advice letter al 233-g/4205-e and · schedules for fixed usage and unmetered service (schedules...

STATE OF CALIFORNIA GAVIN NEWSOM, Governor

PUBLIC UTILITIES COMMISSION

505 VAN NESS AVENUE

SAN FRANCISCO, CA 94102-3298

July 2, 2020

Advice Letter AL 233-G/4205-E and

AL 233-G-A/4205-E-A

Gary A. Stern

Director, State Regulatory Operations

Southern California Edison Company

8631 Rush Street

Rosemead, CA 91770

SUBJECT: Implementation of Emergency Disaster Relief Program in Southern

California Edison Company's Service Territory Due to the Novel

Coronavirus Pandemic Pursuant to Resolution M-4842.

Dear Mr. Stern:

Advice Letter 233-G/4205-E and 233-G-A/4205-E-A is effective as of March 4, 2020.

Sincerely,

Edward Randolph

Deputy Executive Director for Energy and Climate Policy/

Director, Energy Division

P.O. Box 800 8631 Rush Street Rosemead, California 91770 (626) 302-9645 Fax (626) 302-6396

Gary A. Stern, Ph.D. Managing Director, State Regulatory Operations

May 1, 2020

ADVICE 233-G/4205-E (U 338-E)

PUBLIC UTILITIES COMMISSION OF THE STATE OF CALIFORNIA ENERGY DIVISION

SUBJECT: Implementation of Emergency Disaster Relief Program in Southern California Edison Company’s Service Territory Due to the Novel Coronavirus Pandemic Pursuant to Resolution M-4842

Southern California Edison Company (SCE) hereby submits to the California Public Utilities Commission (Commission) the following changes to its tariffs. The tariffs are listed on Attachment A and are attached hereto.

PURPOSE

Pursuant to Ordering Paragraph (OP) 2 of Resolution M-4842 (Resolution), SCE submits this advice letter describing all reasonable and necessary actions to implement emergency customer protections for customers1 adopted in Decision (D.)19-07-015 to support customers during the novel coronavirus (COVID-19) pandemic. Also, SCE is establishing the COVID-19 Pandemic Protections Memorandum Account (CPPMA) for both the electric utility and Catalina gas utility, as directed by Resolution M-4842. BACKGROUND

On March 4, 2020, Governor Newsom declared a statewide emergency due the COVID-19 pandemic.2 In response, SCE voluntarily suspended disconnections for nonpayment and implemented flexible payment plans for all residential and non-residential customers. On March 17, 2020, the Commission’s Executive Director sent a letter to SCE and other Commission-regulated utilities stating the Commission’s expectation that they “extend the same applicable consumer protections directed in D.19-07-015 and D.19-08-025 to customers,” retroactive to March 4, 2020. The latter

1 “Customers” include gas customers served by SCE on Santa Catalina Island. 2 On March 13, 2020, President Trump issued a similar Federal Proclamation stating “that

the COVID-19 outbreak in the United States constitutes a national emergency, beginning March 1, 2020.”

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two decisions aimed to benefit residential and small business customers impacted by then-recent wildfires and related events. The March 17, 2020, letter did not indicate that the measures were aimed exclusively at residential and small commercial customers, and it appeared to look favorably on broader voluntary moratoriums then in place, noting that “some utilities have already announced voluntary moratoriums on service disconnections for non-payments.” (In a companion press release issued the same day, the Commission stated that “Certain utilities and service providers have already announced voluntary moratoriums on service disconnections for non-payment, and today’s action ensures that they continue the moratoriums and that any energy, water, sewer, and communications company under the CPUC’s jurisdiction follows suit.”3) The March 17 letter referred to “consumer protection measures for customers in California,” noting that the pandemic “will be extremely disruptive to all Californians.”4 On March 19, 2020, in response to a directive in the March 17 letter, SCE submitted Advice Letter (AL) 230-G/4174-E (Original AL) to implement emergency consumer protection measures, writing it had implemented a moratorium on disconnections for nonpayment for all customers regardless of type or size. The Original AL also described implementation of flexible payment plans, waiver of deposits and late payment fees, and measures to support low-income customers. Additionally, in the Original AL, SCE proposed to track the expenses associated with these customer protection measures in the existing Emergency Customer Protections Memorandum Account (ECPMA). On April 16, 2020, the Commission adopted a resolution titled Emergency Authorization and Order Directing Utilities To Implement Emergency Customer Protections To Support California Customers During The Covid-19 Pandemic (Resolution), which ratified the directives in the Executive Director’s March 17 letter. The Resolution also directed utilities, “[t]o the extent that they have not already done so in response to the [Letter]” or to the extent their initial filings were not “fully responsive to the requirements of this Resolution,”5 to submit a Tier 2 AL to implement the Resolution and to recover the associated expenses through a to-be-established COVID-19 Pandemic Protections Memorandum Account (CPPMA). In this advice letter, SCE complies with the Commission’s directives in OPs 2 and 4 of the Resolution by: (1) supplementing the protections provided in its Original AL, as required by the Commission, and (2) requesting authorization to track in the CPPMA the incremental costs associated with complying with the Resolution, including with respect to the customer protections set forth in the Original AL. Part A, below, describes the applicable consumer protection measures for residential and small commercial customers consistent with the Resolution. Part B describes the

3 See http://docs.cpuc.ca.gov/PublishedDocs/Published/G000/M329/K673/329673725.PDF 4 March 17, Letter from Executive Director Stebbins (Emphasis added). 5 Resolution, p. 6.

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consumer protection measures SCE extended to medium and large commercial customers. Part C describes additional consumer protection measures that go beyond those set forth in the Resolution. Following that discussion, SCE describes the scope of costs it intends to track in the CPPMA. DISCUSSION

A. SCE Will Continue to Implement Applicable Emergency Customer Protections to All Residential and Small Business Customers

This AL is intended to supplement and replace portions of AL 230-G/4174-E to align with the directives in the Resolution, including identification of protections that do not apply in the current emergency. SCE will implement specific customer protections from Resolution M-4842 and D.19-07-015, as well as the additional customer relief provisions set forth below, for all residential and small business customers,6 effective March 4, 2020. These customer protections will remain in place until April 16, 2021, or as otherwise ordered by the Commission.7 However, as SCE proposed in AL 230-G / 4174-E, SCE requests that SCE be permitted to supplement this AL in the next three months or by August 1, 2020, to evaluate any changes to the current conditions so that the Commission can determine whether the protections should remain in place, be extended, or be discontinued. The following sections describe SCE’s approach to implementing or declining to implement the various customer protections for residential and small business customers set forth in Resolution M-4842. 1. Waive deposit requirements for residential and small business customers seeking to reestablish service for one year and expedite move-in and move-out service requests.

6 As defined in SCE’s Rule 1, Definitions, Small Business Customer: For purposes of

assessing deposits and effectuating certain rebills…a Small Business Customer is a non-residential customer with either a demand of 20 kW or less during the previous calendar year, or an annual usage of 40,000 kWh or less during the previous calendar year. For customers with more than one service account, SCE will aggregate monthly usage data over that calendar year, and will aggregate the maximum peak annual demand for each service account. This definition of Small Business Customer excludes customers on rate schedules for fixed usage and unmetered service (Schedules LS-1, LS-2, DWL, OL-1, TC-1, Wi-Fi-1, and WTR). Per Decision 10-10-032 and Decision 10-11-037, to be treated as a “Small Business Customer” under this definition, non-residential customers who do not meet the above-described electric demand or usage criteria, or for whom SCE lacks 12 months of data from the previous calendar year, may self-certify as a “Micro-Business” under California Government Code 14837 by submitting SCE Form 14-904, Southern California Edison Company Micro-Business Self-Certification Affidavit.

7 In AL 230-G/4174-E, SCE proposed to extend protections to customers who self-identified as being affected by COVID-19. SCE is withdrawing that proposal and will extend protections to all residential and small business customers.

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SCE will not waive deposit requirements for customers seeking to reestablish service because there has been no disruption or degradation of service resulting in the need for customers to relocate and reestablish service. However, as part of its normal practice, SCE does not charge deposits for reestablishment of service for customers who have already established satisfactory credit with SCE. Furthermore, as discussed in section 6 below, SCE is waiving deposits for residential and small commercial customers who, based on late payment patterns, would have received a deposit request in order to reestablish their credit with SCE. SCE will not implement the expedited move-in and move-out service request protection given that there has not been a disruption or degradation of electric service that would necessitate this measure. SCE’s normal business process provides for turn-ons on the same day or within 24 hours of the customer’s request. 2. Stop estimated usage for billing attributed to the time period when a home/unit was unoccupied as a result of the emergency. SCE will not implement this protection because there has not been a disruption or degradation of service as a result of the COVID-19 crisis. This measure would typically be appropriate to implement when customers have had to leave their homes following a natural disaster or emergency, which has generally not occurred during the COVID-19 crisis. 3. Identify the premises of affected customers whose utility service has been disrupted or degraded and discontinue billing these premises without assessing a disconnection charge. SCE will not implement this protection because service has not been disrupted or degraded as a result of the COVID-19 crisis. However, SCE has suspended all disconnections for nonpayment as described in Section 6 below. 4. Prorate any monthly access charge or minimum charges. SCE will not prorate any monthly access charges or minimum charges because there has been no disruption or degradation of service resulting in a need to modify such charges. 5. Implement payment plan options for residential and small business customers. SCE has implemented flexible payment plans for residential and small business customers. SCE works with customers to establish reasonable payment arrangements based on the specific needs of each customer. SCE may also recommend agency assistance and programs available to customers. At a minimum, as directed in D.19-07-015, the following bill payment arrangements will be offered to residential and small commercial customers who have prior arrearages:

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• Initial payment no greater than 20 percent of the amount due; and • The remainder in equal installments over at least 12 billing cycles.

