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An EDISON INTERNATIONAL® Company

(U 338-E)

2015 General Rate Case APPLICATION

Workpapers

GenerationSPVP, Fuel Cell, Catalina SCE-02 Volume 10

N ovem ber 2013

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Workpaper - Southern California Edison / 2015 GRC - APPLICATION1

I.

SOLAR PHOTOV OLTAIC PROGRAM

A. SCE’s Solar Photovoltaic Program Forecast

1. Introduction and Overview of the Solar Photovoltaic Program (SPVP)

SCE’s Solar Photovoltaic Program (SPVP) is a Commission-approved initiative to install

solar photovoltaic panels in SCE’s service territory, primarily on commercial rooftop space.1- This

program will be in effect through 2015 and, as per the original application, involved the installation of

up to 250 MW of solar generating facilities by SCE. The program was modified in Decision D.12-02-

035, reducing the program installation to 125 MW, with no less than 115 MW of solar generation

facilities absent additional authorization.2 This decision also increased the allowable ground mount

installations from 10 percent of total capacity to 20 percent. The program was further reduced to no less

than 91 MW DC (68 MW AC) in D.13-05-033, which will be accomplished in 2013 with the installation

of the final solar rooftop project.

Solar photovoltaic panels convert sunlight directly into electricity using a semiconductor

material. They use no water to generate electricity and have no moving parts. Photovoltaic (PV) panels

generate direct current (DC) electricity, and electrical devices called inverters convert the output to

alternating current (AC) electricity for export to SCE’s electrical distribution system. Each 1.35 MW of

DC yields approximately 1 MW of AC. The Commission found that this easily deployable technology

“can help advance California’s broad goal of developing renewable energy and specifically help make

progress toward the state’s emphasis on developing distributed rooftop solar PV projects.”3

The SPVP projects range primarily in size from 1 to 2 MW each and are installed on

commercial and industrial rooftop space in SCE’s service territory.4 These projects fill an existing gap

in the solar industry market for solar installations of this size and will encourage the development of

more distributed generation projects within this range.5 As originally envisioned, SCE developed these

4 SCE’s Application in A.08-03-015 states that “SCE envisions the individual Solar PV Program installations to be in the 1 to 2 MW range. As the program proceeds, however, some installations may be larger or smaller than this range due to

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Exhibit No. SCE-02 / Generation / Vol. 10Witnesses: R. Perez, J. Rumble and A. Edeson

2Workpaper - Southern California Edison / 2015 GRC - APPLICATION

1 facilities over the five-year construction program life, initially targeting approximately 50 MW annually,

2 and with no more than ten percent of the program consisting of ground-mounted solar PV. This build

3 out plan was modified to 25 MW per year and the ground-mount limit increased to twenty percent with

4 the adoption of D.12-02-035.6

5 During 2008-2012, SCE constructed a total of 24 sites, all of which were delivering

6 energy to the grid by December 31, 2012. In 2013, SCE has one additional site under construction

7 which is expected to be completed by the third quarter of 2013. A summary of all the sites is included in

8 Table I-1 below.

6 D.12-02-035, Attachment 1, p.2See workpapers p. 114

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Table I-1 SPVP Sites 2008-2013

SPVP Site OnlineDate

CAISOCOD

MW AC MW DC [3 ] Inverters

SPVP001 - Fontana[4] 8/7/2008 11/26/2008 2.00 2.44 4SPVP002 - Chino 9/24/2009 12/10/2009 1.00 1.22 2SPVP003 - Rialto 7/19/2010 3/1/2011 1.00 1.22 2SPVP005 - Redlands 12/27/2010 11/24/2012 2.50 3.40 5SPVP006 - Ontario 1/10/2011 8/25/2011 2.00 2.55 4SPVP007 - Redlands 12/29/2010 11/24/2012 2.50 3.20 5SPVP008 - Ontario 12/30/2010 8/25/2011 2.00 2.85 4SPVP009 - Ontario 1/10/2011 8/25/2011 1.00 1.41 2SPVP010 - Fontana 5/18/2011 1/8/2013 1.50 2.25 3SPVP011 - Redlands 11/10/2011 Pending[2] 3.50 5.02 7SPVP012 - Ontario 12/29/2010 8/25/2011 0.50 0.77 1SPVP013 - Redlands 9/15/2011 Pending[2] 3.50 4.93 7SPVP015 - Fontana 12/19/2011 1/15/2013 3.50 4.69 7SPVP016 - Redlands 5/18/2011 Pending[2] 1.50 1.75 3SPVP017 - Fontana 12/14/2011 Pending[2] 3.50 4.50 7SPVP018 - Fontana 5/23/2011 11/24/2012 1.50 1.94 3SPVP022 - Redlands 11/15/2010 8/25/2011 2.00 3.09 4SPVP023 - Fontana 5/12/2011 1/16/2013 2.50 3.86 5SPVP026 - Rialto 8/26/2011 Pending[2] 6.00 8.60 12SPVP027 - Rialto 11/27/2012 Pending[2] 2.00 2.62 4SPVP028 - San Bernardino

12/20/2011 Pending[2] 3.50 4.86 7

SPVP032 - Ontario 12/22/2011 Pending[2] 1.50 1.74 3SPVP033 - Ontario 12/12/2011 Pending[2] 1.00 1.27 2SPVP042 - Porterville 12/28/2010 11/24/2012 5.00 6.77 10SPVP044 - Perris 9/14/2012 Pending[2] 8.00 10.15 16SPVP048 - Redlands Pending[1] Pending 5.00 6.77 10

25 SPVP Sites 67.50 91.42

[1] SPVP 048 is currently under construction

[2] Projects are complete and online, but are pending CAISO review of SCE’s application for COD status

[3] Unless otherwise specified, the energy output in this filing follows the common convention within the PV industry, which is to refer to output as PV panel DC output.

[4] Located on the same rooftop as SPVP015, the sites share a CAISO meter. In the list above, we count these two projects as one site.

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Workpaper - Southern California Edison / 2015 GRC - APPLICATION

We forecast the Test Year 2015 Operation and Maintenance (O&M) expenses to be

$4.298 million ($2012) and the Capital Expenditures for 2013-2017 to be $38.909 million (nominal

dollars). These expenditures are necessary to continue providing reliable service at low cost, while

complying with applicable laws and regulations, and maintaining safe operations for employees and the

public. This testimony supports the reasonableness of SCE’s forecasts.

2. Regulatory History

a) Decision Establishing SPVP

On June 18, 2009, the Commission issued D.09-06-049 authorizing SCE to

install, operate, and maintain up to 250 MW of utility-owned solar photovoltaic (PV) generating

facilities. D.09-06-049 also doubled the size of the program by adding an additional 250 MW

Independent Power Producer (IPP) component, whereby SCE must hold solicitations to procure up to

250 MW of distributed generation bids from IPPs under power purchase agreements.7

SCE proposed in Application (A.) 08-03-015 to install the utility-owned portion

of the program, at a base cost of $875 million (2008 dollars) in direct capital expenditures, or $3.50/W

with a 10 percent contingency. In D.09-06-049, the Commission found reasonable SCE’s direct capital

expenditures forecast of $875 million, plus the 10 percent contingency, for a total reasonableness cap of

$962.5 million.8 See workpapers pp. 106a-cb) Decision Modifying SPVP

On February 11, 2011, SCE filed a Petition for Modification requesting the

program be reduced to no more than 125 MW.9 SCE stated program objectives had been achieved (e.g.,

bolster the 1-2 MW solar PV market) and program goals can continue to be realized in the reduced

program at better cost savings to SCE customers. The Commission agreed that a program reduction

would preserve the intent of the solar program while also reducing costs for customers, thus partially

granting SCE’s Petition for Modification through D.12-02-035.10 As a result, SCE’s solar program was

modified to 125 MW (with no less than 115 MW absent additional authorization), and increasing

D.09-06-045, Ordering Paragraph 2

D.09-06-049, (mimeo), pp. 44-45.

A.08-03-015.

—| See workpapers pp. 104-105

See workpapers pp. 97-989

10See workpapers pp. 106d-f

D.12-02-035, Findings of Fact, pp. 29-30. D.12-02-035 denies SCE’s request to allocate the 250 MW removed from the UOG and IPP portions of the program to a new solicitati on called “IPP Revised,” which aimed for procurement of lower cost solar facilities.


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See workpapers pp. 106g-i

ground-mount installations to twenty percent (equivalent to 25 MW) to accommodate for SCE’s existing

obligations.

In D.12-02-035, the Commission reduced not only the program size, but

proportionately reduced the cost caps previously found reasonable in D.09-06-049. The O&M expense

cap was reduced to approximately $20.655 million (2008 dollars), and the direct capital expenditures

cap reduced to $481.25 million (2008 dollars, with $437.5 million in direct capital plus a 10 percent

contingency). The total costs continue to be based on $3.50/W ($3.85/W including the 10 percent

contingency), with costs in excess of $3.85/W subj ect to a reasonableness review.11

On July 27, 2012, SCE filed a second Petition for Modification, requesting the

program be reduced to 91 MW. SCE stated additional changes that took place in the market justified a

further reduction in the utility owned generation portion of the program. SCE stated that program goals

had been successfully achieved and that customers would realize a greater cost savings with the program

reduction.12 In D.13-05-033, the Commission agreed with SCE’s assessment that market changes

between the first and second Petition for Modification filings warranted a further reduction in the utility-

owned portion of the SPVP program, and thus established that the utility-owned portion of the SPVP

program be capped at 91 MW.13 As well, the Commission made conforming changes to the O&M and

capital estimates to reflect the program reduction. The reasonable cost estimates over the program

period was reduced to approximately $15.037 million (2008 dollars) in O&M expenses, and $350.35

million (2008 dollars) in direct capital expenditures ($318.5 million direct capital plus a 10 percent

contingency). These total costs continue to be based on $3.50/W ($3.85/W including contingency), with

costs in excess of $3.85/W subject to a reasonableness review.14

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II.

SPVP CAPITAL FORECAST

A. Capital Forecast

SCE is not requesting additional capital for construction of any solar PV sites (expected to

conclude in 2013) beyond the amounts authorized in D.09-06-049, and as modified by D.12-02-035 and

D.13-05-033. Table II-2 below shows the summary capital expenditures for 2013 - 2017.

