Mapping & Spatial Data Analytics; Informational Meetings, and the 7

Reliability Operations Center (ROC). Table III-11 shows SCE’s test year request for each activity 8

includes in Distribution Support Activities. 9

39 Refer to WP SCE-02, Vol. 01, Pt. 2, pp. 74-80 – O&M detail for Distribution Support Activities.

2014 2015 2016 2017 2018 2019 2020 2021Labor $8,834 $7,202 $7,326 $8,122 $9,054 $9,228 $8,097 $8,097

Non-Labor $12,997 $5,756 $7,221 $10,044 $9,102 $6,892 $3,356 $3,356Other $10 $20

Total Expenses $21,831 $12,958 $14,546 $18,176 $18,177 $16,119 $11,453 $11,453


Recorded Forecast

$5,000

$10,000

$15,000

$20,000

$25,000

2014 2015 2016 2017 2018 2019 2020 2021


45



46

Table III-11 Distribution Support Activities40

2021 Test Year Request (Constant 2018 $000)

(1) Information Technology (IT) Chargebacks 1

Information Technology (IT) Chargebacks include the costs incurred by 2

the Distribution Business Line for various communication equipment and usage charges. The equipment 3

and usage charges include smart phones, SCE internal landline service, computer and computer access 4

charges, wireless charges, and laptop connectivity charges. These charges are “charged back” to the 5

Distribution Business Line by SCE’s Information Technology organization. These communication costs 6

are necessary for field and office employees to effectively communicate and access on-line data 7

necessary for performing their daily work. 8

(2) Field Accounting Organization (FAO) O&M Activities 9

The Field Accounting Organization (FAO) provides accounting support to 10

distribution field crews. FAO personnel primarily support capital work order processing, but also spend 11

a portion of their time performing O&M activities, such as timesheet entries on behalf of field crews, 12

ordering and stocking construction supplies and tools, and other administrative duties. The O&M 13

activities performed by FAO personnel are necessary to provide accurate timekeeping for construction 14

personnel and to maintain supply and tool inventories for SCE’s field crews. 15

40 Refer to SCE-02, Vol. 01, Pt. 2, pp. 81-82 – Distribution Support Activities – 2021.

Activity Name2021

Request

Information Technology (IT) Chargebacks 1,270$ Field Account Organization (FAO) O&M Activities 757$ Distribution Analytics 180$ Stand-By Time 1,480$ Underground Civil Inspection O&M Activities 390$ Real Properties (RP) O&M Activities 119$ Mapping & Spatial Data Analytics 1,524$ Informational Meetings 3,242$ Reliability Outage Center (ROC) 2,493$ Distribution Support Activities Total 11,453$

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47

(3) Distribution Analytics 1

SCE’s Distribution Analytics group performs data analysis on information 2

collected during planned and unplanned inspections and maintenance activities. This analysis is used to 3

identify trends or patterns in equipment behavior and to develop predictive modeling to assist in the 4

development of more effective equipment maintenance practices. This activity allows SCE to 5

incorporate data modeling of distribution equipment to assist in the identification and development of 6

improved maintenance practices. 7

(4) Stand-By Time 8

Stand-By Time is distribution field crew labor costs incurred when crews 9

are held at the end of a workday in anticipation of potential after-hours emergency work. This occurs 10

when SCE anticipates increased resource requirements due to an approaching storm or when troublemen 11

are responding to emergencies that may require distribution field crews to make repairs or restore 12

service. In these circumstances, crews “stand-by” in the service center until work is assigned or it is 13

determined that their response will not be required. Holding crews at the end of their shift is more cost 14

effective than releasing crews to go home and then calling them back for the emergency work. 15

(5) Underground Civil Inspection O&M Activities 16

Underground civil inspectors are responsible for inspecting underground 17

duct installations prior to the installation of electrical cable and equipment. This underground duct is 18

installed by applicants and deeded to SCE upon completion. Underground civil inspectors charge their 19

labor to the capital project when performing inspections. When the underground civil inspectors are 20

reviewing maps, schematics, designs, construction standards, and performing other administrative duties 21

their labor is charged to expense. The Underground Civil Inspection O&M Activities are necessary for 22

SCE to perform the inspection of all civil work installed on the electric system prior to energization to 23

ensure the construction meets SCE’s design requirements and standards. 24

(6) Real Properties O&M Activities 25

SCE’s Real Properties Organization is responsible for obtaining and 26

maintaining permits, easements, rights-of way, and purchases of land where SCE places its assets and 27

lines. Real Properties O&M Activities includes the costs to review existing land rights to maintain 28

compliance and review requests from external parties to use SCE’s land. The costs for Real Properties 29

O&M Activities includes document procurement costs, recording fees, and other costs associated with 30

the acquisition and maintenance of land rights. 31

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48

(7) Mapping & Spatial Data Analytics 1

Mapping & Spatial Data Analytics includes the costs required to maintain 2

SCE asset records in Geographical Information System (GIS) format. Maintaining accurate asset data is 3

critical to the safety of SCE personnel and the public. The GIS data provides information to field 4

personnel which allows them to identify the source of electricity for each piece of electrical equipment 5

in order to safely energize or de-energize sections of SCE’s distribution grid to perform construction, 6

maintenance, or other types of work on the system while minimizing the frequency and duration of 7

customer interruptions. Maps and spatial data are also used to identify line sections and customers 8

affected by planned and unplanned outages for outage reporting required by the CPUC. 9

For SCE crews to work safely and to operate the distribution grid, maps 10

and spatial data must be updated accurately and timely whenever a change is made to the grid. To 11

maintain mapping and spatial data accuracy, SCE personnel work closely with SCE’s distribution and 12

substation construction and maintenance organizations and SCE’s engineering personnel to update maps 13

following structure and equipment replacements, the addition of new equipment, and the creation of new 14

circuits. Depending on the complexity of the system changes, updates can take a few minutes of work to 15

multiple hours in the most complex of instances. 16

SCE’s mapping and spatial data allows SCE to “overlay” information such 17

as high fire areas, schools, roadways, or parks to identify equipment located in or near these areas. This 18

spatial data allows SCE personnel to visually identify structures near or in specific areas or spaces. 19

Having accurate and GIS based structure and equipment data provides SCE with information to quickly 20

identify and target specific assets based on their location on the system and relative to other landmarks. 21

Maps and spatial data are also integral in SCE’s inspection and maintenance programs, providing the 22

location of each piece of equipment or structure requiring an inspection or maintenance. 23

(8) Informational Meetings 24

SCE must share information with employees in a timely manner. The 25

majority of employees in T&D’s Distribution Organization are represented employees who perform 26

their work outside of an office setting. These field employees are not issued a company computer and do 27

not have ready access to electronic company communication. Informational meetings are held on both a 28

periodic and an ad hoc basis to share information with these field employees. Periodic meetings are held 29

to share information about SCE or T&D, such as goals, performance, or employee concerns. Ad hoc 30

meetings are held as various employee, work location, organizational unit, or company issues arise. Ad 31

48



49

hoc meetings are held to cover information such as new or updated company policies, procedures, and 1

programs; new or updated governmental regulations; proper use of existing tools; and the introduction of 2

new tools and work methods. 3

(9) Reliability Outage Center (ROC) 4

In 2018, SCE formed the Reliability Operations Center (ROC) to pursue 5

the use of data science and advanced analytics to enhance trouble shooting of the distribution grid and to 6

improve safety, reliability, and customer experience. The ROC develops new diagnostics to understand 7

grid conditions and to support real-time operations using situational awareness, remote diagnostics, and 8

data-driven decision making. The ROC collaborates with substation operations, distribution, and 9

engineering to provide real-time troubleshooting and analytical support.41 The ROC is continuously 10

staffed to provide support at all hours. 11

This work is essential to reducing hazardous conditions for the public and 12

improving reliability of the distribution grid through more rapid response to outages. ROC personnel use 13

smart meter and other smart device data to analyze the distribution grid. This data has been used to 14

develop machine-learning applications that speed-up and improve decision making. An example of an 15

application developed by ROC is the “meter alarming downed energized conductor” algorithm which 16

has successfully demonstrated the capability of detecting up to 40% of energized wire-downs within 17

minutes of occurrence. The successful implementation of this type of analysis will enable SCE to safely 18

de-energize a circuit and deploy field crews to perform restoration. This algorithm is continuously 19

monitoring circuits for this condition. The ROC also uses its “early damage detection” algorithm to 20

detect transformers on the verge of failure. This algorithm allows SCE to target transformer 21

replacements to avoid an in-service failure and reduce the impact to customers. 22



The recorded costs in Distribution Support Activities decreased from 2014 25

to 2015 by approximately $8M due to a re-organization. This re-organization moved T&D’s Business 26

Planning & Technology Integration (BPTI) organization to IT. From 2015 to 2016 costs increased by 27

approximately $1M as SCE began its Electric Asset Record Accuracy (EARA) project at the end of 28

41 A portion of the SmartConnect Operations Center (SOC) was moved to the ROC in 2018 during an internal

reorganization. See SCE-02, Vol. 1-Meter Activities for more detail.

49



50

2016. In 2017, costs increased again by approximately $7M as work continued on EARA. Costs in 2018 1

declined by approximately $1M due to a reduction in IT Chargebacks. 2


The test year forecast for Mapping & Spatial Data Analytics is $1.524 4

million. This is $6.723 million lower than 2018 recorded. The funding is necessary to continue to 5

maintain the data in SCE’s GIS database to provide accurate information on the location of all assets. 6

SCE’s test year forecast for all other Distribution Support Activities is last 7

year recorded. SCE expects costs in these areas to remain constant over the next five years and 2018 8

recorded amounts will be sufficient to provide the same level of support to construction and field 9

personnel. 10

C. Capital Expenditures 11

1. Tools and Work Equipment 12


in Figure III-17. 14

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51

Figure III-17 Distribution Tools and Work Equipment42

Multiple CWBS Elements43 Recorded (2014-2018)/Forecast (2019-2023)



This capital category includes the cost to purchase portable tools and specialized 2

test equipment used by distribution personnel when performing work on SCE’s distribution grid. These 3

expenditures are for tools or equipment costing more than $1,000 each: examples include electric, 4

pneumatic and hydraulic power tools; electric generators for use by SCE personnel when performing 5

work on the distribution grid; cable pulling equipment; impulse test sets; power system analyzers; 6

vibration analysis data packs; and volt meters. 7

The tools and equipment are required for SCE to complete the work on the grid in 8

the most safe, reliable and efficient manner possible. These tools and equipment are important for the 9

successful execution of all current and future work on the grid. As tools and work equipment wear-out 10

42 Refer to WP SCE-02, Vol. 01, Pt. 2, pp. 83-86 – capital detail for Distribution Tools and Work Equipment.

43 Tools and Work Equipment includes CWBS Elements CCS-00-SE-CO, CET-ET-MS-SE, CET-OT-OT-SD, CET-PD-OT-DL, CET-PD-MS-SE, and CET-PD-OT-DT.

2014 2015 2016 2017 2018 2019 2020 2021 2022 2023

Nominal $5,484 $3,789 $3,970 $3,497 $3,256 $3,325 $3,376 $3,430 $3,483 $3,546

$1,000

$2,000

$3,000

$4,000

$5,000

$6,000

Forecast

51



52

or break and need to be replaced, it is necessary to purchase new or refurbish the existing equipment to 1

keep SCE’s personnel properly equipped. 2


Tools and work equipment expenditures have varied during the 2014-2018 4

historical period. This variation is driven by the volume of tools and work equipment purchased for new 5

work methods or new construction methods. It is also driven by the replacement and refurbishment of 6

existing tools and equipment due to wear and tear. Because spending from 2014 to 2018 has fluctuated, 7

but has also followed a downward trend, SCE proposes 2018 last year recorded as the forecast for Tools 8

and Work Equipment for the period 2019-2023. Last year recorded will provide SCE with the funding 9

necessary to keep crews equipped to safely and effectively perform work on the system. 10

2. Prefabrication 11

Prefabrication includes costs for SCE’s Distribution Pole Loading Program as well as the 12

Prefabrication costs for all other capital work performed on the distribution grid. The recorded costs for 13

2014 through 2018 and forecast costs for 2019 through 2023 are shown in Table III-12. 14

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53

Table III-12 Prefabrication44

CWBS Element CET-PD-OT-PF Recorded (2014-2018)/Forecast (2019-2023)



Each of SCE’s 34 district service centers has a prefabrication operation 2

responsible for staging material for the construction crews, assembling prepackaged kits, and properly 3

disposing of materials removed from jobsites. 4

Staging material involves receiving shipments from SCE or manufacturer 5

warehouses, performing material validation, and placing the delivered items in storage bays until the 6

material is loaded onto the construction crews’ trucks on the day of the job. Tracking shipments and 7

ordering materials for unplanned jobs is also one of the responsibilities of the prefabrication 8

organization. 9

44 Refer to WP SCE-02, Vol. 1, Pt. 2, pp. 87-89 – Capital detail for Prefabrication.

2014 2015 2016 2017 2018 2019 2020 2021 2022 2023

Nominal $12,895 $13,692 $13,659 $15,183 $16,789 $18,946 $18,843 $22,398 $23,046 $23,709

$5,000

$10,000

$15,000

$20,000

$25,000

Forecast

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54

Assembling kits is the process of gathering construction materials maintained in 1

inventory in the district for construction or maintenance jobs. This process also includes assembling 2

items into a product installed as a single unit. For example, rather than taking three individual 3

transformers to a jobsite and installing them one at a time, the prefabrication group will mount them on a 4

bracket and perform the wiring at the service center. Assembling the material in the service center yard 5

is safer and more efficient than performing the work at the jobsite where there may not be adequate 6

space, specialized tools, or easy access to extra material. By pre-assembling the transformer bank in the 7

yard, the crew then can install the complete “bank” of three transformers as one unit at one time. 8

Properly disposing of removed materials is critical to the electrical construction 9

process. SCE routinely remove many items installed decades ago and which have various requirements 10

related to proper disposal. The prefabrication employees are the service center experts in the 11

environmental compliance processes required to safely dispose of and salvage electrical waste. 12

Prefabrication activities provide distribution crews with the materials needed for 13

daily construction or maintenance work. Rather than having each crew spend time at the warehouse 14

every day trying to gather the equipment and parts needed to execute the work, prefabrication 15

streamlines this for them. This allows SCE to use a less expensive resource to manage and stage 16

materials while using qualified electrical workers to construct and maintain the system. The immediate 17

and long-term impact of eliminating prefabrication would be a reduction in construction and 18

maintenance work completed as qualified electrical workers would perform the prefabrication activities. 19

b) Basis for Capital Expenditure Forecast45 20

Expenditures for Prefabrication support the work performed by distribution crews 21

based out of SCE’s service centers. For Distribution Pole Loading Program Prefabrication SCE is 22

proposing to use 2.83% of the forecast for Distribution Pole Loading Program Replacement program. 23

For non-PLP Prefabrication costs, SCE is proposing last year recorded as the forecast. This request will 24

provide the necessary funding to continue to provide material and assembly support to SCE’s 25

distribution crews. This funding will allow SCE to continue to utilize a lower cost resource to manage 26

inventory and material while allowing SCE’s qualified electrical workers to perform construction and 27

maintenance work on the distribution grid. 28

45 Refer to WP SCE-02, Vol. 01, Pt. 2, pp. 90-91 – Prefabrication – 2021.

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55

3. Distribution Transformers 1


in Figure III-18. This activity includes three sub-activities: (1) transformers for routine, on-going 3

programs; (2) transformers installed in concert with the PLP; and (3) transformers installed as part of the 4

Wildfire Covered Conductor Program (WCCP). 5

Figure III-18 Distribution Transformers Capital Expenditure Summary46

WBS Element CET-PD-OT-TR47 Recorded 2014-2018 / Forecast 2019-2023



T&D capitalizes distribution transformers rated less than 500kVA at the time of 7

purchase.48 SCE installs and removes a large volume of transformers on a regular basis. The work 8

performed in many of SCE’s distribution capital programs require the installation or replacement of 9

transformers. These programs include, for example, new service connections, distribution preventive 10

46 Refer to WP SCE-02, Vol. 01, Pt. 2, pp. 92-94 – Capital detail for Distribution Transformers.

47 Distribution Transformers includes CWBS Elements CET-PD-OT-TR and CET-PD-OT-TR-PL.

48 Code of Federal Regulations (CFR) 18.

2014 2015 2016 2017 2018 2019 2020 2021 2022 2023

Nominal $83,562 $92,355 $91,360 $103,298 $86,811 $94,606 $94,460 $100,136 $103,644 $106,625