For those customers with utility service but who went or will go into arrearage after March 4, 2020, SCE will establish the following bill payment arrangements as directed in D.19-07-015:

• Initial payment no greater than 20 percent of the amount due; and • The remainder in equal installments over at least 8 billing cycles.

SCE has trained its dedicated call center staff to inform and support customers to determine if programs are available to provide financial assistance or determine if extended payment arrangements should be made.

6. Suspend disconnection for nonpayment and associated fees, waive the deposit and late fee requirements.

SCE has suspended disconnections for nonpayment and waived the late fees and deposit requirements for the reestablishment of credit for all residential and small business customers. However, SCE will continue to charge a security deposit for customers who have not yet established credit (e.g., new customer turn-ons). Although the Resolution notes the suspension of disconnections for nonpayment should be applied to residential customers,8 SCE has extended this protection to small business customers and proposes to continue this measure for these customers given the overall guidance provided in the Resolution. SCE does not report late payments to credit reporting agencies on accounts that are active. In addition, SCE proposes to waive late payment charges for all residential and small business customers during the pendency of the COVID-19 crisis. 7. Support low-income residential customers by:

a) Freezing all standard and high-usage reviews for the California Alternate Rates for Energy (CARE) and Family Electric Rate Assistance (FERA) program eligibility for 12 months and potentially longer, as warranted;

SCE has frozen CARE/FERA program standards and high-usage post-enrollment verifications for all customers.

8 Resolution, p. 5.

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b) Contacting all community outreach contractors, the community-based

organizations (CBOs) who assist in enrolling hard-to-reach low-income customers into CARE, in helping better inform customers of these eligibility requirements;

SCE has partnered with its network of over 100 non-profit community- and faith-based organizations across its vast service territory to assist customers in enrolling in income-qualified programs such as CARE/FERA. Further, SCE conducted two webinars with CBOs to provide them with a refresh on SCE’s Income-Qualified Programs (IQP), where 47 organizations attended from the Rate Options Program in addition to capitation agencies for CARE/FERA. SCE provided copies of the presentation and a recorded Skype session in case they would like to provide further training within their organizations.

c) Partnering with the program administrator of the customer funded emergency

assistance program for low-income customers and increase the assistance limit amount for the next 12 months; and

SCE has partnered with SCE's Energy Assistance Fund (EAF) administrator to provide up to an additional $100 in one-time bill payment assistance to all affected income-eligible customers in SCE’s service territory.9 In addition, as part of SCE’s plan for enhanced CARE/FERA outreach efforts due to COVID-19, SCE anticipates sending 1.5 million texts to customers who have opted-in to receiving communications from SCE. These campaigns direct recipients to visit SCE.com/billhelp or to call SCE’s Customer Contact Center (CCC) if they are facing hardships caused by COVID-19.

d) Indicate how the energy savings assistance program can be deployed to assist

customers.

As noted in AL 230-G / 4174-E, as a result of the COVID-19 pandemic, the current guidance is for the public to self-quarantine when appropriate and generally shelter-in-place. Thus, SCE is not planning to deploy energy savings assistance (ESA) contractors to assist affected customers or have staff available at Local Assistance Centers (LACs), as it would for other types of emergencies, due to health concerns for its staff, contractors, and customers. However, SCE has taken actions directed by the Commission to support its ESA vendors with the goal of quickly ramping up ESA program operations to support our customers when it is safe to do so.

9 The list of EAF agencies is available at https://www.sce.com/wps/wcm/connect/4cfdeac8-

2d86-4b34-ba2501c8f4e5abdc/EAF+Agency+Roster_AA.pdf?MOD=AJPERES.

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8. Suspend all removals from CARE/FERA program to avoid unintentional loss of the discounted rate during the period for which the customer is protected under these customer protections.

SCE has suspended all utility-initiated CARE and FERA program removals to avoid unintentional loss of the discounted rate during this period. However, SCE will remove customers from CARE or FERA upon their request.

9. Discontinue generating all recertification and verification requests that require customers to provide their current income information. SCE has discontinued generating all recertification and verification requests for the CARE and FERA programs. 10. Offer repair processing and timing assistance and timely access to utility customers pursuant to Section (§) 8386(c)(18).

SCE will not offer repair processing and timing assistance and timely access because there was no disruption or degradation of service as a result of the COVID-19 crisis.

11. Include customer protections as part of the larger community outreach and public awareness plans under §8386(c)(16)(b).

SCE has undertaken outreach to customers to inform them about their eligibility for SCE's emergency disaster relief program through targeted messaging using the customers’ preferred methods of contact to inform them of the eligibility for customer protections.

Attachment B includes SCE’s Communication Plan, which conveys the availability of these protections and promotes consumer awareness.

12. Meet and confer with the CCAs as early as possible to discuss their roles and responsibilities for each emergency customer protection. Prior to the issuance of the Resolution, SCE had already begun to closely coordinate with CCAs in its service territory about the various consumer protections and discuss issues that will likely have financial and/or operational impacts to the CCAs. This coordination has been productive in terms of understanding the operational and financial impacts to the CCAs, and SCE continues to communicate regularly with the CCAs regarding these issues. In addition, SCE is exploring changing its processes related to reversion of uncollected receivables from 180 days to 360 days and agreed to provide information to CCAs on payment arrangement details for shared customers. After the issuance of the Resolution, SCE held a meet-and-confer discussion on April 28 to discuss roles and responsibilities related to the customer protections listed in the Resolution. The meet-and-confer session was attended by representatives from all

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active CCAs in SCE’s service territory. SCE will continue coordinating with CCAs to address issues raised by the COVID-19 pandemic.

B. Consumer Protections Extended to Medium and Large Commercial Customers

As noted in the “Background” section above, SCE implemented consumer protection measures broadly for all customers beginning in mid-March. Because of the concerns with the broad impacts of the COVID-19 emergency on jobs and the economy across the State, SCE made several consumer protections available to medium and large commercial customers. SCE made the Commission aware of its broader moratorium on disconnections in the Original AL.10 The Resolution recognized SCE’s self-initiated steps, noting that “[s]ome companies have already implemented emergency protections in response to the COVID-19 pandemic, including but not limited to [o]bserving a moratorium on electric …service disconnections for nonpayment and waiving late fees.”11 The broader moratorium was consistent with the spirit of the Resolution, which stated:

These customer protections are a floor, not a ceiling. As we stated in D.19-07-015 and D.19-08-025, we support and encourage the utilities … to do more to help Californians in this time of need. The utilities … have the discretion to add additional customer relief efforts that are unique to their customers’ experience, or the specific type of damage a customer may suffer from as a result of COVID-19.12

SCE’s voluntary extension of consumer protection measures to medium and large commercial customers reflects a sentiment we believe the Commission shares, which is that our business community plays a pivotal role in sustaining employment to Californians within and outside of SCE’s service territory. To the extent these businesses face economic hardships because of the COVID-19 crisis, they too may need assistance at least through the shelter-in-place period. Their strength and resilience will redound to the benefit of the residential and small business customers who are the main focus of the Resolution.

10 SCE AL 230G/4174-E, p. 1. 11 Resolution, pp. 2-3 (citing SCE’s URL, which on the date the Resolution was issued

indicated that the service disconnections for nonpayment were intended to protect all customers).

12 Resolution, p. 4.

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To date, SCE has extended the following protections for medium and large commercial customers:

1. Suspension of disconnections for non-payment 2. Waiving of deposit requirements for re-establishment of service 3. Implementation of flexible payment plan options 4. Waiving of late payment charges

Because SCE has made the Commission aware of its good faith intention to extend these consumer protection to medium and large commercial customers for the last several weeks, SCE seeks authority to track the incremental costs for these customers in the CPPMA starting March 4, 2020 and extending at least to the date on which this advice letter is approved. SCE welcomes additional direction from the Commission, either in connection with this advice letter or in some other forum, about the scope of any continued consumer protection measures that would be suitable for medium and large commercial customers after June 1, including clarity with respect to cost-tracking for post-June 1 protections. SCE requests the Commission provide clear direction by June 1, 202013 on consumer protection measures for medium and large commercial customers outlined above. Without further guidance as of that date, SCE plans to discontinue such protections for medium and large businesses.