See workpapers p. 88Table II-2

Capital Expenditure Forecast 2013 - 2017(Nominal $Millions)

Year 2013 2014 2015 2016 2017 TotalForecast Capital

Expenditures $31.50 $0.425 $1.035 $0.269 $5.68 $38.909

For 2013, the capital forecast includes finishing the construction of the final utility-

owned SPVP site (SPVP 048), the installations of the Electrical Fault Protection System and the

Emerson Monitoring and Control system on the entire utility-owned SPVP fleet, as well as retrofitting

the sites for personnel safety mitigation. The SPVP 048 is a 6.77 MW DC plant located in Redlands,

CA, and is expected to be completed in the third quarter of 2013. The Electrical Fault Protection System

is an automated protection system that shuts down an inverter if adverse power flows are detected in

order to prevent fires and other failures that would damage the buildings or cause harm to the people

who occupy them. The Emerson Monitoring and Control system is an upgrade to the current system that

will add monitoring and reporting functions to all the sites. SCE will use the Emerson system to

monitor, control, and maintain the SPVP sites. Personnel safety mitigation activities include

identification and marking pathways of travel, identification and marking the parameter boundaries, sky

light protection, ladder access railing, and bridges and platform to cover cable trays.

The capital forecast for years 2014-2016 is significantly lower than previous years with

the conclusion of the construction program and installation of the aforementioned systems. The capital

forecast for these years reflects equipment such as inverters, transformers, and other capital designated

replacement components. There is a substantial increase in forecast capital spending in 2017 because

SCE anticipates a significant number of inverters to be replaced in that year. Inverter manufacturers

state that an inverter lifespan is between 7-10 years. Given SCE’s experience with SPVP 001 and 002,

the lifespan is expected to be on the shorter end of the range, at seven years. Since the majority of

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SCE’s utility-owned sites were built in 2010, the additional capital in 2017 is planned for the expected

influx of inverter replacements.

B. 2008-2012 Recorded and Authorized Capital and Forecast Expenditures

In compliance with Ordering Paragraph 7 of D.12-11-051 (SCE’s 2012 GRC decision), SCE is

submitting the following Figure II-1 below, which summarizes SPVP recorded capital expenditures

during 2008 through 2012. This figure also shows forecast expenditures for 2013 through 2017, and the

2012 forecast authorized by the Commission in the 2012 GRC.

See workpapers p. 89Figure II-1

Solar Recorded And Authorized Capital And Forecast Expenditures($000 Nominal)

As shown above in Figure II-1, SCE’s forecast for 2014-2017 is substantially less than recorded

expenditures during 2008-2012. This is primarily due to the expected conclusion of SPVP construction

at the end of 2013. As mentioned above, the 2014-2017 forecasts consist primarily of capital

replacements parts necessary to maintain the solar facilities. The 2013 forecast includes capital budgets

approved in D.09-06-049 and as modified through D.12-02-035 and D.13-05-033 to complete

construction of the final solar site, installation of the Electrical Fault Protection and Emerson systems on

the entire solar fleet, as well as fitting applicable sites for personnel safety mitigation.

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SCE’s recorded 2012 expenditures are lower than the amount authorized in the 2012 GRC,

primarily due to the cancellation of two SPVP proj ects, College of the Desert and Delano. Due to

significant interconnection upgrade costs, SCE decided that building at those sites was not in the best

interest of SCE ratepayers and subsequently cancelled the projects. SCE’s 2012 capital expenditures

were lower also due to SCE’s filing of a second Petition for Modification with the Commission on July

27, 2012, requesting that the utility-owned portion of the program be reduced to 91 MW.15 After filing

its petition, SCE was less aggressive in searching for new sites that would fill the gap created by the

College of the Desert and Delano cancellations, however SCE continued to search for potential

replacement projects should the second Petition for Modification be denied. On May 23, 2013, the

second Petition for Modification was approved by the Commission, and the utility-owned portion of the

SPVP program concluded at 91 MW.

15 Southern California Edison Company’s (U 338-E) Petition for Modification of Decision No. 12-02-035.

See workpapers p. 106g-i

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III.

SPVP O&M FORECAST

A. O&M 2015 Test Year Forecast

Since construction of new facilities concludes in 2013, SCE’s Test Year 2015 forecast consists

o f the ongoing operations and maintenance of the utility-owned solar fleet. SCE will operate and

maintain 25 solar project sites at the completion of the construction phase of the program for a total of

91 MW. Each site will be unique and have differing types and quantities of solar power plant equipment

based on the size of each site and the manufacturer of the equipment.

Test Year 2015 O&M estimates are based on previously established cost per MW for the SPVP

sites for all operations and maintenance activities and include labor and materials necessary for

maintaining the plant and lease expenses. Except for site leases, there is not sufficient O&M history on

the SPVP sites to utilize a forecasting method base d only on recorded data, therefore the O&M forecast

relies more on budgeted forecasts that are based on recorded history. Figure III-2 summarizes the SPVP

Labor and Non-Labor O&M recorded costs from 2008 through 2012, and the Test Year (TY) 2015

forecast of $4.298 million.

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<------------------- Forecast >

As shown above in Figure III-2, labor expenses have increased gradually from 2008

through 2012 reflecting the construction and maintenance efforts for the SPVP projects, and are

expected to further increase in 2013. The labor reduces in 2014 and 2015 to a level appropriate for the

ongoing maintenance of the completed SPVP sites. Non-labor expenses increased substantially in 2011

through 2012 reflecting the expense-related construction non-labor components as well as the

maintenance non-labor components including roof leases, and are expected to further increase in 2013.

The non-labor reduces in 2014 and 2015 to the level appropriate for ongoing maintenance and roof

leases for the 91 MW of SPVP capacity.

1. O&M Forecast Components

In preparation for this 2015 GRC, SCE reassessed O&M activities as identified in the

2012 GRC and, based on program experience, SCE defined a new set of activities that give a more

accurate portrayal of O&M activities going forward. These O&M activities can be broken down into

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three areas, (a) Inspections and Maintenance, (b) Miscellaneous Expenses, and (c) Site Leases.16 These

O&M categories more accurately capture O&M ac tivities for the SPVP plants given O&M experience

from 2010-2012 and correctly categorize how O&M budgets will be planned in future years.

a) Inspections and Maintenance

Project O&M includes the inspections and maintenance of components of the

SPVP facilities such as the Supervisory Control and Data Acquisition (SCADA) system, switchgears,

transformers, and so on. Embedded within the inspections and maintenance of different components of

an SPVP facility is the forecast expenditure for lab or, non-capitalized spare parts and miscellaneous

expenses. SCE’s forecast cost for the Inspection and Maintenance for items (1)-(5) below is $19,240 per

MW DC ($2012), and was calculated based on an itemized forecast of future expenditures.

Beginning in 2014, existing Power Production Department staff who operate and

maintain other SCE utility-owned facilities will perform the inspections and maintenance for the SPVP

facilities. These activities require approximately 5 .5 full time employees (FTE), including roles such as

project manager and supervisor, Instrument/Control and Electrical (ICE) technicians, operator, and

engineering support. The labor cost associated with these personnel is embedded within the project-

specific O&M forecast described below. Inspection and Maintenance expenses are recorded in FERC

Account 549. Descriptions for different types of inspection and maintenance activities are listed in

detail below.

(1) SCADA Inspection and Maintenance

The SCADA gathers, records and transmits data about the performance of

each SPVP site and presents the data to the operator in the form of a Human Machine Interface (HMI).

The SCADA presents the operator with valuable and necessary information to insure safe and reliable

operation of the plants. Since these systems are computer-based, they require routine maintenance

including troubleshooting, software upgrades, security enhancements, virus and malware prevention,

etc.

16 Of the items identified in SPVP’s original and updated testimony in A.08-03-015, Array Cleaning and Inspection now falls into item (e), “Other Equipment Inspection and Maintenance,” Inverter Misc. Maintenance is now defined as item (d), “Inverter Inspection and Maintenance,” DAS Monitoring has been expanded to item (a), “SCADA Inspection and Maintenance,” and Roof Leases remained as is and listed as item (f). Items (c) and (d) were newly defined so as to capture all major components of the SPVP sites.

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(2) Switchgear Inspection and Maintenance

The switchgear and main circuit breaker act as the point of “demarcation”

between the Solar Plant and the SCE electrical grid. The switchgear has meters (to measure the amount

of energy flowing into/out of the site), breakers (which control power flow and allow for isolation), and

replays (which provide circuit protection) of the plant equipment prior to it reaching the SCE

Distribution Grid. These systems require routine maintenance including inspection, cleaning, testing

and repair.

(3) Transformer Inspection and Maintenance

The transformer is used to change voltage levels. SCE’s electrical grid

has many voltages that are used depending on how far energy needs to be transmitted. Higher voltages

allow more energy to be sent on the same size wires with lower losses due to the natural resistances of

the wire. The inverters at the SCE sites produce 208 volts of AC power. Our typical transmission line

from the SPVP solar rooftop sites, to the customers, is 12,000 volts. The transformer steps up the

inverter output voltage from the 208 volts to 12,000 volts, so it can be sent to the customer.

(4) Inverter Inspection and Maintenance

The inverter is the primary energy conversion device on the site. This

device takes the Direct Current from the panels and converts it to Alternating Current for use by

customers.

(5) Rooftop Inspections and Maintenance

As needed, to investigate roof leaks, noises, disturbances with warehouse

occupants, SCE conducts rooftop inspections and maintenance. If the warehouse owner or occupant

discovers an abnormality with their rooftop, SCE is responsible to send a crew to survey the rooftop

where SPVP equipment is installed. SCE may also be responsible to remove portions of an SPVP

facility to appropriately survey the rooftop. If damages are discovered resulting from an SPVP facility,

then it is SCE’s responsibility to repair said damages.

b) Miscellaneous Expenses

The Miscellaneous expense category generally refers to preventative action,

facility maintenance (i.e., safety paint, vegetation management), and repairs for all manufactured

equipment. The sites have multiple pieces of equipment that require periodic attention in order to

maximize the usefulness of the assets. Examples of other expense include, but are not limited to, wire

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and cabling, racking, equipment rental and repairs, transportation, training, and facility maintenance

(i.e., paint, fencing, vegetation management).

Miscellaneous expenses also include array inspection and cleaning, as identified

in the SPVP program application A.08-03-015. After conducting the initial cleaning for SPVP 001, SCE

determined that at the time it was costly and not effective to justify continue array cleaning as originally

planned. There were three main reasons that led to this conclusion. One, array cleaning was more

costly than anticipated; local regulations required the use of deionized water and capture of used water.