$20,000

$40,000

$60,000

$80,000

$100,000

$120,000

Forecast

55



56

and breakdown maintenance, and claims. These transformer purchases provide an inventory which 1

allows SCE to have the necessary equipment available to perform construction work and to replace 2

failed or deteriorated transformers. 3

For example, SCE replaces distribution transformers when they fail in service, or 4

when they show deterioration based on inspections or other fieldwork. Deterioration includes leaks, 5

corrosion, and damage caused by vehicle collisions or acts of nature. When SCE replaces a pole or 6

conductor, it may be cost-effective to replace the attached transformer at the same time, depending on 7

the condition of the transformer. 8

Similarly, during new construction to serve new customers, or when converting 9

overhead lines to underground, distribution transformer installations accompany the installation of poles, 10

cables, and underground structures. 11

In addition to the material cost for the transformer, this capital activity includes 12

associated costs such as waste removal, material retirement/cleanup, material testing, and transformer 13

coatings. The labor to install and remove the transformer from SCE’s system is charged to the capital 14

program for the specific work activity. 15


Figure III-18 shows the forecast expenditure summary for the 2019-2023 period 17

for purchasing transformers to support distribution capital work. As explained previously, transformer 18

purchases are dependent on the specific type of distribution capital work being performed. Based on data 19

collected from completed work orders from 2014-2018, SCE identified the distribution activities that 20

required either the installation or replacement of a transformer less than 500kVA. SCE used this work 21

order data to calculate the number of transformers installed or replaced by each distribution activity 22

type.49 23

To develop the transformer forecast for each activity, SCE used the forecast 24

capital expenditures for each work activity and the total count of transformers for the same activity. The 25

transformer acquisition cost multiplied by the total count of transformers for each activity and each year 26

for 2019-2023 provide the total transformer expenditure forecasts. 27

An example for the Residential New Service Connections is shown in Table III-28

13. Using the data from completed work orders, SCE calculated the need for one transformer for every 29

49 Refer to WP SCE-02, Vol. 01, pp. 95-98 – Distribution Transformers – 2021.

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57

$48,000 spent in Residential New Service Connections. The cost of acquiring transformers for this 1

activity is approximately $3,220 per unit. 2

Table III-13 Transformer Forecast for Residential New Service Connections

Forecast 2019-2023 (Total Company - Constant 2018 $000)

In this example, the forecast count of transformers per year is calculated by 3

dividing the capital expenditure forecast for Residential New Service Connections for 2019-2023 by the 4

average spend per transformer. The total expenditures for transformers in support of Residential New 5

Service Connections is the quantity of transformers forecast multiplied by the total unit cost of the 6

transformer as shown above. 7

SCE forecasts the total cost for transformer purchases needed to perform 8

replacements and installations for all activities based on the transformer quantify forecasts and the 9

transformer unit cost for each activity. As shown in Figure III-18, SCE forecasts the annual expenditures 10

to range from $99.4 million and $131.1 million between 2019 and 2023 in nominal dollars. The increase 11

in forecast is primarily due to increase in work volumes such as Distribution Grid Inspections and 12

Maintenance discussed earlier in this exhibit, System Augmentation New Service Connections discussed 13

in SCE-02, Volume 4, and Transportation Electrification - Charge Ready Program.50 14

SCE’s proposal for Distribution Transformers reflects the reductions to 15

Distribution Preventive and Breakdown Capital Maintenance described in II.C.2.c)(2)(b) above. If 16

SCE’s Enhanced Overhead Inspection program, as proposed in Exhibit SCE-04, Volume 5, is not fully 17

funded SCE will need to restore the funding for transformers used in Distribution Preventive and 18

Breakdown Maintenance as shown in Table III-14. 19

50 SCE is not seeking recovery of Transportation Electrification - Charge Ready Program in the 2021 General

Rate Case, however, this program utilizes distribution transformers as part of the program's operations.

Activity Forecast ($000) - Constant 2018 Transformer Unit ForecastD Transformer 580 Program Forecast ($000) -

Constant 2018

Work Activity WBS

Activity Spend Per Transformer

($000)Price Per

Transformer 2019 2020 2021 2022 2023 2019 2020 2021 2022 2023 2019 2020 2021 2022 2023

Residential New Service Connections

CET-PD-NS-RS 48$ 3,223$ 123,485$ 127,615$ 134,567$ 142,091$ 141,237$ 2,564 2,649 2,794 2,950 2,932 8,261$ 8,537$ 9,002$ 9,506$ 9,449$

57



58

Table III-14 Transformer Requirements for

Distribution Preventive and Breakdown Capital Maintenance Forecast Calculations for EOI51

(Nominal $000)

For Distribution Pole Loading Program transformers SCE is proposing to use 1

4.17%52 of the forecast for Distribution Pole Loading Program Replacement program to forecast PLP 2

transformers.53 3

c) Wildfire Covered Conductor Program (WCCP) Transformers 4

The forecast for transformers to support SCE’s WCCP is shown in Figure III-19 5

and described in SCE-04, Vol. 5. These transformers will be replaced in concert with the installation of 6

covered conductor in SCE’s HFAs. SCE currently replaces distribution transformers across its grid due 7

to failures or near failures. To develop the forecast for WCCP Transformers, SCE calculated the average 8

failure rate for transformers across the SCE system and then applied this percentage to the transformers 9

in the HFA. Next, SCE calculated the forecast of transformers to be replaced in the HFA due to failures 10

or near-failures. This forecast was removed from the total transformer forecast for WCCP Transformers 11

to eliminate the duplication of transformers in both the Distribution Preventive and Breakdown 12

Maintenance and WCCP forecasts.54 13

51 Refer to WP SCE-02, Vol. 1, Pt. 2, pp. 99-100 – Distribution Preventive and Breakdown Maintenance

Transformers – 2021.

52 See SCE Preliminary Statement, Part J.

53 Refer to WP SCE-02, Vol. 1, Pt. 2, pp. 101 - 102 – PLP Transformers – 2021.

54 Refer to WP SCE-0w, Vol. 1, Pt. 2, pp. 103-105 – Wildfire Covered Conductor Program Transformers – 2021.

2019 2020 2021 2022 2023Transformers Required for Preventive & Breakdown Maintenance 43,544$ 43,215$ 44,590$ 45,880$ 47,199$

Transformer Reduction for EOI Performed in HFA (1,969) (5,893) (7,692) (9,471) (11,381) Transformers Required With EOI Funded 41,575$ 37,322$ 36,898$ 36,409$ 35,818$

Forecast

58



59

Figure III-19 Wildfire Covered Conductor Program Transformers

WBS Element CET-PD-OT-TR-WF55 Recorded 2014-2018 / Forecast 2019-2023


1

55 Refer to WP SCE-02, Vol. 1, Pt. 2, pp. 106-107 – Capital detail for Wildfire Covered Conductor Programs

Transformers.

2014 2015 2016 2017 2018 2019 2020 2021 2022 2023

Nominal $1,131 $3,784 $5,107 $5,582 $6,303

$1,000

$2,000

$3,000

$4,000

$5,000

$6,000

$7,000

Forecast

59



60

IV. 1

SAFETY AND RELIABILITY INVESTMENT INCENTIVE MECHANISM (SRIIM) 2

A. Background 3

The SRIIM is a mechanism which the Commission has previously adopted to incentivize SCE to 4

spend authorized dollars on programs that support safety and reliability, and to maintain a workforce of 5

field employees to support the safe and reliable operation of the electric grid. SCE has implemented 6

some form of SRIIM since the early 2000s (although it was not always called “SRIIM”). While this 7

mechanism was initially focused on reliability, the Commission expanded its scope to also include 8

safety. SRIIM replaced previous reliability mechanisms that had focused solely on reliability metrics. 9

Those reliability metrics were based on indicators largely beyond the control of the utility in the short 10

run and did not provide incentives for long-term investment in grid reliability. 11

SRIIM is composed of two components: 12

(1) Hiring field personnel that directly work on projects and programs related to safety and 13

reliability; and 14

(2) Capital investment on projects and programs for safety and reliability. 15

In SCE’s 2018 GRC, the Commission adopted a modified version of SCE’s proposal for SRIIM, 16

which implemented certain changes to the SRIIM as compared to the 2015 GRC. These changes were to 17

both the workforce and capital investment components of SRIIM. 18

1. Workforce 19

The Commission adopted the following changes to the workforce component of SRIIM: 20

(1) Added troubleman trainer and operator trainee classifications to the workforce 21

headcount targets; 22

(2) Adopted SCE’s proposed headcount target of 2,375, subject to adjustment by one-half 23

the percentage change in requested versus authorized T&D capital in the 2018 GRC; and 24

(3) Adopted method to measure headcount as an average of the last quarter of 2020. 25

2. Capital Investments 26

The Commission also adopted revisions to the capital investment component of SRIIM, 27

including: 28

60



61

(1) Added SCE’s Overhead Conductor Program (OCP), 4 kilovolt (kV) Overload-Driven 1

Cutovers, and 4 kV Substation Elimination programs to the previously established SRIIM;56 2

(2) Established SRIIM capital expenditure targets based on the level of capital 3

expenditures that the Commission authorized in the 2018 decision; and 4

(3) Adopted a provision that any spending occurring in the High Priority categories57 in 5

excess of authorized amounts can be used to achieve the targets established for the SRIIM capital 6

categories (only when certain conditions are met). 7

B. 2021 SRIIM Proposal 8

As a matter of principle, safety and reliability of the electric system guide SCE’s resource 9

investments and operations. A strong and capable workforce of field employees is required to make this 10

happen. Accordingly, SCE plans to continue to hire front-line employees and grow its field workforce so 11

that SCE can perform the necessary work to maintain a safe and reliable power grid. 12

SCE recommends the Commission continue the SRIIM as adopted in SCE’s 2018 GRC, with 13

certain modifications. For the 2021 GRC, SCE proposes the following changes to the workforce and 14

capital investment components of the SRIIM: 15

1. Workforce 16

SCE proposes changes to the workforce categories, headcount target, and measurement 17

of headcount as part of this GRC. 18

a) Workforce Categories 19

SCE proposes to maintain the SRIIM workforce classifications adopted by the 20

Commission in SCE’s 2018 GRC, with two exceptions: (1) Since SCE does not have the positions of 21

Distribution Apprentice Groundman or Transmission Apprentice Groundman, SCE proposes to remove 22

these positions from the workforce categories. (2) SCE proposes to add two job classifications to the 23

headcount component: Distribution Apparatus Technician and Distribution Apparatus Foreman. In 24

summary, SCE proposes to continue the SRIIM headcount mechanism with the job classifications 25

identified in Table IV-15 below. 26

56 These programs adopted in the 2015 GRC Decision include SCE’s Worst Circuit Rehabilitation, Cable Life

Extension, Cable-in-Conduit Replacement, Circuit Breaker Replacement, Substation Transformer Replacement, Underground Switch Replacement, and Underground Structure Replacement programs.

57 High Priority categories include Customer Growth, Storm, and Claims programs.

61



62

Table IV-15 Proposed SRIIM Headcount Classifications

b) Headcount Target 1

SCE’s frontline workforce is critical to providing safe and reliable service to 2

customers. SCE proposes to continue the SRIIM headcount target with minor adjustments to the existing 3

mechanism. SCE proposes to increase the SRIIM headcount target in this GRC above previously 4

adopted levels to 2,465 workers. This represents a larger increase than what was requested in the 2018 5

GRC,58 commensurate with the necessary growth required to meet the safety and reliability objectives 6

presented in this GRC. These positions would be composed of workers holding the classifications 7

identified in Table IV-15. If SCE fails to achieve the headcount target, SCE agrees to refund customers 8

in the same manner as approved in the 2018 SRIIM (i.e. SCE would refund $20,000 for each employee 9

shortfall relative to the target, up to 50 employees short, and $80,000 per employee thereafter). As the 10

Commission adopted in the 2018 GRC, SCE proposes to continue with the necessary mechanism to 11

adjust the target headcount level by one-half the percentage change in requested versus authorized T&D 12

capital in the 2021 GRC.59 13

58 In SCE-02, Vol. 01 of its 2018 GRC, SCE requested an initial SRIIM headcount target of 2,375. In D.19-05-

020, the Commission adopted this level, along with a mechanism to adjust this level according to authorized capital spending. This resulted in an adjusted-authorized SRIIM target of 2,175 workers.

59 SCE also notes that achieving the headcount target is contingent upon receiving full funding for T&D Training and Delivery O&M costs, as presented in SCE-06, Vol. 3, Pt. 1.

62



63

c) Measurement 1

The headcount in any job classification can vary with short notice. Backfilling 2

with qualified candidates takes time, especially in the current labor market. Therefore, SCE proposes to 3

modify the headcount measurement mechanism. The current mechanism determines SCE’s SRIIM 4

headcount based on an average over the last quarter of 2020 for the 2018 GRC cycle. SCE proposes that 5

the measurement be modified to account for achieving the headcount level at some point in the last two 6

quarters of the GRC cycle. Specifically, if SCE’s SRIIM headcount exceeds the target level at any time 7

during the period of July 1, 2023 through December 31, 2023, SCE will be deemed to have satisfied the 8

workforce component of SRIIM. This modification will allow SCE flexibility to respond to unexpected 9

attrition should it occur at the very end of the cycle. 10

2. Capital Investments 11

SCE recommends the Commission continue the capital investment component of the 12

SRIIM mechanism, with modifications detailed below, for the 2021 GRC. The Commission adopted the 13

SRIIM to motivate improvements to reliability through investment in the electric grid. It subsequently 14

expanded the mechanism to also include safety spending to help ensure SCE spends toward authorized 15

amounts for select safety and reliability programs. As previously mentioned, SCE is principally focused 16

on safety and reliability, and therefore inherently motivated to invest in programs that improve the safety 17

and reliability of SCE’s electric system. This complements the Commission’s actions over the past few 18

years to establish formal proceedings and mechanisms to further focus on safety and reliability. For 19

example, the Commission established the Safety Model Assessment Proceeding (S-MAP) which has, 20

and continues to develop, various models, frameworks, and reporting requirements to identify and 21

evaluate safety and reliability risks facing utilities and the public.60 22

While the GRC process is SCE’s primary mechanism to request funding for work to be 23

performed in the future, SCE cannot wait for a GRC decision to address emergent safety and reliability 24

issues. Accordingly, the Commission has instructed SCE to “respond to immediate or short-term crises 25

outside of the RAMP and GRC process,” noting that, “the RAMP and GRCs follow a three-year cycle 26

and are not designed to address immediate needs; the utilities have responsibility for addressing safety 27

60 Please see A.15-05-002. Through the S-MAP proceeding, SCE is required to provide an accounting of safety

and reliability spending against Commission-authorized levels. This is done through an annual report filed with the Commission – the Spending Accountability Report (SAR) – which provides a program-by-program accounting of authorized versus recorded spending for safety, reliability, and maintenance programs.

(Continued)

63



64

regardless of the GRC cycle.”61 As the Commission correctly recognizes, SCE must act expeditiously to 1

address emergent risks that cannot wait for the completion of RAMP and GRC processes. 2

Consistent with this guidance, SCE recommends the following change to the SRIIM 3

capital component to provide SCE with some flexibility to reasonably address emergent safety and 4

reliability risks and unexpected customer requests. SCE proposes that any underspend in the SRIIM 5

capital categories62 can be offset by one or more of the following conditions: 6

(1) Spending in excess of 110% of the authorized amount for “High Priority” programs 7

(Storms, Claims, and Customer Driven/Requested work).63 8

(2) Spending above Commission authorized amounts in wildfire mitigation programs that 9

use the same types of resources as those performing SRIIM work.64 10

The capital investment component, with these modifications incorporated, will provide 11

SCE greater flexibility to continue investment in core SRIIM categories while being able to address 12

emergent and unanticipated customer needs and wildfire risks.65 SCE is committed to providing safe and 13

reliable service to its customers as well as continuing its efforts to harden its system against the threat of 14

61 D.16-08-018. INTERIM DECISION ADOPTING THE MULTI-ATTRIBUTE APPROACH (OR UTILITY

EQUIVALENT FEATURES) AND DIRECTING UTILITIES TO TAKE STEPS TOWARD A MORE UNIFORM RISK MANAGEMENT FRAMEWORK, p. 152.