C. Summary of Consumer Protection Measures for Residential and Small Business Customers Above Those Mandated By the Resolution

The following consumer protection measures for residential and small commercial customers were not specifically enumerated in the Resolution, but SCE has implemented them as of the date of this AL submittal, and will be tracking associated costs in the CPPMA: 1. Waiver of Medical Baseline Certification Signature at the Time of Enrollment SCE normally requires customers applying for Medical Baseline to submit the Medical Baseline Allowance Application with a signature from their medical doctor, doctor of osteopathy, physician assistant, or nurse practitioner certifying the customer has a medical condition. Given the challenges posed by the COVID-19 pandemic and the shelter-in-place guidelines, customers can enroll in the Medical Baseline program online without a medical signature for a period of one year beginning March 4, 2020. SCE is waiving the signature requirement on the Medical Baseline Allowance Application at the time of enrollment, and allowing customers to re-submit the certification within one year of their enrollment on Medical Baseline with the necessary signature. Furthermore, SCE

13 This Tier 2 advice letter should be resolved within 30 days, if not sooner.

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is deferring Medical Baseline renewals and certifications so that customers will not be removed from Medical Baseline while these measures are in effect. 2. Waive Service Connection Charge for small and medium business customers For SCE’s small and medium business customers that have elected to curtail routine business activities and/or closed business operations during the COVID-19 pandemic, SCE is waiving the standard $30 service connection charge when the customer elects to re-start their service.14 COVID-19 PANDEMIC PROTECTIONS MEMORANDUM ACCOUNT

Pursuant to Resolution M-4842, SCE is establishing the CPPMA for both the electric utility and the Catalina gas utility. The CPPMA will track costs associated with the customer protections set forth herein; protections/measures that may be offered in SCE’s reasonable discretion during the pendency of the pandemic, and other costs that the Commission has deemed appropriate for inclusion in this account.15 For example, on April 23, 2020, the Commission issued draft Resolution E-5074 ratifying the Executive Director’s letters to direct Investor-Owned Utilities to offer a 60-day advance payment to ESA contractors. The draft Resolution states “In the event that the IOU incurs costs related to payment payback, the IOUs are instructed to track those costs in the COVID-19 memorandum accounts as set out by Resolution M-4842 to track incremental costs associated with complying with this Resolution.” 16 Therefore, SCE will track in the CPPMA the costs associated with ESA Prime contractor repayments as directed by Draft Resolution E-5074 (e.g., defaults and debt forgiveness) that are in excess of SCE’s authorized ESA budget, including unspent funds in the ESA balancing account. In addition, SCE will track cost, revenue and fee shortfalls related to the customer protections identified in Resolution M-4842 and herein, including, but not limited to, waiving deposits, implementing extra payment plans, freezing CARE high-usage eligibility, waiving late fees for residential and small business customers, and customer outreach costs. As noted in Part B above, SCE seeks authority to track costs it incurred to extend consumer protections to medium and large commercial customers at least through the date of the disposition of this advice letter, if not longer should the Commission determine that would be reasonable.

14 The Non-Residential Service Connection Charge will not apply to accounts with monthly

Maximum Demands below 200 kW. 15 Resolution, pp. 5-6. 16 Draft Resolution E-5074, p. 12. If the final Resolution E-5074 modifies this requirement,

SCE will submit a supplemental advice letter to update the CPPMA.

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As noted in D.12-03-054, “[a] moratorium or a cap on the number of disconnections could potentially lead to an excessive increase in write-offs of bad debt.”17 As such, SCE also proposes to track in the CPPMA the write-offs of bad debt (also referred to as uncollectible expense) related to the protections described in this advice letter to the extent they exceed and therefore are incremental to the amount authorized in SCE’s 2018 GRC.18 It is logical, reasonable, and consistent with the conclusions the Commission reached in D.12-03-054 to permit SCE to track uncollectible amounts attributable to increased disconnection protections in the CPPMA for future recovery from customers.19 In addition, SCE anticipates that it may incur incremental financing costs that would not be recovered via the commercial paper financing rates typically applied to revenue under-collections tracked in a memo account. For example, SCE may incur incremental costs associated with establishing and borrowing against a new credit facility in preparation for potential liquidity pressures resulting from reduced revenues related to COVID-19 (which will be attributable to both the customer protection measures adopted by Resolution M-4842 and Governor Newsom’s Stay-at-Home Order). The costs of this additional credit facility could include the upfront costs of establishing the facility, interest expense on the undrawn facility balance, and the interest expense on any amounts drawn from the facility.20 SCE proposes to track the costs associated with any additional credit facility associated with COVID-19-related reduced revenues in the CPPMA. SCE acknowledges that a portion of these incremental financing costs is related to Governor Newsom’s Stay-at-Home Order, and is not specifically related to Resolution M-4842, and thus may be more appropriately tracked in the Catastrophic Event Memorandum Account (CEMA). However, because SCE would procure a single additional credit facility for all of its COVID-19-related revenue shortfalls, SCE requests that it be allowed to track all associated financing costs in a single account because it

17 D.12-03-054, Finding of Fact 18. 18 Pursuant to D.19-05-020, SCE applies the authorized Uncollectible Factor of 0.211% to its

“net billed revenues” (i.e., billings to customers, excluding uncollectibles, franchise fees, and gross receipts tax, and estimates of unbilled revenues associated with customer usage in the month that will not be billed until the following month) to determine the “uncollectible expense authorized in the 2018 GRC.” SCE’s Uncollectible Factor is proposed and approved in the GRC, and remains fixed for the entire GRC period. SCE’s Uncollectible Factor proposal is typically informed by historical averages, but may also include adjustments where necessary. For example, in A.13-11-003, SCE’s 2015 GRC, SCE proposed to adjust its historical uncollectible expense to remove the impact of the residential disconnection measures required by D.12-03-054 until those measures were sunsetted. That proposal was approved by the CPUC in D.15-11-021. SCE will propose a similar adjustment to future Uncollectible Factor proposals to reflect the fact that increased uncollectible expense associated with Resolution M-4842 are being tracked and recovered through the CPPMA.

19 D.12-03-054, at pp. 5-6. 20 If SCE draws on the additional credit facility, the incremental cost will be the interest rate

difference between the facility rate and the Commercial Paper rate.

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will eliminate the need to artificially apportion the costs between the CPPMA and the CEMA. SCE proposes in this advice letter to track incremental financing costs related to COVID-19 in the CPPMA; however, if the Energy Division believes that these costs are more appropriately tracked in the CEMA, SCE respectfully requests that the disposition letter for this advice letter make that clear. Also, to the extent SCE will incur incremental costs to modify its billing systems to implement the consumer protection measures ordered by the Commission, SCE intends to track those costs in the CPPMA. Consistent with OP 1 of Resolution M-4842, SCE requests the effective date of the CPPMA be March 4, 2020, which is the date of the Governor’s State of Emergency declaration.21 Pursuant to the Resolution, SCE will seek recovery of these costs in its General Rate Case proceeding, the Energy Resource Recovery Account Review proceeding, or other appropriate proceeding.22 PROPOSED TARIFF LANGUAGE Pursuant to Resolution M-4842, and as discussed above, the following changes in bold, underlined, and/or strikeout text are being made to SCE’s gas and electric tariffs: Gas tariffs:

• SCE is establishing Preliminary Statement Part J, CPPMA

• SCE’s Rule 6, Establishment and Reestablishment of Credit, Section B, is modified to remove reference to customers who self-certify.

B. Reestablishment of Credit.

The following terms and conditions relating to the reestablishment of credit will not apply until further notice to residential and Small Business Customers to customers who self-certify that they have been financially affected by COVID-19:

• SCE’s Rule 11, Discontinuance and Restoration of Service, Section B, is

modified to remove reference to customers who self-certify.

21 See also March 17, 2020 letter from Ms. Alice Stebbins, Executive Director of the

Commission, stating that “[t]hese customer protections should be retroactively applied to March 4, 2020.”

22 Id.

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B. Nonpayment of Bills. The following terms and conditions relating to disconnections for nonpayment will not apply until further notice to residential and Small Business Customers to customers who self-certify that they have been financially affected by COVID-19:

Electric tariffs:

• SCE is establishing Preliminary Statement Part N.66, CPPMA.

• SCE’s Rule 6, Establishment and Re-Establishment of Credit, Section C, is modified to remove reference to customers who self-certify.

C. Re-establishment of Credit - All Classes of Service. The following terms and conditions relating to the re-establishment of credit will not apply until further notice to residential and Small Business Customers to customers who self-certify that they have been financially affected by COVID-19:

• SCE’s Electric Rule 9, Rendering and Payment of Bills, Section F, is modified to remove reference to customers who self-certify.

F. Late Payment Charge. The following terms and conditions relating to the Late Payment Charge will not apply until further notice to residential and Small Business Customers to customers who self-certify that they have been financially affected by COVID-19:

• SCE’s Electric Rule 11, Discontinuance and Restoration of Service, Section B, is modified to remove reference to customers who self-certify.

B. Nonpayment of Bills or Summary Bills. The following terms and conditions relating to disconnections for nonpayment will not apply until further notice to residential and Small Business Customers to customers who self-certify that they have been financially affected by COVID-19:

No cost information is required for this advice letter. This advice letter will not increase any rate or charge, withdraw service, or conflict with any other schedule, or rule.

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TIER DESIGNATION

Pursuant to OP 2 of Resolution M-4842, this advice letter is submitted with a Tier 2 designation. EFFECTIVE DATE

Although this is a Tier 2 advice letter and it would typically become effective 30 days after submittal, pursuant to OP 1 of Resolution M-4842, 23 SCE respectfully requests an effective date of March 4, 2020. This request is also consistent with the March 17, 2020 letter from the Executive Director stating, “[t]hese customer protections should be retroactively applied to March 4, 2020.”

NOTICE

Pursuant to the directive in Resolution M-4842 and General Order 96-B, SCE requests expedited disposition of this Advice Letter. SCE proposes a shortened protest period of five days and a shortened reply period of three days. Anyone wishing to protest this advice letter may do so by letter via U.S. Mail, facsimile, or electronically, any of which must be received no later than five days after the date of this advice letter. Protests should be submitted to:

CPUC, Energy Division Attention: Tariff Unit 505 Van Ness Avenue San Francisco, California 94102 E-mail: [email protected]

Copies should also be mailed to the attention of the Director, Energy Division, Room 4004 (same address above).