Two, the amount of soiling is greater than expected and would require cleaning more frequently to

materially increase solar production. Three, array cleaning requires a site to be shut down, which means

SCE would lose production output during the time the site was shut down. Therefore, the benefit of

increased kWh resulting from the cleaner panels is diminished due to the loss of production due the

shutdown of sites during the cleaning. As a result, SCE concluded natural processes such as wind and

rainfall would do an adequate job of array cleaning. In the future, should it become advantageous and

cost effective to conduct array cleaning as outlined in A.08-03-015, SCE may elect to conduct regular

array cleanings.

SCE’s forecast cost for Miscellaneous Expenses for the activities described above

is $3,440 per MW DC ($2012), and was calculated based on an estimate of forecast expenditures. Also

included in Miscellaneous Expenses are Added Facility Charges, which are fixed payments that SPVP

pays to SCE T&D for interconnecting the SPVP sites to the grid. SCE’s Test Year 2015 forecast for

Added Facility Charges is $1,648 ($2012) per MW, and was calculated based on historical costs.

Miscellaneous Expenses and Added Facility Charges expense record in FERC Account 549.

c) Site Leases

Site leases on all rooftop sites and the single ground mount site (SPVP 042) are

fixed lease payments that escalate on their anniversary in conjunction with general Consumer Price

Index escalation rates. New site construction will conclude with the completion of SPVP 048 in the

third quarter of 2013. SCE’s forecast for Site Leases is $22,901 per MW ($2012), and was calculated

based on the scheduled lease payments for all the sites. Site Leases expense is recorded in FERC

Account 550.

B. Development of O&M Forecast by FERC Account

Historical O&M data from 2009-2012 includes expenses in excess of that required for the 2015

Test Years due to expenses that relate to new site construction through 2013. Beginning in 2014, during

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the Test Year 2015, and for the years going forward, utility-owned SPVP sites will be operated and

maintained like all other utility-owned generation facilities in the Power Production Department. As

such, O&M expenditures in Test Year 2015 are based on the previously approved cost per MW, which

encompasses the forecasted maintenance expenses. Table III-3 below shows the previously approved

cost per MW and the correlation to our 2015 GRC O&M forecast.

See workpapers pp. 18a-bTable III-3

SPVP O&M Cost per M W

2012 GRC $/MW Forecast (2009$)

2012 GRC$/MW

91 MW Cost (2012$M)

Revised Allocation $/MW 2015 GRC

91 MW Cost (2012$M)

ActivityArray Cleaning/Inspection 8,000 8,702 0.792Inverter Misc. Inspection 5,100 5,548 0.505DAS Monitoring 1,200 1,305 0.119Total Plant Maintenance 14,300 15,556 1.416 24,330 2.214Roof Lease Costs 30,000 32,442 2.952 22,901 2.084

In the 2012 GRC it was believed that roof lease costs would approach $30,000 per MW. The

costs at this time are approximately $23,000/MW, which would likely have been higher if SCE

continued the program past the current 91 MW. O&M expenses for maintenance were forecast at

approximately $16,000/MW in the 2012 GRC, but the experience to date indicates a higher expense of

about $24,300/MW. The total expense forecast for the 2012 GRC and the 2015 GRC per MW of

installed solar capacity remains essentially the same at approximately $47,200/MW. As noted above in

Section 1, the O&M activities have slightly changed from those envisioned when the program began.

However, the costs are in line with the original forecast as shown in Chapter IV SPVP Reasonableness

Review below.

1. FERC Account 549 - Miscellaneous and Other Power Generation Expenses

a) Description of Account

FERC Account 549 includes the cost of labor and expenses incurred in the

operation and maintenance of SPVP sites. The Test Year 2015 SPVP O&M expense forecast is $24,330

per MW DC ($2012). The Labor forecast for this account is $0.555 million and the Non-Labor forecast

is $1.659 million, providing a total TY forecast of $2.214 million. The 2008 through 2012 recorded

expense history and our forecasts for 2013 through 2015 for this account are summarized in Figure III-3

below.

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See workpapers pp. 1-18 and 18b

Figure III-3 SPVP FERC Account 549

Recorded 2008-2012/Forecast 2013-2015(2012 $000)

b) Development of Test Year Forecast

Upon Commission approval of the program in June 2009, SCE began ramping up

the staffing efforts to adequately support the project growth schedule for 2009 and future years. The

increased labor costs through 2012 are reflective of the increased number of personnel required to meet

the increased SPVP project installation schedule. Program staffing during the construction phase will

remain high until construction is completed at the end of 2013. Staffing will decline at the end of 2013

to that necessary for continued maintenance.

The increasing Non-labor costs for 2010 through 2012, and forecast for 2013

reflect the increased number of projects that were installed during those years, and the associated O&M

activities required for project maintenance. In 2013 the costs include installation of systems including

the Electrical Fault Protection System, and the Emerson Monitoring and Control system, required for

safe and reliable operation of SPVP facilities. O&M costs associated with site maintenance will reduce

to a maintenance required level, which is significantly lower than during the construction period.

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SCE developed its 2015 expense forecast primarily based on the previously

planned cost per MW for the SPVP development. As discussed above, the previously planned O&M

expense of approximately $16,000 requires revising up to $24,300/MW, but that is offset by the

reduction from the roof lease cost. In FERC 549 for both Labor and Non-Labor expense, the 2012

expense serves as an appropriate base estimate for our 2015 forecast, with a forecast reduction

adjustment for the 2015 TY. In D. 04-07-022 and D. 89-12-057, the CPUC stated that if costs have

shown a trend in a certain direction over three or more years, the last recorded year is an appropriate

base estimate. Labor expenses have been increasing for five years from 2008-2012, so we used 2012

recorded as the starting base estimate, but we adjusted the 2012 base downward to reflect our belief that

there will be reduced staff in 2015 given that construction of new facilities will conclude in 2013. Non

labor expenses fluctuated significantly from 2008-2012, but this was also due to the timing of the

construction of new facilities as well as the online dates for the various projects, as opposed to

unpredictable factors (such as weather) suggested by the CPUC in D. 04-07-022 and D. 89-12-057 that

would support the use of an average of recorded years as the test year methodology. Since all projects

except SPVP048 were online by the end of 2012, SCE used the 2012 non-labor recorded expense as its

starting base estimate but reduced the expense to the level necessary for the continued site maintenance

forecasted for 2015.

2. FERC Account 550 - Rents


This account includes all rents of property of others used, occupied, or operated in

connection with SPVP projects. The Test Year 2015 SPVP O&M expense forecast is $22,901 per MW

DC ($2012). This account does not contain Labor expense. The Non-Labor forecast for this account is

$2.084 million for the 2015 TY forecast. The 2008 through 2012 recorded expense history and our

forecasts for 2013 through 2015 for this account are summarized in Figure III-4 below.

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See workpapers pp. 19-36 and 36a

Figure III-4 SPVP FERC Account 550

Recorded 2008-2012/Forecast 2013-2015(2012 $000)

2.400 ------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------

. 11112008 2009 2010 2011 2012 2013 2014 2015

□ Labor (std escl) ■ N on-Labor (std escl) □ O ther (not escl)

Labor o o o o o o o o

Non-Labor 0 172 155 756 2.127 2,034 2,034 2,084

Other 0 0 0 0 0 0 0 0

Total 0 172 155 756 2,127 2,084 2,084 2,084

<-------------------------Forecast--------------------------->

b) Development of Test Year Forecast

SCE developed its 2015 exp ense forecast primarily based on the previously

planned cost per MW for the SPVP development. As discussed above, the previously planned Roof

Lease expense of approximately $30,000 requires revising down to $22,901 /MW. In FERC 550 for

Non-Labor expense we utilize a Last Recorded Year with a forecast decrease adjustment for the 2015

TY. In D. 04-07-022 and D. 89-12-057, the CPUC stated that if costs have shown a trend in a certain

direction over three or more years, the last recorded year is an appropriate base estimate. Lease Non

labor expenses have been increasing each year, which provides a base for estimating the test year 2015.

To this base we add an increase adjustment of six months lease for one site that reflected only six

months of 2012 recorded expense.

Costs in this account are expected to remain constant for 2013-2015 and for years

going forward, as these lease costs are fixed and only increase annually with escalation.

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IV.

SPVP REASONABLENESS REVIEW

A. Reasonableness Review Requirement

In D.09-06-049, the Commission found that the reasonableness review of SPVP’s capital

expenditures and O&M costs should be conducted in the GRC proceeding, and review of SCE’s

operation of the facilities should be conducted in the Energy Resource Recovery Account (ERRA)

proceeding. In D.09-06-049, the Commission found reasonable SCE’s cost estimates (in 2008 dollars)

of $41.31 million in O&M and $875.0 million in direct capital expenditures over the 2008 through 2014

program period, and authorized SCE to establish the Solar Photovoltaic Program Balancing Account

(SPVPBA) to record capital costs and O&M expense associated with the SPVP.17 As discussed by Mr.

Snow in Exhibit SCE-10, Volume 1, Part 2, SCE is proposing to eliminate the SPVPBA in this

proceeding and to recover the SPVP rate base and O&M costs in Test Year 2015 GRC base rates.

In accordance with D.09-06-049, this testimony presents for Commission review the capital

expenditures and O&M expenses associated with installation of the 24 completed SPVP sites

(84.65 MW DC).

1. Reasonableness Threshold

In A.08-03-015, SCE provided an estimate of megawatts installed and associated direct

capital expenditures that would be incurred during the five year SPVP. As indicated in SCE’s direct

testimony, Year 0 estimated a time frame from April 2008 to December 2008 for installation of the first

projects totaling 5 MW, and capital expenditures of $25 million.

Table IV-4 summarizes target capital cost of the SPVP and associated installation

schedule as provided in direct testimony to A.08-05-013.18

^ — See workpapers pp. 97-9817 D.06-09-049, (mimed), pp. 44, 45.

18 Please see SCE’s Rebuttal Testimony filed in A.08-03-0 15 on October 3, 2008, Confidential Attachment 1 for details on how target capital cost was developed.