62 SRIIM capital program categories (as adopted in the 2018 GRC Decision and suggested for continuation in this 2021 GRC) include: SCE’s Worst Circuit Rehabilitation (WCR), Cable Life Extension (CLE), Cable-in-Conduit Replacement (CIC), Circuit Breaker Replacement, Substation Transformer Replacement, Underground Switch Replacement, Underground Structure Replacement, Overhead Conductor Program (OCP), 4 kilovolt (kV) Overload-Driven Cutovers, and 4 kV Substation Elimination programs.

63 High Priority capital programs include those in Exhibit SCE-02, Vol. 01, Part 2 (specifically, Distribution Claim, Distribution Transformers); Exhibit SCE-02, Vol. 02 (specifically, Transmission Claims); Exhibit SCE-02, Vol. 02 (specifically, Substation Claims); Exhibit SCE-02, Vol. 04, Part 3 – Chapter II (all New Service Connections programs), and Chapter III (specifically, Relocations, Rule 20 Conversions, and Distribution Added Facilities); Exhibit SCE-04, Vol. 02 (specifically, Transmission/Substation and Distribution Storm Response).

64 This includes capital costs for SCE’s Wildfire Covered Conductor Program and Enhanced Overhead Inspection and Remediation Program (specifically, EOI Capital Expenditures), both of which are presented in Exhibit SCE-04, Vol. 05 – Wildfire Management.

65 SCE notes that emergent and catastrophic risks could come to fruition during the pendency of the 2021 GRC time period, requiring SCE to divert workers and resources from SRIIM programs to help ensure the safety and reliability of the electric system. This could also require shifting resources away from High Priority programs and Wildfire mitigations. In the event this occurs and impacts the achievement of adopted SRIIM capital expenditure targets, SCE anticipates it may be necessary to work with the Commission and parties to ensure SCE is not penalized for prudently mitigating safety and reliability risks to the electric system and customers during extenuating circumstances.

64



65

wildfires. Adoption of the SRIIM with the modifications identified herein will provide the foundation 1

for SCE to commit its resources toward these goals. SCE’s commitment to growing its skilled workforce 2

and targeting highest priority work is reflected in its SRIIM proposal. 3

65

2021 General Rate Case Workpapers SCE-02, Vol. 01, Pt. 2

DOCUMENT PAGE(S)WP SCE-02, Vol. 01, Pt. 2 - Capital Summary for Distribution – Maintenance and Inspection and Capital Related Expense

1 – 3

WP SCE-02, Vol. 01, Pt. 2 – Memo of Understanding 4 – 9WP SCE-02, Vol. 01, Pt. 2 – Overhead Detailed Inspections – 2021 10 – 11WP SCE-02, Vol. 01, Pt. 2 – O&M detail for Distribution Overhead Detailed Inspections

12 – 18

WP SCE-02, Vol. 01, Pt. 2 – O&M detail for Distribution Underground Detailed Inspections

19 – 25

WP SCE-02, Vol. 01, Pt. 2 –Distribution Underground Detailed Inspections – 2021

26 – 27

WP SCE-02, Vol. 01, Pt. 2 – O&M detail for Distribution Preventive and Breakdown O&M Maintenance

28 – 34

WP SCE-02, Vol. 01, Pt. 2 –Distribution Preventive and Breakdown O&M Maintenance – 2021

35 – 37

WP SCE-02, Vol. 01, Pt. 2 – Capital detail for Distribution Preventive and Breakdown Capital Maintenance

38 – 41

WP SCE-02, Vol. 01, Pt. 2 – Distribution Preventive and Breakdown Capital Maintenance – 2021

42 – 43

WP SCE-02, Vol. 01, Pt. 2 – O&M detail for Patrolling and Locating Trouble O&M Expenses

44 – 50

WP SCE-02, Vol. 01, Pt. 2 – O&M detail for Distribution Apparatus Inspection and Maintenance

51 – 57

WP SCE-02, Vol. 01, Pt. 2 – Capital detail for Distribution Claim 58 – 59WP SCE-02, Vol. 01, Pt. 2 – Distribution Claim – 2021 60 – 61WP SCE-02, Vol. 01, Pt. 2 – O&M detail for Streetlight Operations, Inspections and Maintenance

62 – 68

WP SCE-02, Vol. 01, Pt. 2 – Capital detail for Streetlight Maintenance and LED Conversions

69 – 71

WP SCE-02, Vol. 01, Pt. 2 – Streetlight Maintenance and LED Conversions – 2021

72 – 73

WP SCE-02, Vol. 01, Pt. 2 – O&M detail for Distribution Support Activities

74 – 80

WP SCE-02, Vol. 01, Pt. 2 – Distribution Support Activities – 2021 81 – 82WP SCE-02, Vol. 01, Pt. 2– Capital detail for Distribution Tools and Work Equipment

83 – 86

WP SCE-02, Vol. 01, Pt. 2 – Capital detail for Prefabrication 87 – 89WP SCE-02, Vol. 01, Pt. 2 – Prefabrication – 2021 90 – 91WP SCE-02, Vol. 01, Pt. 2 – Capital detail for Distribution Transformers 92 – 94WP SCE-02, Vol. 01, Pt. 2 – Distribution Transformers – 2021 95 – 98WP SCE-02, Vol. 01, Pt. 2 – Distribution Preventive and Breakdown 99 – 100

DOCUMENT PAGE(S)Maintenance Transformers – 2021WP SCE-02, Vol. 01, Pt. 2 – PLP Transformers – 2021 101 – 102WP SCE-02, Vol. 01, Pt. 2 – Wildfire Covered Conductor Program Transformers – 2021

103 – 105

WP SCE-02, Vol. 01, Pt. 2 – Capital detail for Wildfire Covered Conductor Program Transformers

106 - 107



Workpaper Title:

Capital Summary for Distribution – Maintenance and Inspection and

Capital Related Expense SCE-02, Vol. 1, Pt. 2

1



Southern California Edison - Capital Workpapers

Capital Workpapers Summary

SUMMARY BY GRC Volume

(Nominal $000)

Due to rounding, totals may not tie to individual items.

20152014 2016 2017 2018

437,007 438,854 459,590 473,777 487,927

$240,000

$280,000

$320,000

$360,000

$400,000

$440,000

$480,000

$520,000

Forecast Capital Expenditures Recorded and Authorized Capital Expenditures

Description 20232022202120202019

Authorized Expenditures

Recorded and Forecast Expenditures

Total Expenditures 2,297,156

Forecast Capital Expenditures

2019 2020 2021 2022 2023

Recorded, Authorized and Forecast Expenditures

GRC Activity 5 yr Total

Exhibit: SCE-02 Grid Activities

Volume: Distribution I&M and Capital-Related Volume 1 Pt. 2

348,941 396,835 424,019 442,930 399,902

2023202220212020201920182017201620152014

274,314

2018

Recorded Authorized Forecast

2,012,627

38,879 40,385 41,670 42,875 44,108 Distribution Claim 207,916

280,120 278,006 286,850 295,147 303,636 Distribution Preventive and Breakdown Capital Maintenance 1,443,759

3,325 3,376 3,430 3,483 3,546 Distribution Tools and Work Equipment 17,160

95,737 98,244 105,243 109,226 112,928 Distribution Transformers 521,379

18,946 18,843 22,398 23,046 23,709 Prefabrication 106,943

487,927 473,777 459,590 438,854 437,007 GRC Total 2,297,156

2



Southern California Edison - Capital Workpapers

Capital Workpapers Summary

SUMMARY BY GRC Volume

(Nominal $000)


20152014 2016 2017 2018

52,984 48,619 50,342 52,152 53,372

$20,000

$30,000

$40,000

$50,000

$60,000

$70,000

$80,000

$90,000

Forecast Capital Expenditures Recorded and Authorized Capital Expenditures

Description 20232022202120202019

Authorized Expenditures

Recorded and Forecast Expenditures

Total Expenditures 257,470

Forecast Capital Expenditures

2019 2020 2021 2022 2023

Recorded, Authorized and Forecast Expenditures

GRC Activity 5 yr Total


Volume: Distribution Inspections & Maintenance and Capital-Related Volume 1 Pt. 2

87,949 49,122 28,215 34,118 54,833

2023202220212020201920182017201620152014

50,450

2018

Recorded Authorized Forecast

254,237

52,984 48,619 50,342 52,152 53,372 Streetlight Maintenance and LED Conversions 257,470

53,372 52,152 50,342 48,619 52,984 GRC Total 257,470

3



Workpaper Title:

Memo of Understanding

4



Workpaper Title: Memo of Understanding Exhibit: SCE-02, Vol. 1, Pt. 2 Witness: Terry Ohanian

5




6




7




8




9



Workpaper Title:

Overhead Detailed Inspections – 2021

10



Workpaper Name: Distribution Overhead Detailed Inspections - 2021

Exhibit: SCE-02, Vol. 1, Pt. 2

Exhibit Name: Distribution Maintenance and Inspection and Capital Related Expense and Other

Witness: Terry Ohanian

Activity Name: Distribution Overhead Detailed Inspection

1. Recorded and request in constant 2018 $000s.

Overhead Detailed Inspections (ODI) 2014 2015 2016 2017 2018 2019 2020 2021Labor 3,568 3,613 3,780 4,008 3,616 2,712 2,712 2,712

Non-Labor 2,186 2,654 1,721 1,638 1,572 1,179 1,179 1,179

Other - - - - - - - -

Total 5,754 6,267 5,502 5,646 5,188 3,891 3,891 3,891

Annual Grid Patrol (AGP) Labor 888 978 1,144 1,156 977 733 733 733

Non-Labor 505 489 371 193 260 195 195 195

Other - - - - - - - -

Total 1,393 1,467 1,515 1,349 1,237 928 928 928

Wireless Technology Rate (WTR) Labor 129 85 89 60 18 18 18 18

Non-Labor 166 138 164 158 108 108 108 108

Other - - - - - - - -

Total 295 223 253 218 126 126 126 126

Infrared Inspections Labor - - - - 98 - - -

Non-Labor - - - - 1,378 - - -

Other - - - - - - - -

Total - - - - 1,476 - - -

Total Overhead Detailed Inspections Labor 4,585 4,676 5,013 5,224 4,709 3,462 3,462 3,462

Non-Labor 2,856 3,281 2,256 1,988 3,319 1,483 1,483 1,483

Other - - - - - - - -

Total 7,442 7,957 7,269 7,213 8,027 4,945 4,945 4,945

2. Calculation of Percentage of SCE Territory in HFAs based on Circuit Miles.

Circuit Miles in Tiers 2 & 3 8,758

Total Circuit Miles 35,946

Circuit Miles in Tiers 2 & 3 / Total Circuit Miles 24%

Rounded for simplicity 25%

3. Percentage of HFA Circuit Miles Applied to Last Year Recorded for Overhead Detail Inspections & Annual Grid Patrols to calculate forecast.

a b c d

3.a. Overhead Detailed Inspections (ODIs) 2018 Recorded HFA %

Estimate of HFA ODIs (a

x b)

Estimate of non-HFA

ODIs (a - c)Labor 3,616$ 25% 904$ 2,712$

Non-Labor 1,572 25% 393 1,179

Other - - -

Total 5,188$ 1,297$ 3,891$

3.b. Annual Grid Patrols (AGPs) 2018 Recorded HFA %

Estimate of HFA AGPs (a

x b)

Estimate of non-HFA

AGPs (a - c)Labor 977$ 25% 244$ 733$

Non-Labor 260.24 25% 65 195

Other - - -

Total 1,237 309$ 928$

4. Summary of 2021 Test Year Forecast for Distribution Overhead Detailed Inspections

Test Year Forecast (Constant 2018 $000) 2021Overehead Detailed Inspections 3,891$ =Estimate of non-HFA ODIs

Annual Grid Patrols 928 =Estimate of non-HFA AGPs

Wireless Technology Rate 126 =Last Year Recorded

Infrared Inspections - No funding requested

Total 4,945$

Constant 2018 $000Recorded Forecast

11



Workpaper Title:

O&M detail for Distribution Overhead Detailed Inspections

12



(U 338-E)

2021 General Rate Case A.19-08-_____

Workpapers

August 2019

SCE-02 Grid Activities Volume 1 Pt. 2 - Distribution Inspections & Maintenance and Capital-RelatedDistribution Overhead Detail Inspections

13



Forecast

2021

Beginning of Workpapers for:

Labor

Total 4,945

0

1,483

3,462

8,027

0

Recorded/Adj.

2018

3,319

4,709

Other

Non-Labor

Description of Activity:

This activity includes the costs associated with performing overhead detailed inspections, annual grid

patrols, and inspection of wireless carrier installations . Includes the cost of labor, materials used and

expenses incurred in performing overhead detailed inspections. Includes related costs such as:

transportation expenses; meals, traveling, lodging, and incidental expenses; division overhead; and

supply and tool expense.

Cost Type


Volume: Vol 1 Pt. 2 - Distribution Inspections & Maintenance and Capital-Related

Business Planning Element: Inspections & Maintenance

Activity: Distribution Overhead Detail Inspections

Witness: T. Ohanian

2021 GRC Summary

(Constant 2018 $000)


14



Total

4,982

Total

Total

Recorded/Adj.

2014 2015 201820172016Cost Type

4,585 Labor

Non-Labor

Other

2,856

0

7,442

4,676

3,281

0

7,957

5,013

0

2,256

7,269

5,224

1,988

0

7,213

4,709

3,319

0

8,027

Forecast Methods - Summary of Results of Methods Studied


Results of Linear Trending

5 Years: 20214 Years: 20213 Years: 2021

r2*$r2*$r2*$

Results of Averaging

4,966 4,906 4,842

2,654 2,521 2,711 2,740

0 0 0 0

7,620 7,503 7,616 7,581

Other

Non-Labor

Labor

4,647

0

5,045 5,239

2,642 2,557

N/AN/A

0 0

4,374

9,021 7,687 7,796

0.34 0.02 0.22

0.57 0.00 0.00

Cost Type

2017 - 2018

Last Recorded Year

202120202019

8,027

0

3,319

4,709 4,709

3,319

0

8,027

4,709

3,319

0

8,027 Total

Other

Non-Labor

Labor

Cost Type

sd**

2 Years: 3 Years:

sd**2016 - 2018 sd**2015 - 2018

4 Years:

sd**2014 - 2018

5 Years:

258

665

0

212

575

0

226

596

0

239

537

0 Other

Non-Labor

Labor

Cost Type

N/A

N/A N/A N/A N/A

* r2 = R Squared (Based on recorded years data)

** sd = standard deviation (Based on recorded years data)

Itemized Forecast

202120202019

Total

Other

Non-Labor

Labor

Cost Type

0

0

0

0 0

0

0

0 0

0

0

0





Witness: T. Ohanian

15



Cost Type

Recorded/Adj.

2014 2015 Test Year20202019201820172016

4,585 Labor

Non-Labor

Other

Total

2,856

0

7,442

4,676

3,281

0

7,957

5,013

0

2,256

7,269

5,224

1,988

0

7,213

4,709

3,319

0

8,027

1,483

3,462

0

4,945

3,462

1,483

0

4,945

3,462

1,483

0

4,945

Please see the explanation for choosing an adjusted Last Recorded Year Forecast in testimony.

Forecast

2021 GRC Selected Forecast Method


($000)

4,945

0

1,483

3,462 (1,247)

(1,836)

0

(3,082)

Method

Selected Forecast TY Forecast

Incr/(Decr) from

2018

LYR+A

LYR+A

-

Analysis of Forecasting Methods





Witness: T. Ohanian


Analysis of Linear trending Method – In D.89-12-057, and subsequently in D.04-07-022, the CPUC stated that if recorded

expenses have shown a trend in a certain direction for three or more years, the last recorded year is an appropriate base

estimate. Since there is not a clear trend in either direction, linear trending is not an appropriate forecasting method.

Analysis of Averaging Method - In D.89-12-057, and subsequently in D.04-07-022, the CPUC stated that if recorded expenses

have significant fluctuations from year to year, or expenses are influenced by external forces beyond the utility’s control, an

average of recorded-expenses is appropriate. The recorded costs do not show significant fluctuations; as such a historical

average is not an appropriate forecasting method.