Protests and all other correspondence regarding this advice letter should also be sent by letter and transmitted via facsimile or electronically to the attention of:

Gary A. Stern, Ph.D. Managing Director, State Regulatory Operations Southern California Edison Company 8631 Rush Street Rosemead, California 91770

Telephone (626) 302-9645 Facsimile: (626) 302-6396 E-mail: [email protected]

23 OP 1 of Resolution M-4842 states, “Electric, gas, communications, and water and sewer

corporations subject to this Resolution shall retroactively apply the customer protection measures adopted in D.19-07-015 and D.19-08-0225 from March 4, 2020 onward.”

ADVICE 233-G/4205-E (U 338-E) - 15 - May 1, 2020

Laura Genao Managing Director, State Regulatory Affairs c/o Karyn Gansecki Southern California Edison Company 601 Van Ness Avenue, Suite 2030 San Francisco, California 94102 Facsimile: (415) 929-5544 E-mail: [email protected]

There are no restrictions on who may submit a protest, but the protest shall set forth specifically the grounds upon which it is based and must be received by the deadline shown above. In accordance with General Rule 4 of GO 96-B, SCE is serving copies of this advice letter to the interested parties shown on the attached Gas and Electric GO 96-B, R.18-03-011, R.10-02-005, A.14-11-007, R.13-11-005, A.17-01-013, et al., A.16-09-001, and R.15-05-006 service lists. Address change requests to the GO 96-B service list should be directed by electronic mail to [email protected] or at (626) 302-3719. For changes to all other service lists, please contact the Commission’s Process Office at (415) 703-2021 or by electronic mail at [email protected]. Further, under Public Utilities Code Section 491, notice to the public is given by submitting and keeping the advice letter at SCE’s corporate headquarters. To view other SCE advice letters submitted with the Commission, log on to SCE’s web site at https://www.sce.com/wps/portal/home/regulatory/advice-letters. For questions, please contact Eric Yamashita at (626) 302-7306 or by electronic email at [email protected].

Southern California Edison Company

/s/ Gary A. Stern Gary A. Stern, Ph.D.

GAS:ey:cm

ADVICE LETTER S U M M A R YENERGY UTILITY

Company name/CPUC Utility No.:

Utility type:Phone #:

EXPLANATION OF UTILITY TYPE

ELC GAS

PLC HEAT

MUST BE COMPLETED BY UTILITY (Attach additional pages as needed)

Advice Letter (AL) #:

WATERE-mail: E-mail Disposition Notice to:

Contact Person:

ELC = ElectricPLC = Pipeline

GAS = GasHEAT = Heat WATER = Water

(Date Submitted / Received Stamp by CPUC)

Subject of AL:

Tier Designation:

Keywords (choose from CPUC listing):AL Type: Monthly Quarterly Annual One-Time Other:If AL submitted in compliance with a Commission order, indicate relevant Decision/Resolution #:

Does AL replace a withdrawn or rejected AL? If so, identify the prior AL:

Summarize differences between the AL and the prior withdrawn or rejected AL:

Confidential treatment requested? Yes NoIf yes, specification of confidential information:Confidential information will be made available to appropriate parties who execute a nondisclosure agreement. Name and contact information to request nondisclosure agreement/access to confidential information:

Resolution required? Yes No

Requested effective date: No. of tariff sheets:

Estimated system annual revenue effect (%):

Estimated system average rate effect (%):

When rates are affected by AL, include attachment in AL showing average rate effects on customer classes (residential, small commercial, large C/I, agricultural, lighting).

Tariff schedules affected:

Service affected and changes proposed1:

Pending advice letters that revise the same tariff sheets:

1Discuss in AL if more space is needed.

CPUC, Energy DivisionAttention: Tariff Unit505 Van Ness AvenueSan Francisco, CA 94102 Email: [email protected]

Protests and all other correspondence regarding this AL are due no later than 20 days after the date of this submittal, unless otherwise authorized by the Commission, and shall be sent to:

Name:Title:Utility Name:Address:City:State:Telephone (xxx) xxx-xxxx:Facsimile (xxx) xxx-xxxx:Email:

Name:Title:Utility Name:Address:City:State:Telephone (xxx) xxx-xxxx: Facsimile (xxx) xxx-xxxx:Email:

Zip:

Zip:

mailto:EDTariffUnit%40cpuc.ca.gov?subject=

ENERGY Advice Letter Keywords

Affiliate Direct Access Preliminary StatementAgreements Disconnect Service ProcurementAgriculture ECAC / Energy Cost Adjustment Qualifying FacilityAvoided Cost EOR / Enhanced Oil Recovery RebatesBalancing Account Energy Charge RefundsBaseline Energy Efficiency ReliabilityBilingual Establish Service Re-MAT/Bio-MATBillings Expand Service Area Revenue AllocationBioenergy Forms Rule 21Brokerage Fees Franchise Fee / User Tax RulesCARE G.O. 131-D Section 851CPUC Reimbursement Fee GRC / General Rate Case Self GenerationCapacity Hazardous Waste Service Area MapCogeneration Increase Rates Service OutageCompliance Interruptible Service SolarConditions of Service Interutility Transportation Standby ServiceConnection LIEE / Low-Income Energy Efficiency StorageConservation LIRA / Low-Income Ratepayer Assistance Street LightsConsolidate Tariffs Late Payment Charge SurchargesContracts Line Extensions TariffsCore Memorandum Account TaxesCredit Metered Energy Efficiency Text ChangesCurtailable Service Metering TransformerCustomer Charge Mobile Home Parks Transition CostCustomer Owned Generation Name Change Transmission LinesDecrease Rates Non-Core Transportation ElectrificationDemand Charge Non-firm Service Contracts Transportation RatesDemand Side Fund Nuclear UndergroundingDemand Side Management Oil Pipelines Voltage DiscountDemand Side Response PBR / Performance Based Ratemaking Wind PowerDeposits Portfolio Withdrawal of ServiceDepreciation Power Lines

Gas Tariff Sheets

Public Utilities Commission 233-G Attachment A

Cal. P.U.C. Sheet No. Title of Sheet

Cancelling Cal. P.U.C. Sheet No.

1

Original 2262-G Preliminary Statements J Original 2263-G Preliminary Statements J Original 2264-G Preliminary Statements J Revised 2265-G Rules 6 Revised 2227-G Revised 2266-G Rules 11 Revised 2214-G Revised 2267-G Table of Contents Revised 2215-GRevised 2268-G Table of Contents Revised 2216-G

Southern California Edison Original Cal. PUC Sheet No. 2262-G Rosemead, California (U 338-E) Cancelling Cal. PUC Sheet No.

PRELIMINARY STATEMENT Sheet 1

(Continued) (To be inserted by utility) Issued by (To be inserted by Cal. PUC) Advice 233-G Carla Peterman Date Filed May 1, 2020 Decision Senior Vice President Effective Mar 4, 2020 1S12 Resolution M-4842

J. COVID-19 Pandemic Protections Memorandum Account (CPPMA)

a. Purpose

The purpose of the COVID-19 Pandemic Protections Memorandum Account (CPPMA) is to track costs associated with customer protections pursuant to D.19-07-015 and Resolution M-4842 as described in SCE’s Advice 232-G. The CPPMA will record costs incurred starting March 4, 2020, the date of Governor Newsom’s declared State of Emergency in California related to COVID-19, as well as pursuant to Ordering Paragraph 1 of Resolution M-4842, and related Executive Orders.

b. Eligibility

All residential and small business customers are eligible for the emergency customer protections set forth in D.19-07-015 and Resolution M-4842 as described in Advice 232-G, and the costs of providing these customer protections shall be tracked in the CPPMA until April 16, 2021, unless otherwise specified or extended by order of the Commission. The costs of providing these same customer protections for medium and large business customers shall be tracked at least through June 1, 2020. If some or all of these customer protections are offered to medium and large business customers for a longer period, the related costs for these customers shall also be tracked in the CPPMA.

c. Operation of the CPPMA

SCE shall maintain the CPPMA by making monthly entries as follows:

(1) A debit entry equal to the recorded incremental O&M expense and capital-related revenue requirements (depreciation, taxes and return on rate base) associated with the implementation of D.19-07-015, Resolution M-4842, and Advice 232-G. These O&M and capital costs may include implementation and other costs, related, but not limited, to:

a) Incremental costs to implement consumer protections, including IT and billing related costs; and

b) Customer outreach costs

(2) A debit entry equal to the revenue and fees shortfalls resulting from the implemented customer protections for residential and small business customers, including the waiving of late payment charges,

(3) A debit entry equal to the revenue and fees shortfalls resulting from

the implemented customer protections for small and medium business customers, including the waiving of service connection charges.



(Continued)


J. COVID-19 Pandemic Protections Memorandum Account (CPPMA) (Continued)

c. Operation of the CPPMA (Continued)


the implemented customer protections for medium and large business customers, including the waiving of late payment charges,

(5) A debit entry equal to revenue shortfalls resulting from uncollectibles that are in excess of those authorized in SCE’s last GRC for residential and small business customers related to the implemented customer protections such as the suspension of disconnections, waiving of security deposits, and implementation of flexible payment plans,

(6) A debit entry equal to revenue shortfalls resulting from uncollectibles

that are in excess of those authorized in SCE’s last GRC for medium and large business customers related to the implemented customer protections such as the suspension of disconnections, waiving of security deposits, and implementation of flexible payment plans,

(7) A debit entry equal to the cost of additional credit facility, including

the upfront costs of establishing the facility, interest expense on the undrawn facility balance, and the interest expense on any amounts drawn from the facility,

(8) A debit entry equal to the costs associated with ESA Prime

contractor repayments as directed by Resolution E-5074 (e.g., defaults and debt forgiveness) to the extent those costs exceed the authorized ESA budget and unspent funds in the ESA Balancing Account, and,

(9) A debit entry equal to any costs associated with future regulatory

requirements authorizing customer protections related to COVID-19, and

(10) A debit entry equal to any costs for additional protections/measures

(above those specified in D.19-07-015 and Resolution M-4842 as described in SCE’s Advice 232-G) that may be offered in SCE’s reasonable discretion during the pendency of the COVID-19 pandemic,



(Continued)


J. COVID-19 Pandemic Protections Memorandum Account (CPPMA) (Continued)

c. Operation of the CPPMA (Continued) (11) Interest shall accrue monthly by applying one-twelfth of the

Federal Reserve three-month Commercial Paper Rate – Non-Financial, from Federal Reserve Statistical Release H.15 (expressed as an annual rate) to the average monthly balance. If in any month a non-financial rate is not published, SCE shall use the Federal Reserve three-month Commercial Paper Rate – Financial.

d. Review and Disposition

Pursuant to Resolution M-4842, SCE may seek recovery of the costs recorded in the CPPMA in its General Rate Case proceeding, the Energy Resource Recovery Account Review proceeding, or other appropriate proceeding.