^ — See Confidential workpapers pp. 1-23

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Table IV-4Summary o f Capital Costs o f Solar P V Program

(2008$)

Year Capital (Million$) MW Installed Estimated Time Frame

0 $25 5 April '08 to Dec '08

1 $174 50 2009

2 $174 50 2010

3 $174 50 2011

4 $174 50 2012

5 $154 45 2013

Total $875 250

The capital cost schedule in Table IV-4 assumed a Commission decision would be issued

on the SPVP in 2008; however D.09-06-049 did not approve the SPVP until June 18, 2009. The timing

of issuance of D.09-06-049 moved Year 0 of the SPVP installation to 2009. Given this delayed

installation schedule, the reasonableness review threshold as provided in SCE’s application testimony is

applied on a program year basis, rather than a calendar year basis.

Conclusion of Law in D.09-06-049 states that a “ [r]eview of all SPVP costs should be

conducted in SCE’s GRC proceeding.”19 SCE’s target cost for the Solar PV Program is $875.0 million,

or $3.50/W DC.20 The reasonableness threshold is $962.5 million ($ 2008), or $3.85/W DC ($2008),

which is the base case amount plus a reasonable 10 percent contingency.21 If SCE’s direct capital

expenditures are less, on a $/W basis than the reasonableness threshold, then those capital expenditures

will be deemed to be reasonable.

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The cap for direct capital expenditures has reduced to correspond to revised program

installed MW goals approved by the Commission. D.12-02-035 issued February 16, 2012, reduced the

SPVP program by half for the 2008-2012 program period, thus reducing the direct capital expenditures

to $481.25 million ($2008) ($427.5 million ($2008) plus a 10 percent contingency).22 D.13-05-033

issued May 23, 2012, further reduced the program cap to 91 MW, thus concurrently reducing the capital

expenditure cap to $350.35 million ($2008) ($318.5 million ($2008) plus a 10 percent contingency.23

In all three program build out structures, the direct capital expenditure limit remained

$3.85/W ($2008) ($3.50/W ($2008) plus a 10 percent contingency), with the requirement that the cost

cap be subject to a reasonableness review.24

The reasonableness threshold is based on installed watt of direct current (DC) electricity.

Solar photovoltaic panels generate DC electricity, and inverters convert the output to alternate current

(AC) electricity for export to SCE’s electrical distribution system. Each MW AC is equivalent to 1.35

MW DC.

Table IV-5 identifies Reasonableness Thresholds for Direct Solar PV Program Capital

Costs on an installed $/W basis.

See workpapers p. 11022 D. 12-02-035, Conclusion 4.4 (p.27).

23 D. 13-05-033, Conclusion 6.3 (p.16).

24 D.09-06-049, Conclusions of Law 10 (p.57); D.12-02-035, Conclusion 4.4 (p.27); D.13-05-033, Conclusion 6.3 (p.16).

See workpapers p. 118

See workpapers pp. 103, 110 and 118

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Table IV-5Reasonableness Review Threshold For Direct Solar P V Program Capital Costs25

(2008$)

Expenditures Incurred During

$/W

Year 0 5.50Year 1 3.83Year 2 3.83Year 3 3.83Year 4 3.83Year 5 3.76

Though the Solar PV Program estimates a base case total installed cost of $3.50 per watt,

the average cost of installation will vary from year to year. As indicated in SCE’s testimony in the

SPVP application, the capital costs would be higher in the early years but decrease as SCE’s experience

increases.26

In its SPVP application, SCE estimated the costs incurred during the start-up phase of the

program (listed as year “0”) to be $25 million ($ 2008) for up to 5 MW of installed PV generation,

which produces an average installed cost of $5.50/W ($ 2008) for that year. This estimate was based

upon discussions with solar industry experts, and vendor quotes, combined with a forecasted schedule

for installation of SPVP projects. Please refer to Rebuttal Testimony (A.08-03-015) Workpapers for

data on original capital cost estimate. See Confidential workpapers pp. 1-232. ^ SPVP Costs are below the Reasonableness Threshold

SCE’s actual capital expenditures for the start-up phase of SPVP, Year “0” were at the

reasonableness threshold of $5.50/W DC. SCE incurred $20.4 million in capital expenditures for the


25 These threshold amounts will be escalated to nominal year amounts for use in reasonableness review. Consistent with SCE’s testimony in A.08-03-015, because direct capital expenditures will be recorded in nominal dollars during each year of the project, the $/W values will be adjusted for general price inflation between 2008 and later years. SCE proposed to adjust the constant 2008 dollars to nominal dollars by multiplying the $/W costs in 2008 dollars by the ratio of the Gross Domestic Product Price Index for the calendar year being reviewed to the Gross Domestic Product Price Index for 2008.

26 SCE’s Application Testimony, p. 43.

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first 3.71 MW DC of SPVP installations, or $5.50/W DC installed. These expenditures are deemed

reasonable pursuant to D.09-06-049.

Year “ 1” SPVP construction began ramping up with the build of 27.04 MW DC. Capital

expenditures are higher than the reasonableness threshold of $3.83/W DC. SCE incurred $118.8 million

in capital expenditures for the additional MW, which translates to $4.39/W DC.

Year “2” SPVP construction increased significantly resulting in 41.19 MW DC of new

build. Capital expenditures are lower than the reasonableness threshold of $3.83/W DC. SCE incurred

$154.6 million in capital expenditures for the additional MW, which translates to $3.76/W.

Year “3” SPVP construction began to taper off with the construction of 12.77 MW.

Capital expenditures are lower than the reasonableness threshold of $3.83/W DC. SCE incurred $30.3

million in capital expenditures for the additional MW, which translates to $2.37/W.

Although Years 0 and 1 capital expenditures were at or higher than the established cost

cap for SPVP direct capital expenditures in those particular years, remaining years are considerably

lower. The cumulative total for the SPVP program in 2008 dollars shows that capital expenditures at

this point in the program are in fact lower than the program cost cap of $3.85/W ($2008). The

cumulative total of capital expenditures in for years 2008-2012 is $316.4 million ($2008), therefore SCE

is below the cost cap at $3.74/W ($2008).

3. Capital

Capital expenditures can be categorized into two expenditures types: (1) Hardware

Expenditures, and (2) Installation Labor. Descriptions of the categories are included below.

a) Hardware Expenditures

Hardware expenditures represent SCE’s costs to procure the solar panels and

other project-related equipment (such as racks to mount the panels, inverters, data acquisition

equipment, circuit breakers and fuse boxes, metering, and transformers to increase the panel output

voltage to levels utilized in the electrical distribution system).

(1) Solar Panel

SCE utilized solar panels from three manufacturers, First Solar, Sunpower,

and Trina. First Solar FS series two rigid thin film modules were utilized for SPVP 001, 002 and 003.

These panels convert sunlight directly into electricity utilizing layers of cadmium telluride (CDTE)

semiconductor materials. First Solar panels are rated at 72.5 watts DC under standard test conditions

and have a 25-year limited power output warranty. Sunpower and Trina panels were used for the

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remaining SPVP sites. Sunpower and Trina panels have a higher panel rating than First Solar, such that

sites with Sunpower and Trina panels produced more MW per panel.

Sunpower panels were used for ten SPVP sites.27 These panels convert

sunlight directly into electricity utilizing 96 monocrystalline modules per panel protected by tempered

glass. Sunpower panels are rated up to 305 watts DC under standard test conditions and have a 25-year

limited power output warranty. Trina panels were used for the remaining thirteen SPVP.28 These panels

convert sunlight directly into electricity utilizing 72 multicrystalline modules per panel protected by

tempered glass. Trina panels are available in various ratings ranging from 285 through 305 watts DC

under standard test conditions and have a 25-year limited power output warranty.

(2) Inverters and Balance of System

All solar PV modules, regardless of technology, generate direct-current

(DC) power. SCE must convert this DC power to alternating current (AC) power to use in its

distribution system. Inverters perform this conversion. SCE plans to utilize inverters by two different

manufacturers for future SPVP installations, Satcon Technologies and Xantrex.

Satcon PVS-500 Powergate inverters are sized to generate 500 kW AC,

and are designed to interconnect to the distribution grid. The inverters are supplied with an inter

connection voltage of three phases, 480 VAC nominal. As a result of the design for grid

interconnection, the inverters are outfitted with many system protections in place including: inverter

on/off switches, Inverter Over Current Fault protection, Line Frequency Controls, etc. If any of these

system protections detect a deviation from a safe range operation, safety controls will automatically

isolate the system, or parts of the system, from the grid.

The Xantrex GT500kW Grid-Tied Photovoltaic inverter is a three phase

power conversion system that is designed to generate 500kW AC.

Solar PV systems also include conduit, wire, and combiner boxes, called

Balance of System (BOS) components. In order to allow the solar array to achieve the proper operating

voltage of a nominal 600 volts DC, modules must be wired in series (imagine multiple batteries in a

flashlight) into strings. The strings are then terminated in parallel using specially designed

27 SPVP 005, 007, 011, 013, 015, 016, 017, 026, 028, and 044.

28 SPVP 006, 008, 009, 010, 012, 018, 022, 023, 027, 032, 033, 042, and 048.

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combiner/fuse boxes that provide over-current protection to the series strings, before sending the

combined DC power to the inverter.

(3) PV Module Mounting Systems

SPVP systems re quire racks on which to attach the panels. Racking

systems vary and can be scalable, ballast and non-ballast-railed, have penetrating and non-penetrating

designs, and different wind rated to capacities.

(4) SCADA System

The Supervisory Control & Data Acquisition System (SCADA) gathers,

records and transmits data about the performance of each SPVP site and presents the data to the operator

in the form of a Human Machine Interface (HI). The SCADA System presents the operator with

valuable and necessary information to insure safe and reliable operation of the plants. The SCADA

System includes weather sensory equipment that will enable SCE to evaluate impact of weather

conditions experienced on the quantity of power output. Additionally, the Data Processing Gateway

(DPG) receives data from the SCADA System which is transmitted to the CAISO and SCE Generation

Control Center. Data provided to these entities inc lude operational data on a real time basis. The

SCADA System also archives historical data related to the operation of the SPVP sites in databases

which allow for trend analysis as well as alarm and event historical analysis.