Other Forecast Methods not Selected

16



Total

Prior Year TotalTotal Change

Change

4,945 4,945 8,027 7,213 7,269 7,957 7,442

515 (688) (56) 814 (3,082) 0 0

4,585 Labor

Non-Labor

Other

Total

2,856

0

7,442

Recorded /

Forecast

4,676

3,281

0

7,957

5,013

0

2,256

7,269

5,224

1,988

0

7,213

4,709

3,319

0

8,027

1,483

3,462

0

4,945

3,462

1,483

0

4,945

3,462

1,483

0

4,945

Labor Prior Year Total

Change

4,585

4,676

4,676

5,013

5,013

5,224

5,224

4,709

4,709

3,462

3,462

3,462

3,462

3,462

91 337 211 (515) (1,247) 0 0

Recorded/Adj.

2014 2015 202120202019201820172016

Non-Labor Prior Year Total

Change

Total

Other Prior Year Total

Change

Total

2,856

425

3,281

3,281

2,256

(1,025)

1,988

(268)

1,988

3,319

1,331

3,319

1,483

(1,836)

1,483

1,483

0

1,483

1,483

0

0 0 0 0 0 0 0

0 0 0 0 0 0 0

0 0 0 0 0 0 0

2,256

$0

$1,000

$2,000

$3,000

$4,000

$5,000

$6,000

$7,000

$8,000

$9,000

2014 2015 2016 2017 2018 2019 2020 2021

NL L

Recorded/Adj. 2014-2018 / Forecast 2019-2021

Total 4,945 4,945 4,945 8,027 7,213 7,269 7,957

Cost Type

2021 GRC Year Over Year Variance


Forecast





Witness: T. Ohanian


17



Summary of Changes:

Recorded (2014-2018)

Recorded/Adj.

2014 2015 202120202019201820172016Cost Type

4,585 Labor

Non-Labor

Other

Total

2,856

0

7,442

Recorded /

Forecast

4,676

3,281

0

7,957

5,013

0

2,256

7,269

5,224

1,988

0

7,213

4,709

3,319

0

8,027

1,483

3,462

0

4,945

3,462

1,483

0

4,945

3,462

1,483

0

4,945

See Testimony

Forecast (2019-2021)

See Testimony

See Testimony

2021 GRC Forecast Commentary


Forecast





Witness: T. Ohanian


18



Workpaper Title:

O&M detail for Distribution Underground Detailed Inspections

19



(U 338-E)


Workpapers

August 2019

SCE-02 Grid Activities Volume 1 Pt. 2 - Distribution Inspections & Maintenance and Capital-RelatedDistribution Underground Detail Inspections

20



Forecast

2021


Labor

Total 6,158

0

744

5,414

6,762

0

Recorded/Adj.

2018

817

5,945

Other

Non-Labor


This activity includes the costs associated with performing underground detailed inspections on the

distribution grid . Includes the cost of labor, materials used and expenses incurred in performing

underground detailed inspections. Includes related costs such as: transportation expenses; meals,

traveling, lodging, and incidental expenses; division overhead; and supply and tool expense.

Cost Type




Activity: Distribution Underground Detail Inspections

Witness: T. Ohanian

2021 GRC Summary



21



Total

5,383

Total

Total

Recorded/Adj.

2014 2015 201820172016Cost Type

4,321 Labor

Non-Labor

Other

1,109

0

5,431

3,345

1,610

0

4,955

4,273

0

1,816

6,089

5,930

1,084

0

7,014

5,945

817

0

6,762





r2*$r2*$r2*$


5,937 4,873 4,763

951 1,239 1,332 1,287

0 0 0 0

6,888 6,622 6,205 6,050

Other

Non-Labor

Labor

(759)

0

9,129 7,679

(68) 732

N/AN/A

0 0

8,727

7,968 9,061 8,412

0.75 0.90 0.65

0.93 0.75 0.18

Cost Type

2017 - 2018

Last Recorded Year

202120202019

6,762

0

817

5,945 5,945

817

0

6,762

5,945

817

0

6,762 Total

Other

Non-Labor

Labor

Cost Type

sd**

2 Years: 3 Years:

sd**2016 - 2018 sd**2015 - 2018

4 Years:

sd**2014 - 2018

5 Years:

7

134

0

785

422

0

1,114

399

0

1,020

368

0 Other

Non-Labor

Labor

Cost Type

N/A

N/A N/A N/A N/A



Itemized Forecast

202120202019

Total

Other

Non-Labor

Labor

Cost Type

6,158

0

744

5,414 5,363

737

0

6,101 5,676

0

686

4,990





Witness: T. Ohanian

22



Cost Type

Recorded/Adj.

2014 2015 Test Year20202019201820172016

4,321 Labor

Non-Labor

Other

Total

1,109

0

5,431

3,345

1,610

0

4,955

4,273

0

1,816

6,089

5,930

1,084

0

7,014

5,945

817

0

6,762

686

4,990

0

5,676

5,363

737

0

6,101

5,414

744

0

6,158

Please see the explanation for choosing an Itemized Forecast in testimony

Forecast



($000)

6,158

0

744

5,414 (531)

(73)

0

(604)

Method


Incr/(Decr) from

2018

Itemized

Itemized

-






Witness: T. Ohanian







average of recorded-expenses is appropriate. However, an average cost of historical years would not leverage an appropriate

UDI unit rate taking into consideration the annual variances that occur in UDI; as such a historical average is not an

appropriate forecasting method.

Analysis of Last Recorded Year - In D.89-12-057, and subsequently in D.04-07-022, the CPUC stated that if recorded expenses

have been relatively stable for three or more years, the last recorded year is an appropriate base estimate. Due to the annual

variances that occur in UDI, a weighted unit cost is required to forecast this activity. As such last recorded year is not an

appropriate basis for SCE’s forecast


23



Total


Change

6,101 5,676 6,762 7,014 6,089 4,955 5,431

(476) 1,134 925 (252) (1,086) 425 57

4,321 Labor

Non-Labor

Other

Total

1,109

0

5,431

Recorded /

Forecast

3,345

1,610

0

4,955

4,273

0

1,816

6,089

5,930

1,084

0

7,014

5,945

817

0

6,762

686

4,990

0

5,676

5,363

737

0

6,101

5,414

744

0

6,158


Change

4,321

3,345

3,345

4,273

4,273

5,930

5,930

5,945

5,945

4,990

4,990

5,363

5,363

5,414

(976) 928 1,657 15 (955) 373 51

Recorded/Adj.

2014 2015 202120202019201820172016


Change

Total


Change

Total

1,109

501

1,610

1,610

1,816

206

1,084

(732)

1,084

817

(267)

817

686

(131)

686

737

51

737

744

7

0 0 0 0 0 0 0

0 0 0 0 0 0 0

0 0 0 0 0 0 0

1,816

$0

$1,000

$2,000

$3,000

$4,000

$5,000

$6,000

$7,000

$8,000

2014 2015 2016 2017 2018 2019 2020 2021

NL L


Total 6,158 6,101 5,676 6,762 7,014 6,089 4,955

Cost Type



Forecast





Witness: T. Ohanian


24



Summary of Changes:


Recorded/Adj.

2014 2015 202120202019201820172016Cost Type

4,321 Labor

Non-Labor

Other

Total

1,109

0

5,431

Recorded /

Forecast

3,345

1,610

0

4,955

4,273

0

1,816

6,089

5,930

1,084

0

7,014

5,945

817

0

6,762

686

4,990

0

5,676

5,363

737

0

6,101

5,414

744

0

6,158

See Testimony


See Testimony

See Testimony



Forecast





Witness: T. Ohanian


25



Workpaper Title:

Distribution Underground Detailed Inspections – 2021

26



Work

pap

er N

ame

- D

istr

ibu

tion

Un

der

gro

un

d D

etai

led

In

spec

tion

s -

20

21

Ex

hib

it:

SC

E-0

2,

Vol.

1,

Pt.

2

Ex

hib

it N

ame:

D

istr

ibu

tion

Mai

nte

nan

ce a

nd

In

spec

tion

an

d C

apit

al R

elat

ed E

xp

ense

an

d O

ther

Wit

nes

s:

Ter

ry O

han

ian

Act

ivit

y N

ame:

D

istr

ibu

tion

Un

der

gro

un

d D

etai

led

In

spec

tion

1.

Rec

ord

ed a

nd

req

ues

t in

con

stan

t 2

01

8 $

00

0s.

2014

2015

2016

2017

2018

2019

2020

2021

Lab

or

4,3

21

3,3

45

4,2

73

5,9

30

5,9

45

4,9

90

5,3

63

5,4

14

Non

-Lab

or

1,1

09

1,6

10

1,8

16

1,0

84

81

7

68

6

73

7

74

4

Oth

er-

-

-

-

-

-

-

-

Tota

l5

,43

1

4

,95

5

6

,08

9

7

,01

4

6

,76

2

5

,67

6

6

,10

1

6

,15

8

Lab

or

/ T

ota

l8

0%

68

%7

0%

85

%8

8%

88

%8

8%

88

%

Non

-Lab

or

/ T

ota

l2

0%

32

%3

0%

15

%1

2%

12

%1

2%

12

%

2.

Com

ple

ted

an

d f

ore

cast

Un

der

gro

un

d D

etai

led

In

spec

tion

s (U

DI)

an

d F

ield

In

ves

tigat

ion

s (F

I).

2014

2015

2016

2017

2018

2019

2020

2021

2022

2023

UD

I1

72

,04

51

50

,49

51

72

,17

21

73

,99

91

61

,09

01

55

,84

21

67

,51

91

67

,11

11

66

,21

41

73

,98

2

FI

- V

ault

s4

62

59

32

54

32

12

80

28

02

80

28

02

80

FI

- M

anh

ole

s1

10

79

27

62

60

60

60

60

60

FI

Tota

l5

72

67

22

81

38

33

40

34

03

40

34

03

40

Tota

l U

DI

and

FI

17

2,0

45

15

1,0

67

17

2,8

44

17

4,2

80

16

1,4

73

15

6,1

82

16

7,8

59

16

7,4

51

16

6,5

54

17

4,3

22

3.

Cal

cula

tion

of

un

it r

ate

for

insp

ecti

on

s.

Un

it R

ate

32

$

33

$

35

$

40

$

42

$

= (

Tota

l R

ecord

ed /

Tota

l U

DI

and

FI)

5-y

ear

Aver

age

of

Un

it R

ate

36

$

=

($

32

+ $

33

+ $

35

+ $

40

+ $

42

)

4.

Cal

cula

tion

of

20

19

-20

23

fore

cast

usi

ng 5

-yea

r av

erag

e u

nit

rat

e of

$3

6 a

nd

fore

cast

in

spec

tion

s.

2019

-202

3 Fo

reca

st20

1920

2020

2120

2220

2320

21-2

023

Ave

rage

Lab

or

5-y

ear

Aver

age

ofU

nit

Rat

e *

Tota

l In

spec

tion

s *

20

18

Lab

or

as a

Per

cen

tage

of

Tota

l4

,99

0

5

,36

3

5

,35

0

5

,32

2

5

,57

0

5

,41

4

Non

-Lab

or

5-y

ear

Aver

age

Un

it R

ate

* T

ota

l In

spec

tion

s *

Non

-Lab

or

Aver

age

68

6

73

7

73

5

73

2

76

6

74

4

Oth

er-

-

-

-

-

-

Tota

l5

,67

6

6

,10

1

6

,08

6

6

,05

3

6

,33

6

6

,15

8

5.

Rec

ord

ed a

nd

Fore

cast

wit

h T

est

Yea

r N

orm

aliz

ed

2014

2015

2016

2017

2018

2019

2020

2021

Lab

or

4,3

21

3,3

45

4,2

73

5,9

30

5,9

45

4,9

90

5,3

63

5,4

14

Non

-Lab

or

1,1

09

1,6

10

1,8

16

1,0

84

81

7

68

6

73

7

74

4

Oth

er-

-

-

-

-

-

-

-

Tota

l5

,43

1

4

,95

5

6

,08

9

7

,01

4

6

,76

2

5

,67

6

6

,10

1

6

,15

8

Com

plet

edFo

reca

st

Con

stan

t 201

8 $0

00R

ecor

ded

Fore

cast

27



Workpaper Title:

O&M detail for Distribution Preventive and Breakdown O&M Maintenance

28



(U 338-E)


Workpapers

August 2019

SCE-02 Grid Activities Volume 1 Pt. 2 - Distribution Inspections & Maintenance and Capital-RelatedDistribution Preventive and Breakdown O&M Maintenance

29



Forecast

2021


Labor

Total 104,426

0

48,975

55,451

78,215

0

Recorded/Adj.

2018

33,772

44,442

Other

Non-Labor


This activity includes the costs associated with the maintenance and repair of distribution assets

identified through inspection or as a result of breakdown. Includes the cost of labor, materials used

and expenses incurred in performing maintenance on the distribution system. Includes related costs

such as: transportation expenses; meals, travel, lodging, and incidental expenses; division overhead;

and supply and tool expense.

Cost Type




Activity: Distribution Preventive and Breakdown O&M Maintenance

Witness: T. Ohanian

2021 GRC Summary



30



Total

47,605

Total

Total

Recorded/Adj.

2014 2015 201820172016Cost Type

47,810 Labor

Non-Labor

Other

70,959

0

118,770

48,299

55,828

0

104,127

50,038

0

49,570

99,608

48,336

44,562

0

92,898

44,442

33,772

0

78,215





r2*$r2*$r2*$


46,389 47,779 47,785

39,167 42,635 45,933 50,938

0 0 0 0

85,556 90,240 93,712 98,723

Other

Non-Labor

Labor

11,039

0

41,806 44,436

13,904 8,118

N/AN/A

0 0

36,413

47,452 55,710 52,554

0.95 0.52 0.26

0.95 0.97 0.96

Cost Type

2017 - 2018

Last Recorded Year

202120202019

78,215

0

33,772

44,442 44,442

33,772

0

78,215

44,442

33,772

0

78,215 Total

Other

Non-Labor

Labor

Cost Type

sd**

2 Years: 3 Years:

sd**2016 - 2018 sd**2015 - 2018

4 Years:

sd**2014 - 2018

5 Years:

1,947

5,395

0

2,342

6,592

0

2,051

8,076

0

1,834

12,345

0 Other

Non-Labor

Labor

Cost Type

N/A

N/A N/A N/A N/A



Itemized Forecast

202120202019

Total

Other

Non-Labor

Labor

Cost Type

104,426

0

48,975

55,451 48,679

41,125

0

89,804 85,960

0

39,287

46,673





Witness: T. Ohanian

31



Cost Type

Recorded/Adj.

2014 2015 Test Year20202019201820172016

47,810 Labor

Non-Labor

Other

Total

70,959

0

118,770

48,299

55,828

0

104,127

50,038

0

49,570

99,608

48,336

44,562

0

92,898

44,442

33,772

0

78,215

39,287

46,673

0

85,960

48,679

41,125

0

89,804

55,451

48,975

0

104,426


Forecast



($000)

104,426

0

48,975

55,451 11,009

15,203

0

26,211

Method


Incr/(Decr) from

2018

Itemized

Itemized

-






Witness: T. Ohanian







average of recorded-expenses is appropriate. An averaging method would not take into account the change to Priority 3

maintenance items required by recent changes to GO 95; as such a historical average is not an appropriate forecasting

method.


have been relatively stable for three or more years, the last recorded year is an appropriate base estimate. 2018 not reflect a

normal operating year due to changes in the program due to GO95; as such last recorded year is not an appropriate

forecasting method.


32



Total


Change

89,804 85,960 78,215 92,898 99,608 104,127 118,770

(14,643) (4,519) (6,710) (14,683) 7,745 3,844 14,622

47,810 Labor

Non-Labor

Other

Total

70,959

0

118,770

Recorded /

Forecast

48,299

55,828

0

104,127

50,038

0

49,570

99,608

48,336

44,562

0

92,898

44,442

33,772

0

78,215

39,287

46,673

0

85,960

48,679

41,125

0

89,804

55,451

48,975

0

104,426


Change

47,810

48,299

48,299

50,038

50,038

48,336

48,336

44,442

44,442

46,673

46,673

48,679

48,679

55,451

489 1,739 (1,702) (3,894) 2,231 2,006 6,772

Recorded/Adj.

2014 2015 202120202019201820172016


Change

Total


Change

Total

70,959

(15,131)

55,828

55,828

49,570

(6,258)

44,562

(5,008)

44,562

33,772

(10,790)

33,772

39,287

5,515

39,287

41,125

1,838

41,125

48,975

7,850

0 0 0 0 0 0 0

0 0 0 0 0 0 0

0 0 0 0 0 0 0

49,570

$0

$20,000

$40,000

$60,000

$80,000

$100,000

$120,000

2014 2015 2016 2017 2018 2019 2020 2021

NL L


Total 104,426 89,804 85,960 78,215 92,898 99,608 104,127

Cost Type



Forecast





Witness: T. Ohanian


33



Summary of Changes:


Recorded/Adj.