Southern California Edison Revised Cal. PUC Sheet No. 2265-G Rosemead, California (U 338-E) Cancelling Revised Cal. PUC Sheet No. 2227-G

Rule 6 Sheet 1 ESTABLISHMENT AND REESTABLISHMENT OF CREDIT

(To be inserted by utility) Issued by (To be inserted by Cal. PUC) Advice 233-G Carla Peterman Date Filed May 1, 2020 Decision Senior Vice President Effective Mar 4, 2020 1S9 Resolution M-4842

A. Establishment of Credit. Each applicant, before receiving service, will be required to satisfactorily establish his credit, which will be deemed established:

1. If applicant is the owner of the premises to be served or of other real estate within the

territory served by SCE; or 2. If applicant makes a cash deposit to secure payment of bills for the service as prescribed

in Rule 7; or 3. If applicant furnishes a guarantor, satisfactory to SCE, to secure payment of bills for the

service requested; or 4. If applicant has previously been a customer of SCE and during the last twelve

consecutive months of that prior service has paid all bills for gas service on the average within 15 days after presentation.

B. Reestablishment of Credit.

The following terms and conditions relating to the reestablishment of credit will not apply until further notice to residential and Small Business Customers:

1. An applicant who previously has been a customer of SCE and whose gas service has

been discontinued by SCE during the last twelve months of that prior service because of nonpayment of bills, may be required to reestablish credit by depositing the amount prescribed in Rule 7 for that purpose, and by paying gas bills regularly due; except an applicant for domestic service will not be denied service for failure to pay such bills for other classes or service.

2. A customer who fails to pay bills before they become past due as prescribed in Rule

11-A, and who further fails to pay such bills within 15 days after presentation of a discontinuance of domestic service notice or within 5 days after presentation of a discontinuance of nondomestic service notice for nonpayment of bills, may be required to pay said bills and reestablish his credit by depositing the amount prescribed in Rule 7. This rule will apply regardless of whether or not service has been discontinued for such nonpayment.

3. Domestic CARE customers who have already established credit with SCE are required

to pay a reestablishment of credit deposit following a disconnection of service. At SCE’s discretion, SCE may allow CARE customers to make payment arrangements of up to six months.

4. SCE may not assess a reestablishment-of-credit deposit when a Small Business

Customer, as defined in Rule 1, Definitions (or a customer who certifies that it meets the California Government Code Section 14837 definition of “Micro-Business”) fails to pay a bill resulting in whole, or in part, from a back-bill,

5. Before assessing a reestablishment-of-credit deposit on a Small Business Customer, as

defined in Rule 1, Definitions (or on a customer who certifies that it meets the California Government Code Section 14837 definition of “Micro-Business”), SCE must send a warning letter after at least one late payment during any twelve-month period. The warning letter will inform that customer that a reestablishment-of-credit deposit may be assessed if there is another late payment within the same twelve-month period.

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Rule 11 Sheet 1 DISCONTINUANCE AND RESTORATION OF SERVICE

(Continued) (To be inserted by utility) Issued by (To be inserted by Cal. PUC) Advice 233-G Carla Peterman Date Filed May 1, 2020 Decision Senior Vice President Effective Mar 4, 2020 1C11 Resolution M-4842

A. Past Due Bills. When bills are rendered monthly or bimonthly, they will be considered past due if not paid within 19 days after date of presentation. When bills are rendered weekly, they will be considered past due if not paid within 4 days after date of presentation.

B. Nonpayment of Bills.

The following terms and conditions relating to disconnections for nonpayment will not apply until further notice to residential and Small Business Customers:

1. When a bill for gas service has become past due and a 15-day discontinuance of

domestic service notice or a 5-day discontinuance of nondomestic service notice for nonpayment has been issued, service may be discontinued if bill is not paid within the time required by such notice. A customer's deposit to establish credit will not be used as payment to avoid discontinuance of service.

Any customer who has initiated a complaint or requested an investigation within 5

days of receiving a contested bill shall not have domestic service to a residential dwelling discontinued for late payment or nonpayment during the pendency of an investigation by SCE of such customer dispute or complaint. Such domestic service shall not be discontinued for late payment or nonpayment for any customer complying with an amortization agreement entered into with SCE, provided the customer also keeps current his account for gas service as charges accrue in each subsequent billing period. If a residential customer fails to comply with an amortization agreement, SCE shall not terminate service without giving notice to the customer, at least 48 hours prior to termination, of the conditions the customer is required to meet to avoid termination; but, such notice shall not entitle the customer to further investigation by SCE.

If there is an imminent service disconnection, SCE may contact the customer by telephone (including calls or text messages to mobile phones) under the emergency purpose provision described in Rule 3.F., or by e-mail when appropriate.

2. Gas service to a domestic customer will not be discontinued for late payment or

nonpayment when the customer has established to the satisfaction of SCE that: a. Such termination would be especially dangerous to the health of the customer

or a full time resident of the customer's household*; or b. The customer or a full time resident of the customer's household is among the

elderly (age 62 or older) or handicapped*; and c. He or she is temporarily unable to pay for such service in accordance with the

provisions of SCE’s tariffs; and * Certification from a licensed physician, public health nurse, social worker, or other medical professional

acceptable to SCE.

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TABLE OF CONTENTS Sheet 1

(Continued) (To be inserted by utility) Issued by (To be inserted by Cal. PUC) Advice 233-G Carla Peterman Date Filed May 1, 2020 Decision Senior Vice President Effective Mar 4, 2020 1H7 Resolution M-4842

Cal. P.U.C. Sheet No. TITLE PAGE .................................................................................................................................. 2104-G TABLE OF CONTENTS - RATE SCHEDULES ........................................................................... 2267-G TABLE OF CONTENTS - LIST OF CONTRACTS AND DEVIATIONS ...................................... 1980-G TABLE OF CONTENTS - RULES ................................................................................................. 2268-G TABLE OF CONTENTS - SAMPLE FORMS ............................................................................... 1981-G PRELIMINARY STATEMENT: A. Territory Served by the Utility ............................................................................................... 1388-G B. Types and Classes of Service ............................................................................................. 1388-G C. Procedure to Obtain Service ................................................................................................ 1388-G D. Interest ................................................................................................................................... 1388-G E. Symbols ................................................................................................................................ 1388-G F. Baseline Service .......................................................................................................... 1389-1826-G G. Santa Catalina Island Gas Cost Adjustment Clause (GCAC) ................. 1391-1392-1393-2171-G H. Income Tax Component of Contributions Provision ................................................... 2047-1892-G I. Catastrophic Event Memorandum Account (CEMA)……………………………………… 2238-G J. COVID-19 Pandemic Protections Memorandum Account……….. (CPPMA)).2262-2263-2264-G SERVICE AREA MAP ......................................................................................................................... 3-G

RATE SCHEDULES Schedule Cal. P.U.C. No. Title of Sheet No. DE Domestic Service to Utility Employees .................................................................. 1398-G G-1 Domestic Service ........................................................................................... 2172-2173-G G-1-CARE Domestic Service ........................................................................................... 2174-1132-G G-2 General Service ............................................................................................. 2175-1401-G G-OBR Santa Catalina Island On-Bill Repayment Pilot Program….. 2020-1633-1634-1635-G ............................................... ………………………………1636-1637-1638-1813-1814-G GM Domestic Service, Multifamily Accommodation ..................................................... 1402-G G-SE Service Establishment Charge ............................................................................... 1403-G RF-G Surcharge to Fund Public Utilities Commission Reimbursement Fee .................. 2035-G

LIST OF CONTRACTS AND DEVIATIONS Cal. P.U.C. Sheet No. List of Contracts and Deviations ...................................................................................................... 696-G

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(Continued)