(5) Interconnection Equipment

Interconnection Equipment includes equipment necessary for

interconnecting the SPVP projects to the SCE distribution grid. SPVP projects will connect at low

voltages (less than 4 kV) and medium voltages (greater than 4 kV). Standard equipment used for

interconnection includes: transformers; switchgear; meters; fuses; breakers; pad mounted switches; and

standard switchgear protective relays. The interconnection equipment required for each voltage level is

determined on a project specific basis.

b) Installation Expenditures

(1) Scope

Installation consists of SCE’s expenditures to install the Generating

Facility Equipment on the project site including: Site Selection, Engineering, Permitting, Installation

and Commissioning, Project Management and Oversight.

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(2) Description of Installation Activities

(a) Site Selection

The site selection process includes performing initial analysis of a

building’s potential to qualify for inclusion in the SPVP, including rooftop surveys and site walks with

building owners. Some preliminary engineering activities may occur during the site selection process to

determine if a potential roof is compatible with the requirements of a solar energy project.

(b) Engineering

Once a suitable site has been selected, engineering activities begin.

Engineering activities include: reviewing the buildings structural drawings, marking the site to identify

array layout, and creating drawings that clearly define requirements for installation of the solar projects.

(c) Installation and Commissioning

Installation activities include the actual act of placing the racks on

the rooftops, mounting the panels to the racks, and installing all of the Balance of System components.

Once all Installation activities have been completed, Commissioning begins. Commissioning is the

process of turning on the system, testing and notation taking, and troubleshooting any problems.

(d) Project Management and Oversight

Project Mana gement and Oversight activities include overview of

all activities from Engineering to Commissioning projects in accordance with all applicable laws and

regulations, in accordance with SCE’s internal policies, and meet deadlines and budget requirements.

4. Operation & Maintenance Expenses

As previously discussed, SPVP incurs expenses related to Operations and Maintenance

on a project and program specific basis. Project O&M expenses include the activities necessary for

maintaining plant equipment and lease expenses for each project site. SCE contracted with US-Most to

monitor, operate, and maintain SPVP sites. US-Most is an engineering, technology, consulting, and

construction company that focus on renewable energy for Utility and Federal markets. The US-Most

team has extensive operations and maintenance experience in the solar industry, as well as other

renewable energy technologies including wind and geothermal. US-Most monitored, operated, and

maintained the sites beginning in 2009 and continued in 2012. Going forward, SCE plans to conduct

such activities in-house as construction ends. A detailed description of the activities that make up

Project and Program O&M is discussed in the Proj ect O&M Forecast Costs portion of the SPVP

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Forecast Testimony. Please refer to that portion of testimony for a detailed description of each activity

associated with Project O&M.

a) Recorded Program and Project Operations and Maintenance Expenses

Expenses for Project and Program O&M recorded in the SPVPBA from 2008 -

2012 totaled $ 22.8 million. These costs are lower than the projected amount identified in D.13-05-033

for a 91 MW DC program.

b) Recorded Roof Lease Costs

Roof lease expenses recorded in the SPVPBA from 2008 - 2012 totaled $2.8

million. These costs are for commercial roof leases that SCE entered into with building owners to

locate, construct, and operate SPVP projects.

Recorded roof lease costs are higher than expected for the SPVP program for a

variety of reasons. When SCE started the SPVP program, the idea of leasing roof space for PV panel

installations was a novel concept. There was no re al market reference pricing in existence because the

SPVP differed from most large-scale rooftop PV deployments in that it was for large roof building that

would not otherwise qualify for net energy metering. Roof space owners then had the opportunity to set

the market price for lease payments. Additionally, the Independent Power Producer (IPP) component of

the SPVP instilled a new competition for roof space in high solar-potential areas, inflating leasing costs.


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See workpapers pp. 150a-b

V.

SCE'S FUEL CELL PROJECT

A. Introduction and Overview of the Fuel Cell Project

As discussed in the testimony in Exhibit SCE-10, Volume 1, SCE requests that the Commission

terminate the current memorandum account treatment of the Fuel Cell Program and transfer recovery of

these costs to base rates. Therefore, in this testimony, SCE presents a background of SCE’s Fuel Cell

Program, which was approved by the Commission in D.10-04-028, and SCE requests that the

Commission approve SCE’s 2015 O&M test year forecast of $0.669 million for two fuel cell sites.

A fuel cell converts a source fuel, such as natural gas, into electrical current through an

electrochemical reaction. Fuel cell technology generates electricity more efficiently than other

similarly-sized combustion technologies, resulting in lower emissions of greenhouse gases, and because

fuel cells do not burn natural gas, minimal emissions of nitrogen oxide, sulfur dioxide, and particulate

matter. Fuel cells have been designated as “Ultra-Clean” by the California Air Resources Board

(CARB) and exceed all 2007 CARB standards.

SCE’s fuel cell project at University of California Santa Barbara (UCSB) was completed in 2012

and utilizes an electric-only fuel cell technology. The project at California State University San

Bernardino (CSUSB) is expected to be completed in before the end of 2013 and utilizes a combined heat

and power fuel cell technology. The fuel cell system at CSUSB is designed to operate at close to 70

percent total system efficiency by utilizing the fuel cell’s exhaust heat to supplement CSUSB’s hot

water heating system. A description of the selection of the fuel cell sites can be found in SCE’s Fuel

Cell Program direct testimony in A.09-04-018.29

1. Regulatory History

install, operate, and maintain three utility-owned fuel cells (UCSB, CSUSB, and California State

University Long Beach (CSULB)). Decision No. 10-04-028 authorized SCE recovery of $19.1 million

a) Decision Establishing the Fuel Cell Program

On April 14, 2010, the Commission issued D.10-04-028 authorizing SCE to

in capital and $8.9 million in O&M, exclusive of fuel.

See workpapers pp. 151-16029 See A.09-04-018, Exhibit SCE-01, p. 9-15.

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See workpapers p. 150d

Subsequently, SCE concluded that it should not go forward with the third

installation at CSULB and provided testimony supporting its decision in the 2012 GRC.30 Fuel Cell

Energy (FCE) petitioned to modify D.10-04-028 to clarify that SCE should seek an alternate host site for

the third^nstallation. Although SCE and DRA opposed FCE’s petition, the CPUC determined in D.12-

04-011 that SCE attempt to identify an alternate site within one year. The CPUC further authorized SCE

to develop and complete a third fuel cell installation at an alternate site, should the project be able to be

completed within the budget limits and conditions established in D.10-04-028. Following detailed

feasibility studies at two sites previously identified in the initial development activities for the fuel cell

program, SCE has determined that a third fuel cell installation cannot be completed33 within the

parameters of D.10-04-028, and consequently will not pursue a third fuel cell installation.

b) Creation of the Fuel Cell Program Memorandum Account

Decision No.10-04-028, Ordering Paragraph No. 4.b states that SCE shall record

actual capital and O&M costs in a Fuel Cell Program Memorandum Account (FCPMA). The balance

shall be transferred monthly to the generation sub-account of Base Revenue Requirement Balancing

Account (BRRBA), as long as the amounts are no higher than the estimates approved in the decision.

Actual capital expenditures less than or equal to $19.1 million are deemed reasonable. Actual O&M

expenses less than or equal to $8.9 million over the ten year life of the program are also deemed

reasonable. The CPUC currently reviews SCE’s FCPMA expenses annually in SCE’s Energy Resource

Recovery Account (ERRA) Review of Operations proceedings.

2. Request to Eliminate the FCPMA

In Exhibit SCE-10, Volume 1, SCE requests that the Commission terminate the current

memorandum account treatment of the Fuel Cell Program and transfer recovery of these costs to base

rates.32 By doing so, the Commission will be able to review 2015 and future Fuel Cell Program costs in

the GRC proceedings and not in the ERRA. The CPUC denied SCE’s similar request in SCE’s 2012

GRC decision33 due to delays and modifications in the program, as well as the relatively short amount of

time since the memorandum account had been established. SCE has more experience with the program

See workpapers pp. 161-16430 Exhibit SCE-84, Update Testimony (October 24, 2011).

31 See Workpapers titled “Report of Southern California Edison Company Regarding Efforts to Identify an Alternative Fuel Cell Site Pursuant to Decision 12-04-011,” dated May 30, 2013.

32 See testimony of Mr. Snow in Exhibit SCE-10, Volume 1. See W O fkpapefS p p . 165-170

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now, having completed one fuel cell project, nearing completion of the second, and has entered into

long-term service agreements for maintenance. Thus, SCE believes it can forecast with relative

certainty test year O&M expenses.

Because SCE’s request in this application relates to approval of 2015 test year costs, the

reasonableness of 2012-2014 O&M and capital costs recorded in the FCPMA will continue to be

reviewed in SCE’s ERRA proceeding.

3. Capital Expenditures Forecast

Figure V-5 is shown below, in compliance with D.12-11-051 Ordering Paragraph 7.


9

10

Figure V-5 Fuel Cell Program

Recorded, Authorized and Forecast Capital Expenditures

The fuel cell project at UCSB was completed in 2012 and the fuel cell project at CSUSB

will be online in 2013. SCE’s forecast of 2013 capital expenditures for the CSUSB fuel cell project is

Continued from the previous page33 D.12-11-051, p. 592.

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less than $1 million with no additional capital expenditures forecast beyond 201334. Per D.12-11-051

Conclusions of Law 60, the reasonableness of the capital expenditures recorded in the FCPMA will be

addressed in SCE’s 2014 ERRA review proceeding.

4. Operation & Maintenance (O&M) Forecast

ee workpapers pp. 129-146"I Figure V-6 Fuel Cell Program

Recorded and Adjusted 2008-2012/Forecasted 2013-2015 FERC Account 549

(Constant 2012$)


SCE records Fuel Cell Program O&M expenses in FERC Account 549. FERC

Account 549 includes the O&M cost of labor, material used, and expenses incurred in the operation of

the Fuel Cell Program.

b) Recorded and Forecast Costs

The itemized forecast for FERC Account 549, as shown in Figure V-6 consists of

labor and non-labor. The labor portion of the forecast is the market reference point for a Manager -

34 WBS Element CG0-00-GP-PS-000070.

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Program Contract 3. This Full Time Equivalent (FTE) will provide project management and program

contract oversight necessary to support the ongoing safe, compliant, and reliable operation of the fuel

cells. The FTE will interface with the host univers ities, including outage scheduling, and will oversee

numerous vendor service agreements.

The non-labor portion of the forecasts includes ten year Long Term Service

Agreements (LTSA) with the manufacturers of each fuel cell for ongoing maintenance of each unit.