2014 2015 202120202019201820172016Cost Type

47,810 Labor

Non-Labor

Other

Total

70,959

0

118,770

Recorded /

Forecast

48,299

55,828

0

104,127

50,038

0

49,570

99,608

48,336

44,562

0

92,898

44,442

33,772

0

78,215

39,287

46,673

0

85,960

48,679

41,125

0

89,804

55,451

48,975

0

104,426

See Testimony


See Testimony

See Testimony



Forecast





Witness: T. Ohanian


34



Workpaper Title:

Distribution Preventive and Breakdown O&M Maintenance – 2021

35



Workpaper Title: Distribution Preventive and Breakdown O&M Maintenance - 2021Exhibit: SCE-02, Vol. 1, Pt. 2Name: Distribution Maintenance and Inspection and Capital Related Expense and OtherWitness: Terry OhanianActivity Name: Distribution Preventive and Breakdown O&M Maintenance

1. Calculation of Percentage Overhead vs Underground for Preventive & Breakdown O&M Maintenance This calculation uses the sum of 2014-2017 recorded for both Preventive & Breakdown Maintenance to calculate the percentage of this work performed on the overhead system. FERC 593 is overhead and FERC 594 is underground.

Nominal $000 % Recorded2014-2017 by OH/UG

593 - Preventive & Breakdown Maintenance 183,871 47%594 - Preventive & Breakdown Maintenance 206,705 53%Total Maintenance of Overhead & Underground Lines 390,576

2018 was excluded from calculation because it is not used for developing forecast.

2. Recorded for each sub-activity within Distribution Preventive & Breakdown O&M Maintenance Shows calculation of labor and non-labor percentages by each sub-activity. These calculations use 2014-2017 recorded. Shows calculation of 4-year average (2014-2017) recorded for each sub-activity.

Average % Labor /Distribution Preventive O&M Maintenance 2014 2015 2016 2017 2018 2014-2017 Non-Labor

Labor 22,541 21,430 22,098 18,463 17,962 21,133 34.1%Non-Labor 55,659 40,819 36,779 29,940 23,139 40,800 65.9%Other - - - - - - 0.0%Total 78,200 62,249 58,877 48,403 41,101 61,932 100%

Distribution Breakdown O&M MaintenanceLabor 24,357 25,899 27,119 28,936 25,487 26,578 65.8%Non-Labor 14,668 14,427 12,157 14,030 9,999 13,821 34.2%Other - - - - - - 0.0%Total 39,026 40,326 39,276 42,966 35,486 40,398 100%

Preventive Transformer MaintenanceLabor 847 916 757 871 936 848 95.4%Non-Labor 73 18 22 51 83 41 4.6%Other - - - - - - 0.0%Total 920 934 779 922 1,019 889 100%

Graffiti Removal Labor 65 55 64 65 57 62 9.9%Non-Labor 558 563 612 542 551 569 90.1%Other - - - - - 0.0%Total 623 618 676 607 609 631 100%

Total Preventive & Breakdown O&M MaintenanceLabor 47,810 48,299 50,038 48,336 44,442 48,621 46.8%Non-Labor 70,959 55,828 49,570 44,562 33,772 55,230 53.2%Other - - - - - - 0.0%Total 118,770 104,127 99,608 92,898 78,215 103,851 100%

3. Distribution Preventive O&M Maintenance and Distribution Breakdown O&M Maintenance combined. Calculation shows the labor / non-labor percentage for the two sub-activities.

Total Labor 47,711 46.6%Total Non-Labor 54,620 53.4%Total 102,331 100%

Recorded2018 Constant $000

Page 1 of 2

36



Workpaper Title: Distribution Preventive and Breakdown O&M Maintenance - 2021Exhibit: SCE-02, Vol. 1, Pt. 2Name: Distribution Maintenance and Inspection and Capital Related Expense and OtherWitness: Terry OhanianActivity Name: Distribution Preventive and Breakdown O&M Maintenance

4. Development of Forecast for Distribution Preventive and Breakdown O&M Maintenance.

2019 2020 2021 2022 20234.a. Forecast using 4-year average, 2014-2017, with the exception of Graffiti Removal.Distribution Preventive O&M Maintenance - 2014 through 2017 Average

Labor 21,133 21,133 21,133 21,133 21,133 Non-Labor 40,800 40,800 40,800 40,800 40,800 Other - - - - - Total 61,932 61,932 61,932 61,932 61,932

Distribution Breakdown O&M Maintenance - 2014 through 2017 AverageLabor 26,578 26,578 26,578 26,578 26,578 Non-Labor 13,821 13,821 13,821 13,821 13,821 Other - - - - - Total 40,398 40,398 40,398 40,398 40,398

Preventive Transformer Maintenance - 2014 through 2017 AverageLabor 848 848 848 848 848 Non-Labor 41 41 41 41 41 Other - - - - - Total 889 889 889 889 889

Graffiti Removal - Last Year RecordedLabor 57 57 57 57 57 Non-Labor 551 551 551 551 551 Other - - - - - Total 609 609 609 609 609

Total Preventive & Breakdown O&M MaintenanceLabor 48,616 48,616 48,616 48,616 48,616 Non-Labor 55,212 55,212 55,212 55,212 55,212 Other - - - - - Total 103,828 103,828 103,828 103,828 103,828

4.b. Calculates increase due to change in Priority 3 due date.Uses the Distribution Preventive O&M Maintenance Labor/Non-Labor percentages, 34.1% and 65.9%.

Labor - 1,024 3,071 6,142 9,213 Non-Labor - 1,976 5,929 11,858 17,787 Other - - - - - Total - 3,000 9,000 18,000 27,000

4.c. Calculates amount of work performed in High Fire AreasIncludes Distribution Preventive O&M Maintenance, Distribution Breakdown O&M Maintenance, and increase due to Priority 3 change.Applies the 47% for overhead work and 25% for HFA. Assumes half-year for 2019. Uses combined Labor / Non-Labor percentages.

Labor (2,808) (5,736) (5,977) (6,338) (6,699) Non-Labor (3,613) (7,488) (8,011) (8,796) (9,580) Other - - - - - Total (6,421) (13,224) (13,988) (15,134) (16,279)

4.d. Sum of 4.a., 4.b., and 4.c.2019 2020 2021 2022 2023

Labor 45,808 43,904 45,710 48,420 51,130 Non-Labor 51,599 49,701 53,130 58,275 63,419 Other - - - - - Total 97,407 93,605 98,841 106,695 114,549

4.e. Distribution Preventive and Breakdown O&M Maintenance forecast with test year normalized.Total Forecast for Distribution Preventive & Breakdown O&M Maintenance Normalized

2019 2020 2021Labor 45,808 43,904 48,420 Non-Labor 51,599 49,701 58,275 Other - - - Total 97,407 93,605 106,695

2018$Forecast

Page 2 of 2

37



Workpaper Title:

Capital detail for Distribution Preventive and Breakdown Capital Maintenance

38



$0

$2,000

$4,000

$6,000

$8,000

$10,000

Year

Southern California Edison

2021 GRC Capital Workpapers

Cost Estimates - Nominal ($000)

20202019 2021 2022 2023

8,314 8,251 8,514 8,760 9,012



Business Plan Group: Distribution Grid

Business Plan Element: Inspections & Maintenance

GRC Activity: Distribution Preventive and Breakdown Capital Maintenance

1. Witness: T. Ohanian

2. Asset type: Distribution Lines

3. In-Service date: Specific Blanket

4. RO Model ID: 866

5. Pin: 4056

6. CWBS Element: CET-PD-CR-IF-MTW

CWBS Description: Metro West

7. SRIIM Eligible: No

SCE$

2019 - 2023 Total

42,850

2021 GRC - Capital Expenditures Forecast


2019 2020 2021 2022 2023

39



$0

$20,000

$40,000

$60,000

$80,000

$100,000

$120,000

$140,000

$160,000

Year




20202019 2021 2022 2023

134,893 133,875 138,134 142,129 146,217









4. RO Model ID: 867

5. Pin: 4056

6. CWBS Element: CET-PD-IR-PM-MTW



SCE$

2019 - 2023 Total

695,249



2019 2020 2021 2022 2023

40



$0

$20,000

$40,000

$60,000

$80,000

$100,000

$120,000

$140,000

$160,000

Year




20202019 2021 2022 2023

136,913 135,880 140,202 144,258 148,407









4. RO Model ID: 865

5. Pin: 4056

6. CWBS Element: CET-PD-BM-BD-MTW



SCE$

2019 - 2023 Total

705,660



2019 2020 2021 2022 2023

41



Workpaper Title:

Distribution Preventive and Breakdown Capital Maintenance – 2021

42



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43



Workpaper Title:

O&M detail for Patrolling and Locating Trouble O&M Expenses

44



(U 338-E)


Workpapers

August 2019

SCE-02 Grid Activities Volume 1 Pt. 2 - Distribution Inspections & Maintenance and Capital-RelatedPatrolling and Locating Trouble

45



Forecast

2021


Labor

Total 22,029

0

3,196

18,833

22,029

0

Recorded/Adj.

2018

3,196

18,833

Other

Non-Labor


This activity includes the costs incurred by troublemen when patrolling distribution lines to locate

trouble at the request of SCE's system operators or as the result of a customer reported problem.

Activities include: patrolling, switching, locating the cause of the reported problem, and inspecting

SCE equipment installed on customer's property. Includes the cost of labor, materials used and

expenses incurred in performing patrolling and locating of trouble on the distribution grid. Includes

related costs such as: transportation expenses; meals, traveling, lodging, and incidental expenses;

division overhead; and supply and tool expense.

Cost Type




Activity: Patrolling and Locating Trouble

Witness: T. Ohanian

2021 GRC Summary



46



Total

18,001

Total

Total

Recorded/Adj.

2014 2015 201820172016Cost Type

15,837 Labor

Non-Labor

Other

3,433

0

19,270

17,472

3,071

0

20,543

16,982

0

3,037

20,019

18,187

3,324

0

21,511

18,833

3,196

0

22,029





r2*$r2*$r2*$


18,510 17,869 17,462

3,260 3,186 3,157 3,212

0 0 0 0

21,770 21,186 21,026 20,675

Other

Non-Labor

Labor

3,504

0

20,248 20,816

3,455 3,102

N/AN/A

0 0

21,703

25,206 23,703 23,917

0.97 0.70 0.85

0.30 0.42 0.04

Cost Type

2017 - 2018

Last Recorded Year

202120202019

22,029

0

3,196

18,833 18,833

3,196

0

22,029

18,833

3,196

0

22,029 Total

Other

Non-Labor

Labor

Cost Type

sd**

2 Years: 3 Years:

sd**2016 - 2018 sd**2015 - 2018

4 Years:

sd**2014 - 2018

5 Years:

323

64

0

767

118

0

703

113

0

1,027

150

0 Other

Non-Labor

Labor

Cost Type

N/A

N/A N/A N/A N/A



Itemized Forecast

202120202019

Total

Other

Non-Labor

Labor

Cost Type

0

0

0

0 0

0

0

0 0

0

0

0





Witness: T. Ohanian

47



Cost Type

Recorded/Adj.

2014 2015 Test Year20202019201820172016

15,837 Labor

Non-Labor

Other

Total

3,433

0

19,270

17,472

3,071

0

20,543

16,982

0

3,037

20,019

18,187

3,324

0

21,511

18,833

3,196

0

22,029

3,196

18,833

0

22,029

18,833

3,196

0

22,029

18,833

3,196

0

22,029

Last Year Recorded – In D.89-12-057, and subsequently in D.04-07-022, the CPUC stated that if recorded expenses have been

relatively stable for three or more years, the last recorded year is an appropriate base estimate.

Forecast



($000)

22,029

0

3,196

18,833 0

0

0

0

Method


Incr/(Decr) from

2018

LYR

LYR

-






Witness: T. Ohanian







average of recorded-expenses is appropriate. The recorded costs do not show significant fluctuations and SCE bases the

forecast on the most current staffing; as such a historical average is not an appropriate forecasting method.


48



Total


Change

22,029 22,029 22,029 21,511 20,019 20,543 19,270

1,273 (524) 1,492 518 0 0 0

15,837 Labor

Non-Labor

Other

Total

3,433

0

19,270

Recorded /

Forecast

17,472

3,071

0

20,543

16,982

0

3,037

20,019

18,187

3,324

0

21,511

18,833

3,196

0

22,029

3,196

18,833

0

22,029

18,833

3,196

0

22,029

18,833

3,196

0

22,029


Change

15,837

17,472

17,472

16,982

16,982

18,187

18,187

18,833

18,833

18,833

18,833

18,833

18,833

18,833

1,635 (490) 1,205 646 0 0 0

Recorded/Adj.

2014 2015 202120202019201820172016


Change

Total


Change

Total

3,433

(362)

3,071

3,071

3,037

(34)

3,324

287

3,324

3,196

(128)

3,196

3,196

0

3,196

3,196

0

3,196

3,196

0

0 0 0 0 0 0 0

0 0 0 0 0 0 0

0 0 0 0 0 0 0

3,037

$0

$4,000

$8,000

$12,000

$16,000

$20,000

$24,000

2014 2015 2016 2017 2018 2019 2020 2021

NL L


Total 22,029 22,029 22,029 22,029 21,511 20,019 20,543

Cost Type



Forecast





Witness: T. Ohanian


49



Summary of Changes:


Recorded/Adj.

2014 2015 202120202019201820172016Cost Type

15,837 Labor

Non-Labor

Other

Total

3,433

0

19,270

Recorded /

Forecast

17,472

3,071

0

20,543

16,982

0

3,037

20,019

18,187

3,324

0

21,511

18,833

3,196

0

22,029

3,196

18,833

0

22,029

18,833

3,196

0

22,029

18,833

3,196

0

22,029

See Testimony


See Testimony

See Testimony



Forecast





Witness: T. Ohanian


50



Workpaper Title:

O&M detail for Distribution Apparatus Inspection and Maintenance

51



(U 338-E)


Workpapers

August 2019

SCE-02 Grid Activities Volume 1 Pt. 2 - Distribution Inspections & Maintenance and Capital-RelatedDistribution Apparatus Inspection and Maintenance

52



Forecast

2021


Labor

Total 5,697

0

605

5,092

5,697

0

Recorded/Adj.

2018

605

5,092

Other

Non-Labor


This activity includes the costs associated with the inspection, testing, and maintenance of overhead

and underground distribution apparatus used for remote monitoring and control. Examples of

distribution apparatus include capacitors, regulators, network protectors, fault interrupters, and

automatic re-closing switches used for line protection and sectionalizing. Both the inspection and

resulting maintenance performed by the apparatus crews is included in this activity.

Cost Type




Activity: Distribution Apparatus Inspection and Maintenance

Witness: T. Ohanian

2021 GRC Summary



53



Total

5,145

Total

Total

Recorded/Adj.

2014 2015 201820172016Cost Type

4,300 Labor

Non-Labor

Other

815

0

5,115

4,527

1,056

0

5,584

5,084

0

787

5,871

5,260

616

0

5,876

5,092

605

0

5,697





r2*$r2*$r2*$


5,176 4,991 4,853

610 669 766 776

0 0 0 0

5,787 5,815 5,757 5,628

Other

Non-Labor

Labor

305

0

5,833 6,011

80 346

N/AN/A

0 0

5,161

5,467 5,913 6,357

0.00 0.57 0.78

0.79 0.87 0.54

Cost Type

2017 - 2018

Last Recorded Year

202120202019

5,697

0

605

5,092 5,092

605

0

5,697

5,092

605

0

5,697 Total

Other

Non-Labor

Labor

Cost Type

sd**

2 Years: 3 Years:

sd**2016 - 2018 sd**2015 - 2018

4 Years:

sd**2014 - 2018

5 Years:

84

6

0

81

83

0

277

183

0

371

164

0 Other

Non-Labor

Labor

Cost Type

N/A

N/A N/A N/A N/A



Itemized Forecast

202120202019

Total

Other

Non-Labor

Labor

Cost Type

0

0

0

0 0

0

0

0 0

0

0

0





Witness: T. Ohanian

54



Cost Type

Recorded/Adj.