Rules Cal. P.U.C. Rule Title Sheet No. 1 Definitions ........................................................................................................... 1787-1334-1335-G 2 Description of Service ........................................................................................................... 2103-G 3 Application for Service ................................................................................................. 1406-1769-G 4 Contracts ............................................................................................................................... 1407-G 5 Special Information Required on Forms ..................................................................... 1408-1409-G 6 Establishment and Re-establishment of Credit........... ......................................................... 2265-G 7 Deposits ................................................................................................................................. 1410-G 8 Notices .......................................................................................................................... 1770-1771-G 9 Rendering and Payment of Bills ........................................................................ 1788-1579-1175-G 10 Disputed Bills ......................................................................................................................... 1414-G 11 Discontinuance and Restoration of Service ................................... 2266-1713-1339-1340-1341-G ................................................................................................................... 1773-1774-1344-1345-G 12 Rates and Optional Rates ..................................................................................................... 1415-G 13 Temporary Service ............................................................................................................... 1416-G 14 Shortage of Supply and Interruption of Delivery .................................................................. 1417-G 15 Gas Main Extensions ..................................................................................................... 25-26-27-G 16 Service Connections, Meters and Customer's Facilities ..................................................... 28-29-G 17 Adjustment of Bills and Meter Tests ................................................................. 1346-1347-1348-G 18 Supply to Separate Premises and Resale .......................................................................... 1418-G Sample Forms Cal. P.U.C. Form Sheet No. CSD-378 Application and Contract for Gas and/or Water Service .............................................. 132-G CSD-470G 15 Day Notice of Service Termination ........................................................................ 1474-G 14-574.G Gas Statement ........................................................................................................... 1755-G 14-574.G.S Gas Statement-Simplified ........................................................................................... 1756-G 16-263 Income Tax Component of Contribution Agreement .................................................. 389-G 14-764 Catalina Gas LPP Settlement Sample ......................................................................... 737-G 14-765 Catalina Gas LPP Month #11 Sample ......................................................................... 738-G 14-815G Tenant Rights .............................................................................................................. 1475-G 14-938G Authorization to Add Loan Charges to SCE Bill (Non-Residential) ........................... 1864-G

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Electric Tariff Sheets

Public Utilities Commission 4205-E Attachment A

Cal. P.U.C. Sheet No. Title of Sheet

Cancelling Cal. P.U.C. Sheet No.

1

Revised 69058-E Preliminary Statements N Revised 68989-EOriginal 69059-E Preliminary Statements N Original 69060-E Preliminary Statements N Original 69061-E Preliminary Statements N Revised 69062-E Rules 6 Revised 68874-E Revised 69063-E Rules 9 Revised 68825-E Revised 69064-E Rules 11 Revised 68826-E Revised 69065-E Table of Contents Revised 68768-ERevised 69066-E Table of Contents Revised 68828-E

Southern California Edison Revised Cal. PUC Sheet No. 69058-E Rosemead, California (U 338-E) Cancelling Revised Cal. PUC Sheet No. 68989-E


(Continued)

(Continued) (To be inserted by utility) Issued by (To be inserted by Cal. PUC) Advice 4205-E Carla Peterman Date Submitted May 1, 2020 Decision Senior Vice President Effective Mar 4, 2020 3H15 Resolution M-4842

N. MEMORANDUM ACCOUNTS (Continued) 2. Definitions. (Continued) d. Specified Project (Continued) Section Interest Bearing No. Specified Project Memorandum Account* (34) Community Choice Audit Memorandum Account Yes (35) Aliso Canyon Energy Savings Assistance Program Memorandum Account Yes (36) Wireless Fidelity Costs Memorandum Account Yes (37) Residential Service Disconnection Memorandum Account (RSDMA) Yes (38) Tax Accounting Memorandum Account (TAMA) Yes (39) Renewables Portfolio Standard Costs Memorandum Account Yes (40) Greenhouse Gas (GHG) Customer Outreach and Education Yes Memorandum Account (GHGCO&EMA) (41) BioMass Memorandum Account Yes (42) Department of Energy Litigation Memorandum Account Yes (43) Bio RAM Memoramdum Account (BioRAMMA) Yes (44) Project Development Division Memorandum Account (PDDMA) Yes (45) Fire Risk Mitigation Memorandum Account Yes (46) Mohave SO2 Allowance Revolving Fund Memorandum Account (MSARFMA) Yes (47) Energy Division Director’s Peer Review Group Memorandum Account Yes (PRGMA) (48) Greenhouse Gas (GHG) Administrative Costs Memorandum Yes Account (GHGACMA) (49) Net Energy Metering Automation (NEM-A) Billing Automation Costs Memorandum Account (NEMABACMA) Yes (50) Not Used (51) Long-Term Procurement Plan Technical Assistance Yes Memorandum Account (LTAMA) (52) Wildfire Expense Memorandum Account (WEMA) Yes (53) Fire Hazard Prevention Memorandum Account (FHPMA) Yes (54) Service Center Modernization Projects Memorandum Account (SCMPMA) Yes (55) San Onofre Nuclear Generating Station Memorandum Account (SONGSMA) Yes (56) Customer Service Re-Platform Memorandum Account (CSRPMA) Yes (57) Energy Matinee Tariff Program Pilot Memorandum Account (EMTPPMA) Yes (58) Green Tariff Shared Renewables Administrative Costs Yes Memorandum Account (59) Green Tariff Marketing, Education & Outreach Memorandum Account Yes (60) Enhanced Community Renewables Marketing, Education & Outreach Yes Memorandum Account (61) Residential Rate Implementation Memorandum Account (RRIMA) Yes (62) Rule 21 Cost Envelope Option Memorandum Account (CEOMA) Yes (63) Tax Accounting Memorandum Account 2018 (TAMA 2018) Yes (64) California Consumer Privacy Act Memorandum Account (CCPAMA) Yes (65) Distributed Generation Statistics Contractor Memorandum Account (DGSCMA) Yes (66) COVID-19 Pandemic Protections Memorandum Account (CPPMA) Yes * Interest shall accrue monthly to interest-bearing Memorandum Accounts by applying the Interest Rate

to the average of the beginning and ending balance.

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(N)

Southern California Edison Original Cal. PUC Sheet No. 69059-E Rosemead, California (U 338-E) Cancelling Cal. PUC Sheet No.


(Continued)

(Continued) (To be inserted by utility) Issued by (To be inserted by Cal. PUC) Advice 4205-E Carla Peterman Date Submitted May 1, 2020 Decision Senior Vice President Effective Mar 4, 2020 94S29 Resolution M-4842

N. MEMORANDUM ACCOUNTS (Continued)

66. COVID-19 Pandemic Protections Memorandum Account (CPPMA)

a. Purpose

The purpose of the COVID-19 Pandemic Protections Memorandum Account (CPPMA) is to track costs associated with customer protections pursuant to D.19-07-015 and Resolution M-4842 as described in SCE’s Advice 4205-E. The CPPMA will track costs incurred starting March 4, 2020, the date of Governor Newsom’s declared State of Emergency in California related to COVID-19, as well as pursuant to Ordering Paragraph 1 of Resolution M-4842, and related Executive Orders.

b. Eligibility

All residential and small business customers are eligible for the emergency customer protections set forth in D.19-07-015 and Resolution M-4842 as described in Advice 4205-E, and the costs of providing these customer protections shall be tracked in the CPPMA until April 16, 2021, unless otherwise specified or extended by order of the Commission. The costs of providing these same customer protections for medium and large business customers shall be tracked at least through June 1, 2020. If some or all of these customer protections are offered to medium and large business customers for a longer period, the related costs for these customers shall also be tracked in the CPPMA.

c. Operation of the CPPMA

SCE shall maintain the CPPMA by making monthly entries as follows:

(1) A debit entry equal to the recorded incremental O&M expense and

capital-related revenue requirements (depreciation, taxes and return on rate base) associated with the implementation of D.19-07-015, Resolution M-4842, and Advice 4205-E. These O&M and capital costs may include implementation and other costs, related, but not limited, to: a) Incremental costs to implement customer protections, including

IT and billing-related costs; and b) Customer outreach costs


the implemented customer protections for residential and small business customers, including the waiving of late payment charges,

(3) A debit entry equal to the revenue and fees shortfalls resulting from the implemented customer protections for small and medium business customers, including the waiving of service connection charges.



(Continued)



66. COVID-19 Pandemic Protections Memorandum Account (CPPMA) (Continued)


(4) A debit entry equal to the revenue and fees shortfalls resulting from the implemented customer protections for medium and large business customers, including the waiving of late payment charges,

(5) A debit entry equal to revenue shortfalls resulting from uncollectibles that are in excess of those authorized in SCE’s last GRC for residential and small business customers related to the implemented customer protections such as the suspension of disconnections, waiving of security deposits, and implementation of flexible payment plans,

(6) A debit entry equal to revenue shortfalls resulting from uncollectibles that are in excess of those authorized in SCE’s last GRC for medium and large business customers related to the implemented customer protections such as the suspension of disconnections, waiving of security deposits, and implementation of flexible payment plans,

(7) A debit entry equal to the cost of additional credit facility, including

the upfront costs of establishing the facility, interest expense on the undrawn facility balance, and the interest expense on any amounts drawn from the facility,

(8) A debit entry equal to the costs associated with ESA Prime contractor

repayments as directed by Resolution E-5074 (e.g., defaults and debt forgiveness) to the extent those costs exceed the authorized ESA budget and unspent funds in the ESA Balancing Account, and,

(9) A debit entry equal to any costs associated with future regulatory

requirements authorizing customer protections related to COVID-19, and



(Continued)

(To be inserted by utility) Issued by (To be inserted by Cal. PUC) Advice 4205-E Carla Peterman Date Submitted May 1, 2020 Decision Senior Vice President Effective Mar 4, 2020 96S14 Resolution M-4842


66. COVID-19 Pandemic Protections Memorandum Account (CPPMA) (Continued)


(10) A debit entry equal to any costs for additional protections/measures

(above those specified in D.19-07-015 and Resolution M-4842 as described in SCE’s Advice 4205-E) that may be offered in SCE’s reasonable discretion during the pendency of the COVID-19 pandemic,

(11) Interest shall accrue monthly by applying one-twelfth of the Federal

Reserve three-month Commercial Paper Rate – Non-Financial, from Federal Reserve Statistical Release H.15 (expressed as an annual rate) to the average monthly balance. If in any month a non-financial rate is not published, SCE shall use the Federal Reserve three-month Commercial Paper Rate – Financial.

d. Review and Disposition

Pursuant to Resolution M-4842, SCE may seek recovery of the costs recorded in the CPPMA in its General Rate Case proceeding, the Energy Resource Recovery Account Review proceeding, or other appropriate proceeding.