Also included in the non-labor forecast are telecommunications and data services, interconnection

facilities charges, water treatment system service a greement, site maintenance service agreements, and

air quality permit certification and renewal.

c) Development of Test Year Estimate for Account 549

SCE’s Fuel Cell Program has no recorded O&M expenses until 2012, and 2012

did not include a full year of costs to use as a starting point from which to develop a forecast estimate;

therefore SCE chose the Itemized Forecast method for the Fuel Cell Program labor and non-labor. Since

the UCSB project was not operational until September 2012, the 2012 O&M recorded data does not

represent an entire calendar year and does not include any costs associated with the LTSA for this

project. As mentioned earlier, the fuel cell project at CSUSB is not expected to be operational until

2013, and therefore the 2012 O&M recorded data does not include any costs for the CSUSB project.

Because of this, the most appropriate O&M forecasting methodology is an Itemized Forecast. Table V-

6 identifies 2012 recorded Fuel Cell Program O&M costs and the 2013 - 2015 forecast, by project,

along with SCE program management labor for both sites.

Table V-6SCE Fuel Cell Program: 2012-2015 O&M

Calendar year 2012 dollars

2012Recorded

2013Forecast

2014Forecast

2015Forecast

UC Santa Barbara $863 $39,020 $85,576 $88,229

CSU San Bernardino $0 $228,155 $432,030 $467,800

SCE Labor $5,483 $112,500 $112,500 $112,500Total Fuel Cell Program $6,346 $379,675 $630,106 $668,529

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VI.

CATALINA GENERATION

A. Introduction

SCE provides electric service to the approximately 5,000 permanent residents and 750,000

annual visitors of Santa Catalina Island, which is located approximately twenty-seven miles off the

California coast. SCE’s service territory covers the entire Island, and includes the cities of Avalon and

Two Harbors, as well as rural areas located in Catalina’s rugged interior.

Currently, six diesel engine generators located at SCE’s Pebbly Beach Generating Station

(PBGS) in the city of Avalon provide power generation to Catalina residents and visitors. Diesel fuel

for the generators is delivered from refineries on the mainland to Catalina in tanker trucks, which are

transported to Catalina by barge. The fuel is then transferred to storage tanks, which in turn feed the

various engines as needed. The control operators and plant equipment operators at the station monitor

electrical load as it fluctuates throughout the day to ensure the generators meet the customer demand.

Generated electricity flows to a substation and then is distributed through three circuits (Hi Line,

Interior, and Wrigley) at 12 kilovolts (kV). Through numerous transformers located close to customers,

the 12 kV electricity is stepped down to service voltages for general use. Catalina is a closed electrical

system; electricity generated and distributed on Catalina is isolated and self-contained, and cannot be

obtained from the mainland.

SCE’s total generation capacity totals 12 megawatts (MW), which includes six diesel generators

(9.4 MW), twenty-three 65 kilowatt (KW) micro turbines (1.5 MW), and one energy storage battery (1.0

MW). Generation exhaust emissions are heavily regulated by the South Coast Air Quality Management

District (SCAQMD), and extensive air emissions monitoring and control equipment has been installed to

meet operating permit requirements.

1. Forecast O&M Expenses and Capital Expenditures

The following tables provide Catalina Generation’s O&M expense and capital forecasts,

which are described and supported in this chapter.

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Table VI-7 Catalina Generation

Summary o f2013-2015 O&M Forecast(Constant 2012 $000)

Account Activity 2015549.140 Catalina Generation Expenses $4,594

Total O&M Expenses $4,594

Table VI-8 Catalina Generation

Summary o f2013-2017 Capital Expenditures Forecast(Nominal $000) ]

________________Activity____________________2213________ 2214________ 2015________ 2016________ 2017________ TotalPBGS Generation Automation Installation $800 $3,505 $0 $0 $0 $4,305Projects less than $1 Million_____________ $1,680______ $1,960__________$420_________$310_________ $60______ $4,430

Total Expenditures $2,480______ $5,465__________$420_________$310_________ $60______ $8,735

2. Comparison of 2012 GRC Request, Authorized, and Recorded

In the 2012 GRC, SCE requested Catalina Generation O&M expenses of $5.149 million

and was authorized $4.913 million. SCE recorded O&M expenses of $4.194 million.

Expenses were lower than authorized in 2012 for several reasons. First, there were no

unplanned generation outages in 2012. Second, some planned maintenance work was rescheduled to

2013. Lastly, costs incurred for replacement of catalysts were lower than anticipated as a result of some

scheduling delays.

B. O&M Expenses

1. Catalina Generation O&M Expenses

Catalina Generation’s O&M expenses include all costs related to Catalina’s generation

assets. The expenses incurred for SCE’s electric distribution assets on Catalina Island are recorded in

the appropriate chapters within T&D’s testimony. FERC Account 549.140 includes the expenses related

to operating, maintaining, and repairing SCE’s Catalina Generation assets, the auxiliary apparatus and

systems, including the emergency generator, compressed air, emission control and monitoring systems,

pumps, diesel fuel storage tanks, compressors, and ventilation equipment, and the supervision and

management costs for generation personnel. This account also includes various miscellaneous expenses,

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including ordering and handling diesel fuel oil, spare parts, general and administrative support staff,

urgent automotive repair, tools, and hazardous waste documentation and compliance reporting.

Table VI-9 Catalina Generation O&M Expenses

FERC Account 549.140 Recorded and Adjusted 2008-2012/Forecast 2013-2015

(Constant 2012 $000)

Recorded Forecast2008 2009 2010 2011 2012 2013 2014 2015

Labor $1,744 $1,584 $1,984 $2,034 $2,230 $1,915 $1,915 $1,915Non-Labor $2,357 $3,421 $3,369 $2,286 $1,964 $2,679 $2,679 $2,679

Total $4,100 $5,005 $5,353 $4,319 $4,194 $4,594 $4,594 $4,594

Ratio of Labor to Total 43% 32% 37% 47% 53% 42% 42% 42%

Basis of Forecast: Five-Year AverageBasis of Labor/Non-Labor Split: Five-Year Average

a) Cost Forecast

Expenses in this account significantly fluctuate from year to year depending on

the extent of maintenance and repair work required for the generation assets and related equipment.

Costs have varied over the years for three primary reasons;

1) Catalina’s Gas, Water and Electric utilities share staff and expenses: Catalina

is the hub for all three of SCE’s utilities on the island. The amount of work

required for the different types of equipment vary from year to year. Annual

workloads can vary significantly for a variety of reasons. For instance,

fluctuations can result from different maintenance schedules for equipment,

responses to emergency or inspections, or emerging situations such as storms.

As a result, in one year, electric O&M costs may be down, while the costs

recorded to Gas and Water O&M may increase.

2) Capital projects: Personnel on Catalina are called upon to work on both

capital and O&M projects, doing everything from design work, to project

management, to daily supervision of the work. As projects wind up or down,

34



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the recorded O&M costs will either decrease or increase, as time is charged to

a capital work order.

3) Maintenance of Generation Equipment: The generators on Catalina undergo

scheduled and unscheduled maintenance activities. For example, in 2009,

SCE performed maintenance on its emission control equipment, and in 2010,

SCE performed major overhauls on four of its six diesel generators. With the

addition of the micro-turbines, these costs will tend to fluctuate even more

than they have in the past.

The variability in workload over the years affects both labor and non-labor

collectively. For instance, SCE personnel may be performing routine maintenance on one generator,

and experience problems with another generator at the same time, and have to call in contract resources.

SCE may also be working on a gas or water matter , and similarly have to bring in contract resources to

handle a temporary increase in workload due to unscheduled maintenance on one of the generators or

turbines. Since most of this fluctuation cannot be predicted very well (for instance, it depends on

weather and unpredictable equipment problems), SCE has determined that a five-year average is the best

methodology to forecast costs for 2015.

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C. Capital Expenditures

1. PBGS Generation Automation Project

Figure VI-7 PBGS Generation Automation Project

Recorded 2008-2012/Forecast 2013-2017(Nominal and Constant 2012 $000)


2008 2009 2010 2011 2012 2013 2014 2015 2016 2017Nominal $ $23 $201 $963 $2,591 $1,853 $800 $3,505 $- $- $-2012 Constant $ $28 $232 $1,059 $2,777 $1,853 $775 $3,321 $- $- $-

Nominal $ -2012 Constant $

The PBGS Generation Automation project was approved in the 2012 GRC. The project,

which was originally expected to be completed by year-end 2012, has been delayed slightly, but

significant work has been performed ($5.6 million through 2012) and the project is expected to be

completed in 2014. The project was delayed until the work scope specified in the 2009 Settlement

Agreement between SCAQMD and SCE for NOx control was fully understood. This delay allowed the

generation automation design to be integrated with several other Catalina projects, including the new

NaS battery, Micro Turbines installation, and the Control Room Betterment, Main Building Betterment,

and Security Betterment projects. All of these systems must work in parallel, and the Automation

system design needed to be integrated with peer sy stems that were being subsequently installed.

The project cost has also increased from $4.6 million (in the 2012 GRC) to $9.9 million,

due to unforeseen complexities, which include inte rference removal, design, programming, equipment

purchase, construction, and commissioning costs. The commissioning period has been extended from 4

months to 14 months because Catalina operations allow only one unit to be shut down at a time for

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engine control modification, final connections, and commissioning. The longer commissioning period

increases the costs of contractors, construction management, and engineering support. The actual cost

o f major equipment has been about three times the original estimate, and the costs of programming and

construction have been higher than originally estimated after they were put out for competitive bidding.

SCE’s Supervisory Control and Data Acquisition (SCADA) enhancement project will

automate the monitoring and control of the generation system and provide real time data on the

maintenance and operations activities of this system. This installation will provide one integrated

control system that can dispatch controlling actions using various options that are system knowledge-

based. The control system uses programmed knowledge of systems to make controlling decisions

regarding the optimization of the island’s electrical system.

Installing the SCADA system for Catalina generation will:

• Improve the labor-intensive process of starting the generating units

• Reduce the station operating complexity

• Maximize the air quality benefits of the micro turbines and NaS battery use

• Improve diesel generator fuel economy

• Reduce diesel engine NOx emis sions to help meet SCAQMD emission requirements

• Improve plant system safety and reliability

• Provide automatic dispatch capability

a) Cost Forecast

Figure VI-7 shows the estimated costs for the SCADA project. Cost estimates are

based on work scope developed from an engineering assessment, budgetary quotations from vendors,

and published reference book for cost estimating like “R.S. Means.” Detailed cost analysis is provided

in the Catalina capital workpaper titled “PBGS Generation Automation Project.”