2014 2015 Test Year20202019201820172016

4,300 Labor

Non-Labor

Other

Total

815

0

5,115

4,527

1,056

0

5,584

5,084

0

787

5,871

5,260

616

0

5,876

5,092

605

0

5,697

605

5,092

0

5,697

5,092

605

0

5,697

5,092

605

0

5,697



Forecast



($000)

5,697

0

605

5,092 0

0

0

0

Method


Incr/(Decr) from

2018

LYR

LYR

-






Witness: T. Ohanian







average of recorded-expenses is appropriate. The recorded costs do not show significant fluctuations; as such a historical



55



Total


Change

5,697 5,697 5,697 5,876 5,871 5,584 5,115

469 287 5 (179) 0 0 0

4,300 Labor

Non-Labor

Other

Total

815

0

5,115

Recorded /

Forecast

4,527

1,056

0

5,584

5,084

0

787

5,871

5,260

616

0

5,876

5,092

605

0

5,697

605

5,092

0

5,697

5,092

605

0

5,697

5,092

605

0

5,697


Change

4,300

4,527

4,527

5,084

5,084

5,260

5,260

5,092

5,092

5,092

5,092

5,092

5,092

5,092

227 557 176 (168) 0 0 0

Recorded/Adj.

2014 2015 202120202019201820172016


Change

Total


Change

Total

815

241

1,056

1,056

787

(269)

616

(171)

616

605

(11)

605

605

0

605

605

0

605

605

0

0 0 0 0 0 0 0

0 0 0 0 0 0 0

0 0 0 0 0 0 0

787

$0

$1,000

$2,000

$3,000

$4,000

$5,000

$6,000

2014 2015 2016 2017 2018 2019 2020 2021

NL L


Total 5,697 5,697 5,697 5,697 5,876 5,871 5,584

Cost Type



Forecast





Witness: T. Ohanian


56



Summary of Changes:


Recorded/Adj.

2014 2015 202120202019201820172016Cost Type

4,300 Labor

Non-Labor

Other

Total

815

0

5,115

Recorded /

Forecast

4,527

1,056

0

5,584

5,084

0

787

5,871

5,260

616

0

5,876

5,092

605

0

5,697

605

5,092

0

5,697

5,092

605

0

5,697

5,092

605

0

5,697

See Testimony


See Testimony

See Testimony



Forecast





Witness: T. Ohanian


57



Workpaper Title:

Capital detail for Distribution Claim

58



$0

$5,000

$10,000

$15,000

$20,000

$25,000

$30,000

$35,000

$40,000

$45,000

Year




20202019 2021 2022 2023

38,879 40,385 41,670 42,875 44,108





GRC Activity: Distribution Claim




4. RO Model ID: 864

5. Pin: 4055

6. CWBS Element: CET-PD-CL-DC-MTW


7. SRIIM Eligible: Yes

SCE$

2019 - 2023 Total

207,916



2019 2020 2021 2022 2023

59



Workpaper Title:

Distribution Claim – 2021

60



Workpaper Title: Distribution Claim - 2021Exhibit: SCE-02, Vol. 1, Pt. 2Name: Distribution Maintenance and Inspection and Capital Related Expense and OtherWitness: Terry OhanianActivity Name: Distribution Claim

2014 2015 2016 2017 2018Distribution Claim 28,290$ 30,823$ 37,318$ 40,853$ 37,299$

Escalation Rates: 2014 2015 2016 2017 20181.134 1.108 1.091 1.052 1.000

5-year Average2014 2015 2016 2017 2018 2014-2018

Recorded x Escalation 32,079$ 34,138$ 40,696$ 42,965$ 37,299$ 37,435$

Escalation Rates: 2019 2020 2021 2022 20231.039 1.079 1.113 1.145 1.178

2019 2020 2021 2022 2023Forecast Distribution Claim 38,879$ 40,385$ 41,670$ 42,875$ 44,108$

Claim forecast is developed by escalating 2014-2017 to constant $2018 and then calculating a five-year average (2014-2018). Next, the five-year average is escalated to nominal dollars.

Nominal $000

Constant 2018 $000

Nominal $000

Recorded

Forecast

61



Workpaper Title:

O&M detail for Streetlight Operations, Inspections and Maintenance

62



(U 338-E)


Workpapers

August 2019

SCE-02 Grid Activities Volume 1 Pt. 2 - Distribution Inspections & Maintenance and Capital-RelatedStreetlight Operations, Inspections, and Maintenance

63



Forecast

2021


Labor

Total 6,575

0

2,475

4,100

6,575

0

Recorded/Adj.

2018

2,475

4,100

Other

Non-Labor


This activity includes the costs associated with operating, inspecting, and maintaining SCE-owned

streetlighting assets. Activities include inspecting streetlights for outages, mapping, customer billing

and record-keeping, general administration, and maintenance of streetlights. Includes the cost of

labor, materials used and expenses incurred in performing streetlight operations, inspections, and

maintenance. Includes related costs such as: transportation expenses; meals, traveling, lodging, and

incidental expenses; division overhead; and supply and tool expense.

Cost Type




Activity: Streetlight Operations, Inspections, and Maintenance

Witness: T. Ohanian

2021 GRC Summary



64



Total

4,368

Total

Total

Recorded/Adj.

2014 2015 201820172016Cost Type

4,619 Labor

Non-Labor

Other

4,125

0

8,744

3,990

3,392

0

7,382

4,099

0

2,187

6,286

4,905

2,256

0

7,161

4,100

2,475

0

6,575





r2*$r2*$r2*$


4,503 4,274 4,343

2,365 2,306 2,577 2,887

0 0 0 0

6,868 6,674 6,851 7,230

Other

Non-Labor

Labor

2,882

0

4,785 4,281

1,371 669

N/AN/A

0 0

4,370

7,252 6,155 4,950

0.00 0.11 0.00

0.91 0.38 0.69

Cost Type

2017 - 2018

Last Recorded Year

202120202019

6,575

0

2,475

4,100 4,100

2,475

0

6,575

4,100

2,475

0

6,575 Total

Other

Non-Labor

Labor

Cost Type

sd**

2 Years: 3 Years:

sd**2016 - 2018 sd**2015 - 2018

4 Years:

sd**2014 - 2018

5 Years:

402

109

0

380

123

0

367

482

0

356

754

0 Other

Non-Labor

Labor

Cost Type

N/A

N/A N/A N/A N/A



Itemized Forecast

202120202019

Total

Other

Non-Labor

Labor

Cost Type

0

0

0

0 0

0

0

0 0

0

0

0





Witness: T. Ohanian

65



Cost Type

Recorded/Adj.

2014 2015 Test Year20202019201820172016

4,619 Labor

Non-Labor

Other

Total

4,125

0

8,744

3,990

3,392

0

7,382

4,099

0

2,187

6,286

4,905

2,256

0

7,161

4,100

2,475

0

6,575

2,475

4,100

0

6,575

4,100

2,475

0

6,575

4,100

2,475

0

6,575



Forecast



($000)

6,575

0

2,475

4,100 0

0

0

0

Method


Incr/(Decr) from

2018

LYR

LYR

-






Witness: T. Ohanian







average of recorded-expenses is appropriate. Averaging the historical costs would not take into account savings achieved in

2018 through the restructuring of our streetlighting organization, streetlight sales, and LED conversions; as such a historical



66



Total


Change

6,575 6,575 6,575 7,161 6,286 7,382 8,744

(1,362) (1,096) 875 (586) 0 0 0

4,619 Labor

Non-Labor

Other

Total

4,125

0

8,744

Recorded /

Forecast

3,990

3,392

0

7,382

4,099

0

2,187

6,286

4,905

2,256

0

7,161

4,100

2,475

0

6,575

2,475

4,100

0

6,575

4,100

2,475

0

6,575

4,100

2,475

0

6,575


Change

4,619

3,990

3,990

4,099

4,099

4,905

4,905

4,100

4,100

4,100

4,100

4,100

4,100

4,100

(629) 109 806 (805) 0 0 0

Recorded/Adj.

2014 2015 202120202019201820172016


Change

Total


Change

Total

4,125

(733)

3,392

3,392

2,187

(1,205)

2,256

69

2,256

2,475

219

2,475

2,475

0

2,475

2,475

0

2,475

2,475

0

0 0 0 0 0 0 0

0 0 0 0 0 0 0

0 0 0 0 0 0 0

2,187

$0

$2,000

$4,000

$6,000

$8,000

$10,000

2014 2015 2016 2017 2018 2019 2020 2021

NL L


Total 6,575 6,575 6,575 6,575 7,161 6,286 7,382

Cost Type



Forecast





Witness: T. Ohanian


67



Summary of Changes:


Recorded/Adj.

2014 2015 202120202019201820172016Cost Type

4,619 Labor

Non-Labor

Other

Total

4,125

0

8,744

Recorded /

Forecast

3,990

3,392

0

7,382

4,099

0

2,187

6,286

4,905

2,256

0

7,161

4,100

2,475

0

6,575

2,475

4,100

0

6,575

4,100

2,475

0

6,575

4,100

2,475

0

6,575

See Testimony


See Testimony

See Testimony



Forecast





Witness: T. Ohanian


68



Workpaper Title:

Capital detail for Streetlight Maintenance and LED Conversions

69



$0

$400

$800

$1,200

$1,600

$2,000

$2,400

$2,800

$3,200

Year




20202019 2021 2022 2023

900 1,500 3,000 3,000 3,000


Volume: Distribution Inspections & Maintenance and Capital-Related

Volume 1 Pt. 2


Business Plan Element: Infrastructure Replacement

GRC Activity: Streetlight Maintenance and LED Conversions




4. RO Model ID: 876

5. Pin: 4058

6. CWBS Element: CET-PD-OT-SL-MTE

CWBS Description: Metro East


SCE$

2019 - 2023 Total

11,400



2019 2020 2021 2022 2023

70



$0

$10,000

$20,000

$30,000

$40,000

$50,000

$60,000

Year




20202019 2021 2022 2023

52,084 47,119 47,342 49,152 50,372


Volume: Distribution Inspections & Maintenance and Capital-Related

Volume 1 Pt. 2


Business Plan Element: Infrastructure Replacement

GRC Activity: Streetlight Maintenance and LED Conversions




4. RO Model ID: 877

5. Pin: 4058

6. CWBS Element: CET-PD-OT-SL-MTW



SCE$

2019 - 2023 Total

246,070



2019 2020 2021 2022 2023

71



Workpaper Title:

Streetlight Maintenance and LED Conversions – 2021

72



Wor

kapa

per T

itle:

Stre

etlig

ht M

aint

enan

ce a

nd L

ED C

onve

rsio

ns -

2021

Exhi

bit:

SC

E-02

, Vol

. 1, P

t. 2

Nam

e: D

istri

butio

n M

aint

enan

ce a

nd In

spec

tion

and

Cap

ital R

elat

ed E

xpen

se a

nd O

ther

Witn

ess:

Ter

ry O

hani

anA

ctiv

ity N

ame:

Stre

etlig

ht M

aint

enan

ce a

nd L

ED C

onve

rsio

ns

2014

2015

2016

2017

2018

2019

2020

2021

2022

2023

Stre

etlig

ht M

aint

enan

ce &

LED

Con

vers

ions

81,7

19

48,5

18

28,2

45

34,1

18

54,8

33

52

,984

48

,619

50

,342

52

,152

53

,372

Fore

cast

uni

ts a

nd u

nit r

ates

in $

2018

for s

treet

light

mai

nten

ance

& L

ED c

onve

rsio

ns a

ctiv

ities

:

Stee

l Pol

e R

epla

cem

ent

Qua

ntity

2,20

0

1,

650

2,30

0

2,

300

2,30

0

U

nit R

ate

7,40

0$

7,

400

$

7,40

0$

7,

400

$

7,40

0$

St

eel P

ole

Rep

lace

men

t Tot

al16

,280

,000

12

,210

,000

17

,020

,000

17

,020

,000

17

,020

,000

Fixt

ure

Rep

lace

men

tQ

uant

ity (0

.02

x Fo

reca

st L

S-1

HPS

V la

mps

)7,

500

5,00

0

4,

000

3,00

0

2,

000

Uni

t Rat

e33

5$

335

$

33

5$

335

$

33

5$

Fixt

ure

Rep

lace

men

t Tot

al2,

512,

500

1,67

5,00

0

1,

340,

000

1,00

5,00

0

67

0,00

0

LED

Con

vers

ions

Qua

ntity

70,0

00

66,3

00

50,0

00

50,0

00

50,0

00

Uni

t Rat

e40

0$

400

$

40

0$

400

$

40

0$

LED

Con

vers

ion

Tota

l28

,000

,000

26

,520

,000

20

,000

,000

20

,000

,000

20

,000

,000

Smar

t Sen

sors

Qua

ntity

6,00

0

10

,000

20

,000

20

,000

20

,000

U

nit R

ate

150

$

15

0$

150

$

15

0$

150

$

Sm

art S

enso

rs T

otal

900,

000

1,

500,

000

3,00

0,00

0

3,

000,

000

3,00

0,00

0

Con

duct

or A

llow

ance

600,

000

$

60

0,00

0$

600,

000

$

60

0,00

0$

600,

000

$

Se

ries S

treet

light

s (R

egul

ated

Out

put T

rans

form

er S

yste

m R

ebui

ld)

325,

000

$

16

5,00

0$

865,

000

$

1,

500,

000

$

1,60

0,00

0$

St

reet

light

Mai

nten

ance

Rep

air

2,40

0,00

0$

2,

400,

000

$

2,40

0,00

0$

2,

400,

000

$

2,40

0,00

0$

Esca

latio

n R

ates

:1.

039

1.

079

1.

113

1.

145

1.

178

2019

2020

2021

2022

2023

Stee

l Pol

e R

epla

cem

ents

16,9

08

13,1

72

18,9

45

19,4

93

20,0

54

Fixt

ure

Rep

lace

men

ts2,

609

1,80

7

1,

492

1,15

1

78

9

LED

Con

vers

ions

29,0

79

28,6

09

22,2

62

22,9

06

23,5

65

Smar

t Sen

sors

935

1,

618

3,33

9

3,

436

3,53

5

C

ondu

ctor

Allo

wan

ce62

3

647

66

8

687

70

7

Serie

s Stre

etlig

hts (

Reg

ulat

ed O

utpu

t Tra

nsfo

rmer

Sys

tem

Reb

uild

)33

8

178

96

3

1,71

8

1,

885

Stre

etlig

ht M

aint

enan

ce R

epai

r2,

493

2,58

7

2,

673

2,76

1

2,

837

52,9

84

48,6

19

50,3

42

52,1

52

53,3

72

Fore

cast

LS-

1 H

PSV

Stre

etlig

hts u

sed

for F

ixtu

re R

epla

cem

ent F

orec

ast

2018

2019

2020

2021

2022

2023

LS-1

HPS

V49

8,18

9

348,

474

22

2,17

4

172,

174

12

2,17

4

72,1

74

Rec

orde

dFo

reca

st

Fore

cast

s in

$201

8

Fore

cast

, Nom

inal

$00

0

Nom

inal

$00

0

73



Workpaper Title:

O&M detail for Distribution Support Activities

74



(U 338-E)


Workpapers

August 2019

SCE-02 Grid Activities Volume 1 Pt. 2 - Distribution Inspections & Maintenance and Capital-RelatedDistribution Support Activities

75



Forecast

2021


Labor

Total 11,453

0

3,356

8,097

18,177

20

Recorded/Adj.

2018

9,102

9,054

Other

Non-Labor


This activity includes costs to support our construction crews working on the distribution system,

including chargebacks for information technology, Stand-by Time, Informational Meetings, Field

Accounting O&M Activities, Distribution Analytics, Reliability Outage Center, Real Properties O&M

Activities, Mapping and Spatial Data Analytics, and underground civil activities. Includes the cost of

labor, materials used and expenses incurred in performing these activities. Includes related costs such

as: transportation expenses; meals, travel, lodging, and incidental expenses; division overhead; and

supply and tool expense.

Cost Type



Business Planning Element: Capital Related Expense & Other

Activity: Distribution Support Activities

Witness: T. Ohanian

2021 GRC Summary



76



Total

8,167

Total

Total

Recorded/Adj.