Rule 6 Sheet 2 ESTABLISHMENT AND RE-ESTABLISHMENT OF CREDIT

(Continued)

(To be inserted by utility) Issued by (To be inserted by Cal. PUC) Advice 4205-E Carla Peterman Date Submitted May 1, 2020 Decision Senior Vice President Effective Mar 4, 2020 2C15 Resolution M-4842

C. Re-establishment of Credit - All Classes of Service.

The following terms and conditions relating to the re-establishment of credit will not apply until further notice to residential and Small Business Customers:

1. An applicant who previously has been a customer of SCE and whose electric service has

been discontinued by SCE during the last twelve months of that prior service because of nonpayment of bills or Summary Bill(s), may be required to re-establish credit by depositing the amount prescribed in Rule 7 and Rule 22 for that purpose, and by paying electric bills or Summary Bill(s) regularly due; except, an applicant for domestic service will not be denied service for failure to pay such bills for other classes of service.

2. A customer who fails to pay bills or Summary Bill(s) before they become past due as

prescribed in Rule 11.A and who further fails to pay such bills or Summary Bill(s) within 15 days after presentation of a discontinuance of domestic service notice or within 5 days after presentation of a discontinuance of nondomestic service notice for nonpayment of bills, may be required to pay said bills and re-establish credit by depositing the amount prescribed in Rule 7 and Rule 22. This rule will apply regardless of whether or not service has been discontinued for such nonpayment.

3. A customer taking service for other than domestic or being billed through a Summary Bill

which includes both domestic and nondomestic service accounts may be required to re-establish credit in accordance with Rule 6.B and Rule 22 in case the conditions of service or basis on which credit was originally established have, in the opinion of SCE, materially changed.

4. Domestic CARE or FERA customers who have already established credit with SCE are

required to pay SCE a reestablishment of credit deposit following a disconnection of service. At SCE’s discretion, SCE may allow CARE or FERA customers to make payment arrangements of up to six months.

5. Where the residential customer service disconnection practices ordered per D.12-03-054

require SCE to waive otherwise applicable customer deposits, SCE may require a deposit from residential customers who have written three or more bad checks within one year and from customers involved in fraud.

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Rule 9 Sheet 3 RENDERING AND PAYMENT OF BILLS

(Continued)

(Continued) (To be inserted by utility) Issued by (To be inserted by Cal. PUC) Advice 4205-E Carla Peterman Date Submitted May 1, 2020 Decision Senior Vice President Effective Mar 4, 2020 3C16 Resolution M-4842

E. Level Pay Plan. (Continued)

5. When a settlement bill is rendered, any amounts due for usage over and above plan amounts already paid are then due and payable in accordance with SCE's filed tariff schedules; any credit for plan amounts paid in excess of actual usage will be applied to the customer's next regular monthly bill or will be refunded by check if so requested by the customer.

6. Level Pay Plan amounts will be reviewed and may be adjusted if there is a 20% or greater difference (10% or greater for small commercial and lighting customers) from the current Level Pay Plan payment amount and the newly calculated Level Pay Plan payment amount based on such review.

7. Participants may be removed from the Plan if, in the opinion of SCE, the conditions of service or basis on which credit was originally established have materially changed. If a customer is removed from the Level Pay Plan, a settlement bill will be rendered as described in Section E.5. above.

For customers with a minimum of 365 days of service, the following condition applies:

The Level Pay Plan amount is based on the daily average bill amount in dollars, multiplied by 365 and divided by 11 months. The Level Pay Plan amount will be rounded up or down to the nearest $1.00.

For customers with less than 365 days of service or customers electing the Level Pay Plan at the time service begins at a specific service address, the following condition applies:

The Level Pay Plan amount will be based at one-half of the deposit base amount determined in accordance with the provisions of Section A.1 of Rule 7, Deposits, established on the account.

F. Late Payment Charge.

The following terms and conditions relating to the Late Payment Charge will not apply until further notice to residential and Small Business Customers:

A Late Payment Charge of 0.7% may be applied to the total unpaid balance of a domestic or non-domestic Customer Account if the customer's payment is not received by the date indicated on the Customer Account Bill or Summary Bill. Domestic California Alternate Rates for Energy (CARE) customers are exempt from application of the Late Payment Charge.

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Rule 11 Sheet 1 DISCONTINUANCE AND RESTORATION OF SERVICE

(Continued) (To be inserted by utility) Issued by (To be inserted by Cal. PUC) Advice 4205-E Carla Peterman Date Submitted May 1, 2020 Decision Senior Vice President Effective Mar 4, 2020 1C15 Resolution M-4842

A. Past Due Bills or Summary Bills. When bills or domestic Summary Bills for electric service or for SCE services provided beyond the Point of Delivery are rendered monthly or bimonthly, they will be considered past due if not paid within 19 days after date of presentation. When bills are rendered weekly, they will be considered past due if not paid within 4 days after date of presentation.

Non-domestic Summary Bills may be considered past due if not paid within 7 days after presentation. Bills for accounts that serve state agencies will be considered past due as described in Rule 9.F.

B. Nonpayment of Bills or Summary Bills.

The following terms and conditions relating to disconnections for nonpayment will not apply until further notice to residential and Small Business Customers:

1. When a bill or Summary Bill for electric service has become past due and a 15-day

discontinuance of domestic service notice or a 5-day discontinuance of nondomestic service notice for nonpayment has been issued, service may be discontinued if the bill or Summary Bill is not paid within the time required by such notice. A customer's deposit to establish credit will not be used as payment to avoid discontinuance of service. When discontinuance of service for a Summary Bill occurs, that discontinuance may occur at any one or all service accounts related to the specified Summary Bill.

Any customer who has initiated a complaint or requested an investigation within 5 days of receiving a contested bill or Summary Bill shall not have domestic service to a residential dwelling discontinued for late payment or nonpayment during the pendency of an investigation by SCE of such customer dispute or complaint. Such domestic service shall not be discontinued for late payment nonpayment for any customer complying with an amortization agreement entered into with SCE, provided the customer also keeps current his account for electric service as charges accrue in each subsequent billing period. If a residential customer fails to comply with an amortization agreement, SCE shall not terminate service without giving notice to the customer, at least 48 hours prior to termination, of the conditions the customer is required to meet to avoid termination; but, such notice shall not entitle the customer to further investigation by SCE. If there is an imminent service disconnection, SCE may contact the customer by telephone (including calls or text messages to mobile phones) under the emergency purpose provision described in Rule 3.F., or by e-mail when appropriate.

2. Electric service to a domestic customer or to a domestic service account included in a Summary Bill will not be discontinued for late payment or nonpayment when the customer has established to the satisfaction of SCE that:

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(Continued) (To be inserted by utility) Issued by (To be inserted by Cal. PUC) Advice 4205-E Carla Peterman Date Submitted May 1, 2020 Decision Senior Vice President Effective Mar 4, 2020 1H9 Resolution M-4842

Cal. P.U.C. Sheet No.

TITLE PAGE ............................................................................................................................. 11431-E TABLE OF CONTENTS - RATE SCHEDULES .... 69065-68500-68396-68769-68770-68771-68771-E ........................................................................................................... 68773-68014-68774-E TABLE OF CONTENTS - LIST OF CONTRACTS AND DEVIATIONS ................................... 68779-E TABLE OF CONTENTS - RULES ................................................................................. 69066-64043-E TABLE OF CONTENTS-INDEX OF COMMUNITIES, MAPS, BOUNDARY DESCRIPTIONS 62213-E TABLE OF CONTENTS - SAMPLE FORMS.. .................. 62213-68473-61576-67878-67879-61631-E

........................................................................................................... 67880-67881-63296-E

PRELIMINARY STATEMENT:

A. Territory Served ......................................................................................................... 22909-E B. Description of Service ................................................................................................ 22909-E C. Procedure to Obtain Service ..................................................................................... 22909-E D. Establishment of Credit and Deposits ....................................................................... 22909-E E. General .......................................................................... 45178-45179-45180-53818-45182-E F. Symbols ..................................................................................................................... 45182-E G. Gross Revenue Sharing Mechanism ....... 26584-26585-26586-26587-27195-27196-54092-E

.................................................................................................. 51717-53819-27200-27201-E H. Baseline Service ........................................................... 52027-52028-52029-52030-52031-E I. Charge Ready Program Balancing Account ........................................ 68156-68157-68158-E J. Pole Loading and Deteriorated Pole Program Balancing Account ....... 68384-67495-68385-E ......................................................................................................................... 68386-67498-E K. Nuclear Decommissioning Adjustment Mechanism ........................................ 36582-57779-E L. Purchase Agreement Administrative Costs Balancing Account ........... 55207-51922-55208-E M. Income Tax Component of Contributions ....................................................... 58419-58420-E N. Memorandum Accounts .... 21344-67638-69058-58221-49492-61165-61166-61167-53821-E

........ 50418-42841-61168-64869-64870-44950-44951-44952-44953-42849-42850-42851-E ........ 65677-65678-55623-61171-42856-61172-61173-52033-50419-55048-61174-42863-E ........ 42864-67639-67640-51235-45920-51236-61175-50209-42872-42873-50421-46539-E ........ 42876-42877-42878-42879-42880-42881-42882-54534-53371-56253-44959-42887-E ........ 53321-53322-61176-52551-52552-49928-56235-56236-56237-55144-55145-44029-E

........ 53016-57156-57157-51163-51164-51165-51166-67414-51168-51169-51170-51171-E ........ 51244-55806-56393-56394-56395-56396-56397-56398-56399-58978-69059-69060-E

.................................................................................................................................... 69061-E O. California Alternate Rates for Energy (CARE) Adjustment Clause ................. 34705-41902-E .................................................................................................. 36472-38847-56788-68625-E P. Tree Mortality Non-Bypassable Charge Balancing Account………...65929-65930-65931-E

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(Continued)


RULESRule Cal. P.U.C. No. Title of Sheet Sheet No.