\ , ,

\ — See workpapers p. 190

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2. Projects Less Than $1 Million

Figure VI-8Various Catalina Generation Projects Less Than $1 Million

Forecast 2013-2017(Nominal and Constant 2012 $000)

$2,500

2013 2014 2015 2016 2017Nominal $ $1,680 $1,960 $420 $310 $602012 Constant $ $1,627 $1,857 $389 $280 $53

Nominal $ ^ ^ ^ 2 0 1 2 Constant $

Catalina Generation also has severa l projects that are forecast to cost less than $1 million.

Figure VI-8 captures the estimated costs for these projects, which include:

• Antenna Consolidation/Platform Installation

• SCR Catalyst Replacement

• Diesel Unit 8 Zero-T Overhaul

• Diesel Unit 15 Zero-T Overhaul

• Plant Asphalt and Concrete Rep lacement

• Diesel Engine Water Treatment Program

• Perimeter Fencing Replacement

• Corrosion Control Program

• Sequence of Events Recorder

38



1 • Fuel Meter System Upgrade

2 • Diesel Engine Vibration Continuous Monitoring System

3 • Diesel Engine House Enclosures

4 D. Recorded Capital Expenditures Compared to Previous GRC Authorized

5 In compliance with Ordering Paragraph 7 of D.12-11-051, Figure VI-9 below summarizes

6 Catalina Generation’s recorded capital expenditures during 2008 through 2012, as well as forecast

7 expenditures for 2013 through 2017, and the 2009 and 2012 forecasts adopted by the Commission in our

8 2009 GRC25 and 2012 GRC.33

Figure VI-9 Catalina Generation

Recorded, Authorized and Forecast Expenditures


35 D.09-03-025

36 D.12-11-051

39


2015 General Rate Case - APPLICATION INDEX OF WORKPAPERS

EXHIBIT SCE-02, Vol. 10

DOCUMENT PAGE(S)Solar Photovoltaic ProgramO&M Workpapers for FERC Account 549 1-18Response to DRA-Verbal-010 Q.C.01 18aSolar Program O&M Forecast 18bO&M Workpapers for FERC Account 550 19-36Solar Program O&M Forecast 36aO&M Workpapers for FERC Account 546 37-46O&M Workpapers for FERC Account 548 47-56O&M Workpapers for FERC Account 551 57-66O&M Workpapers for FERC Account 553 67-76O&M Workpapers for FERC Account 554 77-86Capital Expenditure Workpapers 87-92Excerpts from D.09-06-049 93-106Excerpts from A.08-03-015 106a-cExcerpt fromA.08-03-015, Petition for Modification 106d-fExcerpt fromA.08-03-015, Second Petition for Modification 106g-iExcerpt from D.12-11-051, Ordering Paragraph 7 106jExcerpts from D.12-02-035 107-114Excerpts from D.13-05-033 115-120Recorded Cost Reasonableness 121-128Fuel Cell ProgramO&M Workpapers for FERC Account 549 129-146Capital Expenditure Workpapers 147-150Excerpts from D.10-04-028 150a-dA.09-04-018 Fuel Cell Program Testimony Excerpt 151-160A.10-11-015 2012 GRC Update Testimony- SCE 84 161-164A.09-02-013 A.09-04-018 Fuel Cell - Report of Southern California Edison Company (U 338-E) Regarding Efforts to Identify an Alternative Fuel Cell Site Pursuant to Decision 12-04-011

165-170

CatalinaFERC Account 549.140 - Operations and Maintenance of Generation Facilities 171-186

Catalina Generation Capital Workpapers 187-189PBGS Generation Automation Project Capital Forecast 190FERC Account 546.140 191-198FERC Account 548.140 199-206FERC Account 551.140 207-214FERC Account 552.140 215-222FERC Account 553.140 223-230ERC Account 554.140 231-238


Exhibit SCE-02, Volume 10 WORKPAPERS

Solar Photovoltaic Program

O&M FERC Account 549

Witness: Rudy Perez

Exhibit No. SCE-02/ Generation / Vol. 10Witnesses: R. Perez, J. Rumble and A. Edeson


Beginning of Workpapers for:

FERC Account: 549 Miscellaneous Other Power Generation Expenses

A ctiv ity: 549 - SOLAR PHOTOVOLTAIC PROGRAM

Witness: Rodolfo L Perez

Forecast Method

Chosen

2012$ (000)

Recorded

2012

Forecast

2015

Labor Last Recorded Year Adj. 1,731 555

Non-Labor Last Recorded Year Adj. 3,038 1,659

O ther N/A 0 0

Total 4,769 2,214

Description of Activity:

This activity includes the cost of program labor and expenses incurred in the operation and m aintenance of S o lar Photovoltaic

Program (S P V P ) projects.

Final Cost Centers included in this activity (S ee Appendix A for additional detail):

F525699 F527623 F527624 F527625 F527626 F527649 F527651 F528076 F528080 F528084

F528336



F E R C A c c o u n t : 5 4 9 M is c e lla n e o u s O th e r P o w e r G e n e ra t io n E x p e n s e s

A c tiv ity : 5 4 9 - S O L A R P H O T O V O L T A IC P R O G R A M

W itn e s s : R o d o lfo L P e re z

D E T E R M IN A T IO N O F R E C O R D E D /A D J U S T E D

I R e c o rd e d P erio d

$ (000)

2008 2009 2010 2011 2012

F E R C F o r m 1 R e c o rd e d (N o m in a l $)

Labor 0 0 0 3 146

N on-Labor 0 113 77 11,590 1,749

O ther 0______________0______________ 0______________0_____________0

Total 0 113 77 11,593 1,895

A d ju s tm e n ts - (N o m in a l $ ) - s e e A p p e n d ix B fo r a d d itio n a l d e ta il

Labor 102 474 964 1,488 1,585

Non-Labor 348 798 759 1,306 1,289

O ther 0 0 0 0 0

Total 450 1,272 1,723 2,794 2,874

R e c o rd e d /A d ju s te d (N o m in a l $)

Labor 102 474 964 1,491 1,731

Non-Labor 348 911 836 12,896 3,038

Other 0 0 0 0 0

Total 450 1,385 1,800 14,387 4,769

E sca la tio n :

Labor 1.1414 1.1070 1.0701 1.0327 1.0000

Non-Labor 1.0881 1.0814 1.0642 1.0254 1.0000

O ther 1.0000 1.0000 1.0000 1.0000 1.0000

R e c o rd e d /A d ju s te d (C o n s ta n t 2 0 1 2 $ )

Labor

Non-Labor

Other Total

116

379

0495

525

985

01 510

1,032

890

01,922

1.540

13.223

014,763

1,731

3.038

04.769

16 ,000

14 .000

12.000

10,000

8,000

6,000

4 .0 0 0

2.000

0

R e c o rd e d A d ju s te d 2 0 0 8 -2 0 1 2 (2 0 1 2 $ )

m200 8 200 9 2010 2011 2012

□ L a b o r (s td escl) ■ N o n -L abo r (s td esc l) □ Cither (no t escl)




Activ ity: 549 - SOLAR PHOTOVOLTAIC PROGRAM


Forecasting Methods - Summary o f Results o f all Methods Studied - 2012$ (000)

2 Recorded Years (2011 - 2012):Results of Averaging (A2)

COoCM 2014 | 2015 | sd** | Chosen_abor 1,635 1,635 1,635 96 no''Jon-Labor 8,131 8,131 8,131 5,093 noOther 0 0 0 0 noTotal 9,766 9,766 9,766 n/a n/a

3 Recorded Years (2010 -2012):Results of Linear Trending (T3)

LaborNon-LaborOtherTotal

2013 2014 2015 r2 * Chosen2,1347,865

0

2,4838,939

0

2,83310,014

0

0.94 no0.03 no0.00 no

9,999 11,422 12,847 n/a n/a

2013Results of Averaging (A3)

| 2014 ' '2015 sd* Chosen1,4345,717

0

1,4345,717

0

1,4345,717

0

295 no5,380 no

0 no7,151 7,151 7,151 n/a n/a

4 Recorded Years (2009 - 2012):Results of Linear Trending (T4)


2013 2014 2015 r2 * Chosen2,2399,157

0

2,65111,006

0

3,06412,855

0

0.97 no

0.17 no0.00 no

11,396 13,657 15,919 n/a n/a


sd** | Chosen2014 20151,207 1,2074,534 4,534

0 0

1,2074,534

0

469 no5,090 no

0 no5,741 5,741 5,741 n/a n/a

5 Recorded Years (2008 - 2012):Results of Linear Trending (T5) Results of Averaging (A5)


CO

oCM 2014 | 2015 | r2* I Chosen 2013 | 2014 | 2015 | sd** | Chosen2,262 2,686 3,111 0.98 no 989 989 989 605 no8,970 10,726 12,481 0.26 no 3,703 3,703 3,703 4,846 no

0 0 0 0 . 0 0 no 0 0 0 0 no11,232 13,412 15,592 n/a n/a 4,692 4,692 4,692 n/a n/a

Other Methods:

Last Recorded Year (LRY)


2013 2014 20151,7313,038

0

1,7313,038

0

1,7313,038

0

| ChoseTTItemized Forecast (IF)

yesyesno

4,769 4,769 4,769 n/a

2013 2014 2015 i r Chosen

nonon/a

Forecast Adjustments:Base Forecast Method Adjustments*


Method 2013 | 2014 | 2015 | 2013 | 2014 | 2015 | |LRY 1,731 1,731 1,731 377 (1,176) (1,176)LRY 3,038 3,038 3,038 2,498 (1,379) (1,379)N/A 0 0 0 0 0 0

4,769 4,769 4,769 2,875 (2,555) (2,555)

r2 = R Squared (Based on recorded years data)

sd = standard deviation (Based on recorded years data)

See Appendix B Fo r Additional Detail






Results:

Labor

Non-Labor

Other

Total

Forecasting Results

M ethod Selected 2013 | 201 4 | 201 5 | |

Last Recorded Y ear Adj. 2 ,108 555 555

Last Recorded Y ear Adj. 5 ,536 1 ,659 1,659

N/A 0 0 0

7,644 2 ,2 1 4 2 ,214

Analysis o f Forecasting Methods

Analysis of Linear Trending Method:In D. 0 4 -07 -022 and D. 89 -12 -057 , the C P U C stated that if costs have shown a trend in a certain direction over three or more

years, the last year recorded is an appropriate base estim ate. Labor costs have been increasing each year, which provides

our base for estimating Test Year 2015. Non-labor costs have not shown a trend. S ee analysis of last recorded year below.