2014 2015 201820172016Cost Type

8,834 Labor

Non-Labor

Other

12,997

0

21,831

7,202

5,756

0

12,958

7,326

0

7,221

14,546

8,122

10,044

10

18,176

9,054

9,102

20

18,177





r2*$r2*$r2*$


8,588 7,926 8,108

9,573 8,789 8,031 9,024

15 10 8 6

18,176 16,966 15,964 17,137

Other

Non-Labor

Labor

12,551

50

10,784 8,788

13,818 7,273

N/AN/A

39 31

11,623

24,224 24,642 16,092

0.99 0.91 0.06

0.42 0.74 0.03

0.89 0.78

Cost Type

2017 - 2018

Last Recorded Year

202120202019

18,177

20

9,102

9,054 9,054

9,102

20

18,177

9,054

9,102

20

18,177 Total

Other

Non-Labor

Labor

Cost Type

sd**

2 Years: 3 Years:

sd**2016 - 2018 sd**2015 - 2018

4 Years:

sd**2014 - 2018

5 Years:

466

471

5

706

1,174

8

741

1,661

8

756

2,480

8

1.00

Other

Non-Labor

Labor

Cost Type

N/A

N/A N/A N/A N/A



Itemized Forecast

202120202019

Total

Other

Non-Labor

Labor

Cost Type

11,453

0

3,356

8,097 8,097

3,356

0

11,453 16,119

0

6,892

9,228





Witness: T. Ohanian

77



Cost Type

Recorded/Adj.

2014 2015 Test Year20202019201820172016

8,834 Labor

Non-Labor

Other

Total

12,997

0

21,831

7,202

5,756

0

12,958

7,326

0

7,221

14,546

8,122

10,044

10

18,176

9,054

9,102

20

18,177

6,892

9,228

0

16,119

8,097

3,356

0

11,453

8,097

3,356

0

11,453


Forecast



($000)

11,453

0

3,356

8,097 (957)

(5,746)

(20)

(6,724)

Method


Incr/(Decr) from

2018

Itemized

Itemized

-






Witness: T. Ohanian







average of recorded-expenses is appropriate. Distribution Support Activities is composed of nine sub-activities forecasted

using various methods. Due to merging many sub-activities into the forecast for Distribution Support Activities, the forecast

in whole was deemed as an ""Itemized Forecast"", and an averaging method was not appropriate for the total activity.


have been relatively stable for three or more years, the last recorded year is an appropriate base estimate. Distribution

Support Activities is composed of nine sub-activities forecasted using various methods. Due to merging many sub-activities

into the forecast for Distribution Support Activities, the forecast in whole was deemed as an ""Itemized Forecast"". and a last

recorded year method was not appropriate for the total activity.


78



Total


Change

11,453 16,119 18,177 18,176 14,546 12,958 21,831

(8,873) 1,588 3,630 1 (2,058) (4,666) 0

8,834 Labor

Non-Labor

Other

Total

12,997

0

21,831

Recorded /

Forecast

7,202

5,756

0

12,958

7,326

0

7,221

14,546

8,122

10,044

10

18,176

9,054

9,102

20

18,177

6,892

9,228

0

16,119

8,097

3,356

0

11,453

8,097

3,356

0

11,453


Change

8,834

7,202

7,202

7,326

7,326

8,122

8,122

9,054

9,054

9,228

9,228

8,097

8,097

8,097

(1,632) 124 796 932 174 (1,131) 0

Recorded/Adj.

2014 2015 202120202019201820172016


Change

Total


Change

Total

12,997

(7,241)

5,756

5,756

7,221

1,465

10,044

2,823

10,044

9,102

(942)

9,102

6,892

(2,210)

6,892

3,356

(3,536)

3,356

3,356

0

0 0 0 20 10 0 0

0 0 20 10 0 0 0

0 0 10 10 (20) 0 0

7,221

$0

$4,000

$8,000

$12,000

$16,000

$20,000

$24,000

2014 2015 2016 2017 2018 2019 2020 2021

O NL L


Total 11,453 11,453 16,119 18,177 18,176 14,546 12,958

Cost Type



Forecast





Witness: T. Ohanian


79



Summary of Changes:


Recorded/Adj.

2014 2015 202120202019201820172016Cost Type

8,834 Labor

Non-Labor

Other

Total

12,997

0

21,831

Recorded /

Forecast

7,202

5,756

0

12,958

7,326

0

7,221

14,546

8,122

10,044

10

18,176

9,054

9,102

20

18,177

6,892

9,228

0

16,119

8,097

3,356

0

11,453

8,097

3,356

0

11,453

See Testimony


See Testimony

See Testimony



Forecast





Witness: T. Ohanian


80



Workpaper Title:

Distribution Support Activities – 2021

81



Wor

kpap

er T

itle:

Dis

tribu

tion

Supp

ort A

ctiv

ities

- 20

21Ex

hibi

t: S

CE-

02, V

ol. 1

, Pt.

2N

ame:

Dis

tribu

tion

Mai

nten

ance

and

Insp

ectio

n an

d C

apita

l Rel

ated

Exp

ense

and

Oth

erW

itnes

s: T

erry

Oha

nian

Act

ivity

Nam

e: D

istri

butio

n Su

ppor

t Act

iviti

es

Sub-

Act

ivity

Nam

e20

1420

1520

1620

1720

1820

1920

2020

2120

2220

23In

form

atio

n Te

chno

logy

(IT)

Cha

rgeb

acks

12,1

18$

4,78

9$

5,

092

$

2,47

3$

1,

270

$

1,27

0$

1,

270

$

1,27

0$

1,

270

$

1,27

0$

Fi

eld

Acc

ount

Org

aniz

atio

n (F

AO

) O&

M A

ctiv

ities

1,60

1

1,

251

1,06

1

1,

141

757

75

7

757

75

7

757

75

7

Dis

tribu

tion

Ana

lytic

s54

9

20

13

3

264

18

0

180

18

0

180

18

0

180

St

and-

By

Tim

e45

7

306

95

7

1,10

2

1,

480

1,48

0

1,

480

1,48

0

1,

480

1,48

0

U

nder

grou

nd C

ivil

Insp

ectio

n O

&M

Act

iviti

es22

3

303

27

7

317

39

0

390

39

0

390

39

0

390

R

eal P

rope

rties

(RP)

O&

M A

ctiv

ities

512

49

1

436

14

1

119

11

9

119

11

9

119

11

9

Map

ping

& S

patia

l Dat

a A

naly

tics

1,49

4

1,

444

2,33

0

8,

293

8,24

7

6,

189

1,52

4

1,

524

1,52

4

1,

524

Info

rmat

iona

l Mee

tings

2,61

8

2,

246

2,44

9

2,

699

3,24

2

3,

242

3,24

2

3,

242

3,24

2

3,

242

Rel

iabi

lity

Out

age

Cen

ter (

RO

C)

2,25

8

2,

109

1,81

1

1,

746

2,49

3

2,

493

2,49

3

2,

493

2,49

3

2,

493

21,8

31$

12,9

58$

14,5

46$

18,1

76$

18,1

77$

16,1

19$

11,4

53$

11,4

53$

11,4

53$

11,4

53$

Rec

orde

dFo

reca

stC

onst

ant 2

018

$000

82



Workpaper Title:

Capital detail for Distribution Tools and Work Equipment

83



$0

$400

$800

$1,200

$1,600

$2,000

$2,400

$2,800

Year




20202019 2021 2022 2023

2,645 2,637 2,671 2,704 2,747




Business Plan Element: Capital Related Expense & Other

GRC Activity: Distribution Tools and Work Equipment


2. Asset type: Stores/Lab/Miscellaneous


4. RO Model ID: 868

5. Pin: 4050

6. CWBS Element: CET-PD-OT-DL-MTW



SCE$

2019 - 2023 Total

13,405



2019 2020 2021 2022 2023

84



$0

$100

$200

$300

$400

$500

$600

Year




20202019 2021 2022 2023

512 519 535 551 565







2. Asset type: General Other


4. RO Model ID: 869

5. Pin: 5265

6. CWBS Element: CET-ET-MS-SE-526500

CWBS Description: Specialized Equipment - Engineering


SCE$

2019 - 2023 Total

2,682



2019 2020 2021 2022 2023

85



$0

$40

$80

$120

$160

$200

$240

Year




20202019 2021 2022 2023

169 220 224 228 233







2. Asset type: General Other


4. RO Model ID: 870

5. Pin: 5265

6. CWBS Element: CET-PD-MS-SE-526500

CWBS Description: Specialized Equipment - Tool Kits


SCE$

2019 - 2023 Total

1,073



2019 2020 2021 2022 2023

86



Workpaper Title:

Capital detail for Prefabrication

87



$0

$2,000

$4,000

$6,000

$8,000

$10,000

$12,000

$14,000

$16,000

Year




20202019 2021 2022 2023

14,002 14,544 15,007 15,441 15,885





GRC Activity: Prefabrication




4. RO Model ID: 874

5. Pin: 4052

6. CWBS Element: CET-PD-OT-PF-MTW



SCE$

2019 - 2023 Total

74,880



2019 2020 2021 2022 2023

88



$0

$1,000

$2,000

$3,000

$4,000

$5,000

$6,000

$7,000

$8,000

Year




20202019 2021 2022 2023

4,944 4,299 7,391 7,605 7,824





GRC Activity: Prefabrication




4. RO Model ID: 875

5. Pin: 4052

6. CWBS Element: CET-PD-OT-PF-PL

CWBS Description: Prefab (395) - Pole Loading


SCE$

2019 - 2023 Total

32,063



2019 2020 2021 2022 2023

89



Workpaper Title:

Prefabrication – 2021

90



Wor

kpap

er T

itle:

Pre

fabr

icat

ion

- 202

1Ex

hibi

t: S

CE-

02, V

ol. 1

, Pt.

2N

ame:

Dis

tribu

tion

Mai

nten

ance

and

Insp

ectio

n an

d C

apita

l Rel

ated

Exp

ense

and

Oth

erW

itnes

s: T

erry

Oha

nian

Act

ivity

Nam

e: P

refa

bric

atio

n

1. R

ecor

ded

and

fore

cast

in n

omin

al $

000.

2014

2015

2016

2017

2018

2019

2020

2021

2022

2023

aTo

tal P

refa

bric

atio

n12

,895

$

13,6

92$

13

,659

$

15,1

83$

16

,789

$

18,9

46$

18

,843

$

22,3

98$

23

,046

$

23,7

09$

2. C

alcu

latio

n of

Pol

e Lo

adin

g Pr

ogra

m (P

LP) P

refa

bric

atio

nb

PLP

Rep

lace

men

ts (1

)5,

313

$

15

1,03

3$

88

,985

$

84,5

16$

11

3,06

5$

16

8,13

1$

14

8,38

0$

25

1,16

8$

25

8,43

3$

26

5,86

7$

c

PLP

Und

erbu

ild (2

)-

$

-$

-

$

12

$

3,

784

$

6,

570

$

3,

522

$

10

,004

$

10,2

93$

10

,589

$

dTo

tal P

LP R

epla

cem

ents

& U

nder

build

(b +

c)

5,31

3$

151,

033

$

88,9

85$

84

,528

$

116,

849

$

174,

701

$

151,

902

$

261,

172

$

268,

726

$

276,

456

$

eC

alcu

late

d PL

P Pr

efab

(d x

0.0

283)

(3)

150

$

4,27

4$

2,51

8$

2,

392

$

3,

307

$

4,

944

$

4,

299

$

7,

391

$

7,

605

$

7,

824

$

3. N

on-P

LP P

refa

bric

atio

n re

cord

ed c

osts

fN

on-P

LP P

refa

b (a

- e)

(4)

12,7

45

9,

417

11

,141

12,7

91

13

,482

Esca

latio

n R

ates

:1.

039

1.07

9

1.

113

1.14

5

1.

178

gN

on-P

LP P

refa

b Fo

reca

st (5

)14

,002

14,5

45

15

,007

15,4

41

15

,885

hTo

tal P

refa

bric

atio

n R

ecor

ded/

Fore

cast

(f +

g)

12,8

95

13

,692

13,6

59

15,1

83

16

,789

18,9

46

18

,843

22,3

98

23

,046

23,7

09

(1) T

otal

reco

rded

and

fore

cast

for D

istri

butio

n Po

le L

oadi

ng P

rogr

am.

(2) T

otal

reco

rded

and

fore

cast

for D

istri

butio

n Po

le L

oadi

ng U

nder

build

.(3

) Pol

e Lo

adin

g Pr

ogra

m P

refa

bric

atio

n is

cal

cula

ted

by a

pply

ing

2.83

% to

the

reco

rded

/fore

cast

for t

he D

istri

butio

n Po

le L

oadi

ng P

rogr

am &

PLP

L U

nder

build

.(4

) Tot

al P

refa

bric

atio

n m

inus

Cal

cula

ted

PLP

Pref

ab(5

) 201

8 R

ecor

ded

for N

on-P

LP P

refa

b x

esca

latio

n

Nom

inal

$00

0R

ecor

ded

Fore

cast

91



Workpaper Title:

Capital detail for Distribution Transformers

92



$0

$20,000

$40,000

$60,000

$80,000

$100,000

Year




20202019 2021 2022 2023

87,321 88,126 89,245 92,439 95,097





GRC Activity: Distribution Transformers




4. RO Model ID: 873

5. Pin: 4052

6. CWBS Element: CET-PD-OT-TR-TRANSF

CWBS Description: Transformers (580)

7. SRIIM Eligible: Yes

SCE$

2019 - 2023 Total

452,228



2019 2020 2021 2022 2023

93



$0

$2,000

$4,000

$6,000

$8,000

$10,000

$12,000

Year




20202019 2021 2022 2023

7,285 6,334 10,891 11,206 11,528









4. RO Model ID: 872

5. Pin: 4052

6. CWBS Element: CET-PD-OT-TR-PL

CWBS Description: Transformers (580) - Pole Loading


SCE$

2019 - 2023 Total

47,244



2019 2020 2021 2022 2023

94



Workpaper Title:

Distribution Transformers – 2021

95



W

OR

KP

AP

ER

TIT

LE

:

Dis

trib

utio

n T

rans

form

ers -

202

1 W

BS

Ele

men

t - C

ET

-PD

-OT

-TR

W

orkp

aper

Titl

e: D

istri

butio

n Tr

ansf

orm

ers

- 202

1 E

xhib

it: S

CE

-02,

Vol

. 1, P

t. 2

Witn

ess:

Ter

ry O

hani

an

96



Dev

elop

men

t of U

nit C

ount

T

o d

evel

op t

he

dis

trib

uti

on t

ransf

orm

ers

unit

count

fore

cast

nee

ded

at

the

acti

vit

y l

evel

, an

act

ivit

y s

pen

d p

er t

ransf

orm

er r

ate

is

calc

ula

ted. T

he

acti

vit

y s

pen

d p

er t

ransf

orm

er r

epre

sents

that

the

acti

vit

y w

ill

requir

e one

tran

sform

er u

nit

for

ever

y 'X

' doll

ars

spen

t.

In o

rder

to c

alcu

late

th

e ac

tivit

y s

pen

d p

er t

ransf

orm

er r

ate,

SC

E a

nal

yze

s th

e his

tori

cal

quan

tity

of

tran

sform

ers

use

d f

or

the

acti

vit

y

along w

ith

the

tota

l re

cord

ed c

apit

al e

xpen

dit

ure

s bet

wee

n 2

014 a

nd 2

018.

Usi

ng t

his

dat

a, a

5 y

ear

wei

ghte

d a

ver

age

is t

hen

calc

ula

ted a

t th

e ac

tivit

y l

evel

by t

akin

g t

he

tota

l re

cord

ed e

xpen

dit

ure

s div

ided

by t

he

tota

l tr

ansf

orm

er q

uan

titi

es u

sed d

uri

ng t

he

his

tori

cal

tim

e per

iod.

Bel

ow

is

an e

xam

ple

cal

cula

ting t

he

acti

vit

y s

pen

d p

er t

ransf

orm

er f

or

the

Dis

trib

uti

on C

apit

al P

reven

tive

Mai

nte

nan

ce a

ctiv

ity:

The

tota

l tr

ansf

orm

er q

uan

tity

use

d b

etw

een 2

014 a

nd 2

018

= 3

3,24

3

Tota

l re

cord

ed c

apit

al e

xpen

dit

ure

s bet

wee

n 2

014

and 2

018 =

~$6

62,2

28,0

00

Usi

ng a

5 y

ear

wei

ghte

d a

ver

age,

the

app

rox

imat

e ac

tivit

y s

pen

d p

er t

ransf

orm

er =

~$662,2

28,0

00 ÷

33,2

34 =

~$2

0,00

0

T

he

tran

sform

er u

nit

fore

cast

is

then

cal

cula

ted

by d

ivid

ing t

he

acti

vit

y's

cap

ital

ex

pen

dit

ure

fore

cast

per

giv

en y

ear

2019 a

nd 2

023 b

y

the

acti

vit

y s

pen

d p

er t

ransf

orm

er r

ate

as s

how

n b

elow

.