1 Definitions .......... 59339-58936-55551-60125-58779-66544-66545-55556-57629-55558-E ...................................................................................................................... 55559-55560-E

............................................................................................... 66546-66547-55563-55564-E 2 Description of Service ......................... 22926-22927-22928-25264-22930-22931-22932-E ............................ 22933-22934-67817-67818-47145-47146-47147-47148-47149-47150-E 3 Application for Service ................................................................................. 50441-22943-E 4 Contracts .......................................................................................... 55734-39859--55679E 5 Special Information Required on Forms ............................... 65949-27743-51306-31052-E 6 Establishment and Re-establishment of Credit ........................................... 55074-69062-E 7 Deposits ........................................................................................... 64425-55077-47771-E 8 Notices ......................................................................................................... 55078-27747-E 9 Rendering and Payment of Bills ................................ 56607-58024-69063-52504-52692-E 10 Disputed Bills ............................................................................................... 65951-55079-E 11 Discontinuance and Restoration of Service .............. 69064-64426-22966-22967-22968-E ......................................................................... 56590-64427-51311-65952-63533-68826-E 12 Rates and Optional Rates ................................................................ 64428-65953-51311-E 13 Temporary Service ................................................................................................. 51312-E 14 Shortage of Supply and Interruption of Delivery ......................................... 53899-26339-E 15 Distribution Line Extensions .... 24684-47151-47152-47153-47154-68371-47156-47157-E ................ 47158-67820-47160-47161-47162-47163-47164-67821-51853-47167-47168-E 16 Service Extensions ............................... 24700-49672-48155-24703-24704-47169-47170-E ..... 47171-47172-47173-47174-47175-47176-47177-47178-47179-47180-48156-48157-E 17 Adjustment of Bills and Meter Tests .......................... 19616-47773-47774-19619-19620-E 18 Supply to Separate Premises and Use by Others ............... 47472-45543-51854-45545-E 20 Replacement of Overhead With Underground Electric Facilities ...... 31867-23019-23020-E ........................................................................................................... 31868-26177-31869-E 21 Generating Facility Interconnections .... 58780-54719-54720-54721-54722-56118-56119-E ..... 56120-54726-64429-54728-56121-54730-54731-54732-54733-54734-64038-64039-E ..... 56122-58781-58782-54740-56125-56126-56127-54744-54745-54746-58783-65306-E ..... 57537-54750-58784-54752-54753-58785-58786-58787-54757-54758-54759-67970-E ..... 54761-54762-58789-54764-58790-58791-58792-54768-64430-58793-65954-54772-E ..... 54773-54774-54775-54776-54777-54778-54779-54780-54781-54782-54783-54784-E ..... 54785-54786-54787-54788-54789-54790-54791-54792-54793-54794-54795-54796-E ..... 54797-54798-54799-54800-54801-54802-54803-54804-54805-54806-54807-54808-E ..... 54809-54810-54811-54812-58796-54814-54815-54816-54817-54818-54819-54820-E ..... 54821-54822-54823-54824-54825-54826-54827-54828-54829-54830-54831-54832-E ..... 54833-56129-54835-54836-54837-54838-54839-54840-54841-54842-54843-54844-E ..... 56130-56131-56132-56133-56134-56135-56136-56137-56138-56139-56140-56141-E

. 56142-56143-56144-56145-56146-58797-58798-62070-56150-63988-63989-63990-E 64882-64883-68420-68421-63993-68422-68423-64884-62082-62083-62084-62085-E 62086-62087-62088-62089-62090-62091-62092-62093-62094-62095-62096-62097-E 62098-62099-62100-62101-62102-62103-62104-62105-62106-62107-62108-62109-E 62110-62111-62112-62113-64040-62115-62116-62117-62118-62119-E

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Attachment B

COMMUNICATION PLAN

OBJECTIVE

The objective of the customer communication plan is to raise awareness and inform customers about the existence of the consumer protections available during and post the COVID-19 pandemic.

STRATEGY

SCE’s strategy will include a combination of tactics designed to reach all customers and raise awareness about the consumer protections. Tactics will include but may not be limited to on-bill messaging, direct mail when appropriate, email, CBO engagement, targeted social media and web pages across SCE’s website.

SCE’s awareness campaign will reach customers across SCE’s territory during and following the pandemic.

IMPLEMENTATION

Community Outreach

SCE will take all available steps to raise awareness and engage affected customers on the consumer protections that are available and crucial. To accomplish this, SCE will use various forums, tactics and channels to reach customers to inform them about these necessary protections, which may include, but are not limited to, those outlined below.

1. Webpages

SCE has added and will continue to add information on consumer protections on SCE.com webpages including COVID-19 response, bill assistance, and disaster support at the following addresses: SCE.com/Safety/Coronavirus, SCE.com/BilHelp, and SCE.com/DisasterSupport.

SCE will engage its agency partners to develop copy for the content updates. The cost for similar COVID-19 related copywriting done in March 2020 was $4,977.

2. Outbound Emails

SCE will review all active (i.e., “in-market”) and planned (i.e., “not-yet-launched”) email campaigns to determine potential for consumer protections message integration. For customers who have opted in to receive promotional marketing communications electronically, SCE will engage its agency partners to also provide estimated cost for including dynamic message on any emails designated for deployment to those opted-in customers.

SCE may also elect to send a transactional email which does not require opt-in. SCE will utilize in-house resources to deploy the transactional email.

3. Digital & Radio Ads

SCE will produce advertisements such as radio spots, digital video, banner, and social media ads directing customers to visit SCE.com for information on consumer protections. The advertisements will be produced by, and media will be purchased by SCE agency partners. SCE recently deployed a comparable, three-month campaign to inform customers about changes to essential outages due to COVID-19 at a cost of $2,157,477.1

4. Bill Onsert

Space permitting, SCE has included and will continue to include COVID-19 consumer protections messaging and the link to the SCE.com/Safety/Coronavirus webpage on all residential customer bills using “on-bill” (onsert) messaging. SCE anticipates this proactive, pre-disaster awareness messaging will be implemented on a monthly basis, consistent with SCE’s current communication cadence for bill onsert messaging.

SCE will utilize internal marketing resources to develop high-level messaging that could be utilized for the bill onsert regardless of the type of disaster declared. As such, no incremental costs are anticipated to be incurred for bill onsert messaging.

5. Direct Mail

Similar to the outbound emails, SCE will review all active (i.e., “in-market”) and planned (i.e., not-yet-launched”) direct-to-customer campaigns to determine the extent to which supporting marketing communications can be augmented to include messaging that directs

1 Estimate based on IW Group Invoice #029920 for SCE COVID-19 Essential Outage Communications

customers to SCE.com to receive information about the consumer protections afforded to them.

Message augmentation may potentially include creation of a free-standing insert that would accompany a marketing campaign’s pre-printed customer letter or materials.

The estimated cost per mail piece is $0.67.2 Actual cost will vary based on the final quantity of inserts printed.

Alternatively, if print production has not yet occurred for a campaign’s customer letter or other materials, SCE can also ask its agency partners to evaluate the feasibility of and incremental cost for including messaging on those letters or materials.

The cost to implement messaging cannot be projected at this time in absence of obtaining an actual quote from the marketing agency that considers among other things scope, lead time for programming the message, ease of implementation, and the quantity and format of the communications that will display the message.

SCE will ensure that any free-standing inserts created, or dynamic messaging implemented in support notifying customers about consumer protections are provided in the same languages as the primary direct mail or email communications they should accompany.

6. Community Based Organization (CBO) Engagement

SCE has established relationships with nearly 1,600 non-profit community and faith-based organization across its vast service territory to help increase awareness and educate customers on rates and other income assistance programs like, CARE/FERA and Medical Baseline. SCE is working and will continue to work with organizations to disseminate information on consumer protections to customers.

Multi-Language Support

SCE will provide the consumer protections information in accordance with the language requirements outlined in D.20-03-004: English, Spanish, Chinese (including Cantonese, Mandarin, and other Chinese languages), Tagalog, Vietnamese and Korean, as well as languages “prevalent” within SCE’s service territory including languages spoken by indigenous communities that occupy significant roles in California’s agricultural economy regardless of prevalence.

SCE will maintain current production workflows for six core languages (English, Spanish, Chinese, Tagalog, Vietnamese and Korean) which are effective in reaching approximately 95% of SCE

2 Estimate aligns with 2021 GRC cost assumption

customer base. The approach and cost for additional prevalent languages will be defined in SCE’s Wildfire Mitigation Plan workplan and budget, set to be filed on May 15, 2020.

SCE is exploring the use of the Google Display Network Responsive Delivery3 to build and deliver display advertisements in the additional languages identified to be prevalent in SCE service territory.

3 https://support.google.com/google-ads/answer/6363750

advice letter al 233-g/4205-e and · schedules for fixed usage and unmetered service (schedules...

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