W

orkp

aper

Titl

e: D

istri

butio

n Tr

ansf

orm

ers

- 202

1 E

xhib

it: S

CE

-02,

Vol

. 1, P

t. 2

Witn

ess:

Ter

ry O

hani

an

97



Dev

elop

men

t of C

osts

T

o d

evel

op t

he

dis

trib

uti

on t

ransf

orm

ers

cost

fore

cast

at

the

acti

vit

y l

evel

, th

e tr

ansf

orm

er u

nit

cost

is

calc

ula

ted b

y u

sin

g a

3 y

ear

wei

ghte

d a

ver

age.

The

capit

al e

xpen

dit

ure

fore

cast

is

then

der

ived

by t

akin

g t

he c

alcu

late

d p

rice

per

tra

nsf

orm

er t

imes

the

unit

fore

cast

per

giv

en y

ear

bet

wee

n 2

019 a

nd 2

023.

Bel

ow

is

an e

xam

ple

cal

cula

ting t

he

Dis

trib

uti

on T

ransf

orm

er c

apit

al e

xpen

dit

ure

fore

cast

for

Dis

trib

uti

on C

apit

al P

reven

tive

Mai

nte

nan

ce a

ctiv

ity:

SC

E a

nal

yzed

his

tori

cal

dat

a of

unit

ized

work

ord

ers.

The

anal

ysi

s su

gges

ted t

hat

SC

E n

eeds

ones

tra

nsf

orm

er f

or

ever

y $

20

,000

spen

d i

n D

istr

ibuti

on C

apit

al P

reven

tive

Mai

nte

nan

ce w

ork

. T

he

cost

of

acquir

ing t

ransf

orm

ers

for

this

act

ivit

y i

s ap

pro

xim

atel

y

$4,2

30 p

er u

nit

.

T

he

fore

cast

count

of

tran

sform

ers

per

yea

r is

gen

erat

ed b

y d

ivid

ing t

he

capit

al e

xpen

dit

ure

fore

cast

for

Dis

trib

uti

on C

apit

al

Pre

ven

tive

Mai

nte

nan

ce f

or

2019

-2023 b

y t

he

aver

age

spen

d p

er t

ransf

orm

er.

The

tota

l ex

pen

dit

ure

s fo

r tr

ansf

orm

ers

in s

up

port

of

Dis

trib

uti

on

Cap

ital

Pre

ven

tive

Mai

nte

nan

ce i

s th

e co

unt

of

tran

sform

er f

ore

cast

s ti

mes

the

tota

l unit

cost

of

the

tran

sform

er a

s sh

ow

n

above.

Wor

kpap

er T

itle:

Dis

tribu

tion

Tran

sfor

mer

s - 2

021

Exh

ibit:

SC

E-0

2, V

ol. 1

, Pt.

2 W

itnes

s: T

erry

Oha

nian

98



Workpaper Title:

Distribution Preventive and Breakdown Maintenance Transformers – 2021

99



Wor

kpap

er T

itle:

Dis

tribu

tion

Prev

entiv

e an

d B

reak

dow

n Tr

ansf

orm

ers -

202

1Ex

hibi

t: S

CE-

02, V

ol. 1

, Pt.

2N

ame:

Dis

tribu

tion

Mai

nten

ance

and

Insp

ectio

n an

d C

apita

l Rel

ated

Exp

ense

and

Oth

erW

itnes

s: T

erry

Oha

nian

Act

ivity

Nam

e: D

istri

butio

n Tr

ansf

orm

ers

1. C

alcu

latio

n of

Dis

tribu

tion

Prev

entiv

e an

d B

reak

dow

n M

aint

enan

ce C

apita

l Tra

nsfo

rmer

s with

out E

OI r

educ

tion.

2019

2020

2021

2022

2023

2019

2020

2021

2022

2023

Dis

tribu

tion

Cap

ital P

reve

ntiv

e M

aint

enan

ce14

0,95

9

15

2,09

2

16

1,92

3

17

1,42

6

18

1,42

9

29

,913

32

,275

34

,361

36

,378

38

,501

R

emov

e Id

le F

acili

ties

9,05

2

9,76

7

10,3

99

11,0

09

11,6

51

27

29

31

33

34

Dis

tribu

tion

Cap

ital B

reak

dow

n M

aint

enan

ce14

3,16

3

15

4,47

0

16

4,45

5

17

4,10

6

18

4,26

6

15

,574

16

,804

17

,890

18

,940

20

,045

To

tal

293,

175

316,

330

336,

777

356,

541

377,

346

45,5

13

49,1

08

52,2

82

55,3

50

58,5

80

2. C

alcu

latio

n of

Dis

tribu

tion

Prev

entiv

e an

d B

reak

dow

n M

aint

enan

ce C

apita

l Tra

nsfo

rmer

s with

EO

I red

uctio

n.

2019

2020

2021

2022

2023

2019

2020

2021

2022

2023

Dis

tribu

tion

Cap

ital P

reve

ntiv

e M

aint

enan

ce13

4,89

3

13

3,87

5

13

8,13

4

14

2,12

9

14

6,21

7

28

,625

28

,409

29

,313

30

,161

31

,028

R

emov

e Id

le F

acili

ties

8,31

4

8,25

1

8,51

4

8,76

0

9,01

2

25

24

25

26

27

Dis

tribu

tion

Cap

ital B

reak

dow

n M

aint

enan

ce13

6,91

3

13

5,88

0

14

0,20

2

14

4,25

8

14

8,40

7

14

,894

14

,781

15

,252

15

,693

16

,144

28

0,12

0

27

8,00

6

28

6,85

0

29

5,14

7

30

3,63

6

43

,544

43

,215

44

,590

45

,880

47

,199

2019

2020

2021

2022

2023

3. A

dditi

onal

tran

sfor

mer

fund

ing

requ

ired

if EO

I is n

ot a

utho

rized

.1,

969

5,

893

7,

692

9,

471

11

,381

Act

ivity

For

ecas

t ($0

00) -

Nom

inal

Tra

nsfo

rmer

For

ecas

t ($0

00) -

Nom

inal

Act

ivity

For

ecas

t ($0

00) -

Nom

inal

Tra

nsfo

rmer

For

ecas

t ($0

00) -

Nom

inal

Tra

nsfo

rmer

For

ecas

t ($0

00) -

Nom

inal

100



Workpaper Title:

PLP Transformers – 2021

101



Workpaper Title: PLP Transformers - 2021Exhibit: SCE-02, Vol. 1, Pt. 2Name: Distribution Maintenance and Inspection and Capital Related Expense and OtherWitness: Terry OhanianActivity Name: Distribution Transformers

2019 2020 2021 2022 2023PLP Replacements (1) 168,131$ 148,380$ 251,168$ 258,433$ 265,867$ PLP Underbuild (2) 6,570$ 3,522$ 10,004$ 10,293$ 10,589$ Total PLP Replacements & Underbuild (b + c) 174,701$ 151,902$ 261,172$ 268,726$ 276,456$ Calculated PLP Transformers (d x 0.0417) (3) 7,285$ 6,334$ 10,891$ 11,206$ 11,528$

Total PLP Transformers 7,285 6,334 10,891 11,206 11,528

(1) Total forecast for Distribution Pole Loading Program.(2) Total forecast for Distribution Pole Loading Underbuild.(3) Pole Loading Program Transformers is calculated by applying 4.17% to the forecast for the Distribution Pole Loading Program & PLPL Underbuild.

ForecastNominal $000

102



Workpaper Title:

Wildfire Covered Conductor Program Transformers – 2021

103



Wor

kpap

er T

itle:

Wild

fire

Cov

ered

Con

duct

or P

rogr

am T

rans

form

ers -

202

1Ex

hibi

t: S

CE-

02, V

ol. 1

, Pt.

2N

ame:

Dist

ribut

ion

Mai

nten

ance

and

Insp

ectio

n an

d C

apita

l Rel

ated

Exp

ense

and

Oth

erW

itnes

s: T

erry

Oha

nian

Act

ivity

Nam

e: W

ildfir

e C

over

ed C

ondu

ctor

Pro

gram

Tra

nsfo

rmer

s

Qua

litat

ive

Sum

mar

y

ID:

WF-

060

Del

iver

able

:FR

3 Tr

ansf

orm

ers

Des

cri p

tion:

Cur

rent

FR

3s in

stal

ls tri

gger

ed b

y fa

ilure

; thi

s SB9

01 p

ortio

n is

oppo

rtuni

tyA

dditi

onal

Det

ail:

Esc

alat

ion:

CA

P - D

istrib

utio

n

Qua

ntita

tive

Sum

mar

y (d

olla

rs in

thou

sand

s)

2019

2020

2021

2022

2023

2024

2025

2026

2027

2028

GS&

RP

Filin

g(2

018$

)-

$

-

$

-$

-$

-$

-$

-$

-$

-$

-$

L (2

018$

)-

$

-

$

-$

-$

-$

-$

-$

-$

-$

-$

NL

(201

8$)

-$

-$

-

$

-

$

-

$

-

$

-

$

-

$

-

$

-

$

(N

omin

al $

)-

$

-

$

-$

-$

-$

-$

-$

-$

-$

-$

L (N

omin

al$)

-$

-$

-

$

-

$

-

$

-

$

-

$

-

$

-

$

-

$

N

L (N

omin

al$)

-$

-$

-

$

-

$

-

$

-

$

-

$

-

$

-

$

-

$

U

nits

-

-

-

-

-

-

-

-

-

-

2019

2020

2021

2022

2023

2024

2025

2026

2027

2028

Op

Plan

Ref

resh

(Inc

rem

enta

l)(2

018$

)1,

089

$

3,50

8$

4,58

8$

4,

874

$

5,34

9$

3,

452

$

-$

-$

-$

-$

L (2

018$

)N

L (2

018$

)(N

omin

al $

)1,

131

$

3,78

4$

5,10

7$

5,

582

$

6,30

3$

4,

181

$

-$

-$

-$

-$

L (N

omin

al$)

NL

(Nom

inal

$)U

nits

545

1,

754

2,

294

2,43

7

2,

675

1,72

6

-

-

-

-

Dat

a/C

alcu

latio

n (d

olla

rs in

thou

sand

s)

Page 1 of 2

104



Wor

kpap

er T

itle:

Wild

fire

Cov

ered

Con

duct

or P

rogr

am T

rans

form

ers -

202

1Ex

hibi

t: S

CE-

02, V

ol. 1

, Pt.

2N

ame:

Dist

ribut

ion

Mai

nten

ance

and

Insp

ectio

n an

d C

apita

l Rel

ated

Exp

ense

and

Oth

erW

itnes

s: T

erry

Oha

nian

Act

ivity

Nam

e: W

ildfir

e C

over

ed C

ondu

ctor

Pro

gram

Tra

nsfo

rmer

s

Ass

umpt

ions

OH

tran

sfor

mer

s in

syst

em44

0,00

0

appr

oxim

ate

num

ber o

f OH

tran

sfor

mer

s in

entir

e sy

stem

(PR

ISM

mod

el)

100,

000

appr

oxim

ate

num

ber o

f OH

tran

sfor

mer

s in

HFR

A (P

RIS

M m

odel

plu

s HFR

A fi

lter)

23%

appr

oxim

ate

perc

enta

ge o

f OH

tran

sfor

mer

s in

HFR

AO

H tr

ansf

orm

er r

emov

als i

n sy

stem

(for

all

caus

es)

138,

000

appr

oxim

ate

tota

l OH

tran

sfor

mer

rem

oval

s (al

l) ov

er 1

1 ye

ars (

per C

YM

E-R

AM

stud

y fro

m 2

018

GR

C)

12,5

45

per y

ear O

H re

mov

als (

all)

23%

assu

med

HFR

A fr

actio

n2,

851

HFR

A re

mov

als p

er y

ear (

all)

51,0

00

appr

oxim

ate

tota

l OH

tran

sfor

mer

rem

oval

s (FA

ILU

RE

or N

EAR

FA

ILU

RE)

ove

r 11

year

s (pe

r CY

ME-

RA

M st

udy

from

201

8 G

RC

)4,

636

per y

ear O

H re

mov

als (

failu

re o

r nea

r-ter

m fa

ilure

)23

%as

sum

ed H

FRA

frac

tion

1,05

4

H

FRA

rem

oval

s per

yea

r (fa

ilure

or n

ear-t

erm

failu

re)

1,79

7

H

FRA

rem

oval

s per

yea

r (ot

her)

1.0

Failu

re o

r nea

r-ter

m fa

ilure

mul

tiplie

r - a

ssum

ed to

be

with

in to

p qu

artil

e p(

fail)

so 1

00%

of t

hese

are

with

in c

andi

date

poo

l0.

25O

ther

mul

tiplie

r - a

ssum

ed to

be

rand

omly

dist

ribut

ed a

mon

g p(

fail)

dist

ribut

ion

so 2

5% o

f the

se a

re w

ithin

can

dida

te p

ool

1,05

4

ca

ndid

ate

trans

form

er re

mov

als p

er y

ear (

failu

re o

r nea

r-ter

m fa

ilure

)44

9

cand

idat

e tra

nsfo

rmer

rem

oval

s per

yea

r (ot

her)

1,50

0

A

PPR

OX

IMA

TE

EX

PEC

TE

D R

ED

UC

TIO

N IN

CA

ND

IDA

TE

TR

AN

SFO

RM

ER

PO

PUL

AT

ION

PE

R Y

EA

R F

OR

NO

N-W

CC

P R

EM

OV

AL

RE

ASO

NS

2580

0El

igib

le T

rans

form

er P

opul

atio

n13

,000

To

tal H

FRA

Mile

s

Non

-Tie

red

Perc

enta

ge R

emov

ed12

.03%

2024

red

uced

by

abov

e pe

rcen

tage

of t

otal

pro

ject

cos

t (20

19-2

024)

2019

2020

2021

2022

2023

2024

2025

2026

2027

2028

Rem

oval

s fro

m e

ligib

le p

opul

atio

n1,

500

1,50

0

1,50

0

1,

500

1,50

0

1,

500

1,50

0

1,

500

1,50

0

1,

500

Rem

aini

ng C

andi

date

s 24

,300

22

,800

21,3

00

19,8

00

18,3

00

16,8

00

15,3

00

13,8

00

12,3

00

10,8

00

WC

CP

mile

s29

110

0014

0016

0019

0013

350

00

0W

CC

P an

nual

dep

loym

ent (

% o

f HFR

A)

2%8%

11%

12%

15%

10%

0%0%

0%0%

WC

CP

trans

form

er re

mov

al fo

reca

st54

5

1,75

4

2,29

4

2,

437

2,67

5

1,

726

-

-

-

-

Cos

t Per

Uni

t2.

00$

2.

00$

2.

00$

2.

00$

2.

00$

2.

00$

2.

00$

2.00

$

2.

00$

2.00

$

FR

3 T

rans

form

ers (

2018

$)1,

089

$

3,

508

$

4,

588

$

4,

874

$

5,34

9$

3,45

2$

-$

-$

-$

-$

Esc

alat

ion

Inde

x20

1920

2020

2120

2220

2320

2420

2520

2620

2720

28C

AP

- Dist

ribut

ion

1.03

86

1.07

88

1.

1131

1.

1453

1.

1782

1.

2112

1.

2464

1.

2835

1.

3219

1.

3620

FR

3 Tr

ansf

orm

ers (

2018

$)1,

089

$

3,50

8$

4,58

8$

4,

874

$

5,34

9$

3,

452

$

-$

-$

-$

-$

FR3

Tra

nsfo

rmer

s (N

omin

al$)

1,13

1$

3,78

4$

5,10

7$

5,58

2$

6,

303

$

4,

181

$

-

$

-

$

-

$

-

$

Page 2 of 2

105



Workpaper Title:

Capital detail for Wildfire Covered Conductor Programs Transformers

106



$0

$1,000

$2,000

$3,000

$4,000

$5,000

$6,000

$7,000

Year




20202019 2021 2022 2023

1,131 3,784 5,107 5,582 6,303









4. RO Model ID: 871

5. Pin: 4052

6. CWBS Element: CET-PD-OT-TR-FR

CWBS Description: Transformers (SB901)


SCE$

2019 - 2023 Total

21,907



2019 2020 2021 2022 2023

107

:runsdshuv · 2019. 8. 30. · 6 refer to wp sce-02, vol. 01, pt. 2, pp. 4-9 – memo of...

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