Analysis of Averaging Method:In D. 0 4 -07 -022 and D. 89 -12 -057 , the C P U C stated that for those accounts which have significant fluctuations in recorded

expenses from year to year, an average of recorded expenses is appropriate. Recorded labor costs in this account have not

fluctuated significantly from year to year, so an average is not an appropriate forecast. Non-labor costs fluctuated in

201 0 -2 0 1 2 , however, the averaging method results in a forecast amount that is higher than the expected costs needed in this

account. S e e analysis of last recorded year below.

Analysis of Last Recorded Year (2012):In D. 0 4 -07 -022 and D. 89 -12 -057 , the C P U C stated that if costs have shown a trend in a certain direction over three or more

years, the last year recorded is an appropriate base estim ate. Labor costs have been increasing each year, which provides

our base for estimating Test Year 2015. To the labor base w e add increased costs in 201 3 for forecast construction activities, and decreased costs in 201 4 -2 015 . Non-labor costs utilize the last recorded year as the most reasonable basis to forecast

our expected expense level. To the non-labor base w e add increased costs in 2013 for forecast construction activities, and

decreases in 2014 and 201 5 to account for decreased materials costs.

Analysis of Itemized Forecast Method:Not applicable.






Recorded 2008-2012 / Forecast 2013-2015 2012$ (000)

16,000

14.000

12.000

10,000

8,000

6,000

4.000

2.000

02008 2009 2010 2011 2012 2013 2014 2015

□ L ab o r (s td esc l) ■ N o n -L abo r (s td e sc l) □ O the r (no t esc l)

:m m

*

|_____________________________________________________Recorded Period$ (0 0 0 )

F o re ca s t E xp e n se s (c o n s ta n t 2012$) 2008 | 2009 I 2010 | 2011 | 2012 2013 | 2014 | 2015Labor (s tan dard esca la tion ) 116 525 1,032 1,540 1,731 2,108 555 555

N o n-L abo r (s tandard esca la tion ) 379 985 890 13,223 3 ,038 5,536 1,659 1,659

O ther (no t e sca la tab le ) 0 0 0 0 0 0 0 0

Total 495 1,510 1,922 14,763 4 ,769 7,644 2 ,214 2,214

Labor P rio r ye a r Total 1,731 2 ,108 555

C h ange 377 (1,553) 0

Total 1,731 2,108 555 555

N o n-L abo r P rio r ye a r Total 3,038 5 ,536 1,659

C h ange 2.498 (3.877) 0

Total 3 ,038 5,536 1,659 1,659

O th e r P rio r ye a r Total 0 0 0

C h ange 0 0 0

Total 0 0 0 0

Total C h a n g e |

Labor 377 (1,553) 0

N o n-L abo r 2,498 (3,877) 0

O th e r 0 0 0

Total N /A 2,875 (5,430) 0






This page shows the changes in Labor, Non-Labor, and Other expenditures forecast during 2013 through 2015, including reasons for the addition of personnel (labor), increased office supplies required due to an increase in activity (non-labor).

2012 -2013

Labor: 377

Increased labor expense due to increased construction phase activities.

Non-Labor: 2,498

Increased non-labor expense due to increased construction phase activities.

Other: 0

Not applicable.






This page shows the changes in Labor, Non-Labor, and Other expenditures forecast during 2013 through 2015, including reasons for the addition o f personnel (labor), increased office supplies required due to an increase in activity (non-labor).

2013 -2014

Labor: (1,553)

Transition from capital installation to operation and maintenance phase of project.

Non-Labor: (3,877)

Decreased material costs due to completion of installation.

Other: 0

Not applicable.







20 1 4 -2015 _______________

Labor: 0

Not applicable.

Non-Labor: 0

Not applicable.

Other: 0

Not applicable.



THIS PAGE INTENTIONALLY LEFT BLANK



FERC Account:

A ctiv ity:

Witness:

549 Miscellaneous Other Power Generation Expenses

549 - SOLAR PHOTOVOLTAIC PROGRAM

Rodolfo L Perez

APPENDIX A

Detail Description of Final Cost Centers Included in This Activity




Activity: 549 - SOLAR PHOTOVOLTAIC PROGRAM


Description of Final Cost Centers included in this activity:

F525699 PROJECT DEVELOPMENT - SOLAR PHOTOVOLTAIC PROGRAM - MISCELLANEOUSOPERATION AND MAINTENANCE EXPENSESThis final cost center records the Project Development Solar Photovoltaic Program (SPVP) miscellaneous Operation and Maintenance (O&M) expenses such as material, contract and other costs incurred in connection with the SPVP.

F527623 SOLAR PV OPERATIONS 546 SUPERVISION & ENGINEERINGIncludes labor and expenses incurred in the general supervision and direction of the operation of rooftop solar photovoltaic systems at SPVP Sites 2, 3, 5, 6, 7, 8, 9, 11, 12, 13, 16, 22 and 26.Activities include: labor and expenses for operations manager and supervisors, Engineering & Technical Service labor and expenses, and Power Production Department Home Office engineering expenses.

F527624 SOLAR PV OPERATIONS 549 MISCELLANEOUS GENERATION EXPENSESIncludes labor and expenses that are not readily assignable to other operating accounts at SPVP Sites 2, 3, 5, 6, 7, 8, 9, 11, 12, 13, 16, 22 and 26. Activities include: management and administrative labor; general clerical support; labor relations costs, office supplies, safety and training expenses, first aid supplies, etc.

F527625 SOLAR PV MAINTENANCE 551 SUPERVISION & ENGINEERINGIncludes labor and expenses incurred in the general supervision and direction of the maintenance of rooftop solar photovoltaic systems at SPVP Sites 2, 3, 5, 6, 7, 8, 9, 11, 12, 13, 16, 22 and 26.Activities include: labor and expenses for maintenance manager and supervisors; NERC-CIP engineering costs; and hazardous material control.

F527626 SOLAR PV MAINTENANCE 554 MISCELLANEOUS GENERATION EXPENSESIncludes the cost of labor, materials and expenses incurred in the maintenance of rooftop solar photovoltaic systems at SPVP Sites 2, 3, 5, 6, 7, 8, 9, 11, 12, 13, 16, 22 and 26. Activities include: balance of plant systems; vehicle costs, station consumables, compressed air systems, fire systems, training for operations and maintenance, etc.

F527649 SOLAR PV - 548 OPERATIONS EXPENSESIncludes labor, materials used and expenses incurred in operating rooftop solar photovoltaic systems at SPVP Sites 2, 3, 5, 6, 7, 8, 9, 11, 12, 13, 16, 22 and 26. Activities include: operations craft labor and expenses, environmental compliance costs, permits and fees, and other expenses related to generation.

F527651 SOLAR PV MAINTENANCE 553 MAINTENANCE OF GENERATION & ELECTRICAL EQUIPMENTIncludes the cost of labor, materials and expenses incurred in the maintenance of rooftop solar photovoltaic systems at SPVP Sites 2, 3, 5, 6, 7, 8, 9, 11, 12, 13, 16, 22 and 26. Activities include: labor and expenses for maintenance craft labor; maintenance materials, contractor costs, maintenance of auxiliary electrical systems, calibration and maintenance, electrical distribution, etc.

F528076 SOLAR PV SITE 5 MAINTENANCE 553 MAINTENANCE GENERATION-ELECTRICAL EQUIPMENTIncludes the cost of labor, materials and expenses incurred in the maintenance of rooftop solar photovoltaic systems at SPVP Sites 2, 3, 5, 6, 7, 8, 9, 11, 12, 13, 16, 22 and 26. Activities include: labor and expenses for maintenance craft labor; maintenance materials, contractor costs, maintenance of auxiliary electrical systems, calibration and maintenance, electrical distribution, etc.




Activity: 549 - SOLAR PHOTOVOLTAIC PROGRAM



F528080 SOLAR PV MAINTENANCE 553 MAINTENANCE GENERATION-ELECTRICAL EQUIPMENTIncludes the cost of labor, materials and expenses incurred in the maintenance of rooftop solar photovoltaic systems at SPVP Sites 2, 3, 5, 6, 7, 8, 9, 11, 12, 13, 16, 22 and 26. Activities include: labor and expenses for maintenance craft labor; maintenance materials, contractor costs, maintenance of auxiliary electrical systems, calibration and maintenance, electrical distribution, etc.

F528084 SOLAR PV SITE 5 OPERATIONS 546 SUPERVISION-ENGINEERINGIncludes labor and expenses incurred in the general supervision and direction of the operation of rooftop solar photovoltaic systems at SPVP Sites 2, 3, 5, 6, 7, 8, 9, 11, 12, 13, 16, 22 and 26. Activities include: labor and expenses for operations manager and supervisors, Engineering & Technical Service labor and expenses, and Power Production Department Home Office engineering expenses.

F528336 SOLAR PV SITE 2 MAINTENANCE 553 GENERATION-ELECTRICAL EQUIPMENTIncludes the cost of labor, materials and expenses incurred in the maintenance of rooftop solar photovoltaic systems at SPVP Sites 2, 3, 5, 6, 7, 8, 9, 11, 12, 13, 16, 22 and 26. Activities include: labor and expenses for maintenance craft labor; maintenance materials, contractor costs, maintenance of auxiliary electrical systems, calibration and maintenance, electrical distribution, etc.






Recorded/Adjusted (Constant 2012$) By Final Cost Center$ (000)

2008 2009 2010 2011 2012

F525699 PROJECT DEVELOPMENT - SOLAR PHOTOVOLTAIC PROGRAM - MISCELLANEOUS OPERATION AND MAINTENANCE EXPENSES

495 1,510 1,922 14,574 4,078

F527623 SOLAR PV OPERATIONS 546 SUPERVISION & ENGINEERING

0 0 0 3 1

F527624 SOLAR PV OPERATIONS 549 MISCELLANEOUS GENERATION EXPENSES

0 0 0 10 45

F527625 SOLAR PV MAINTENANCE 551 SUPERVISION & ENGINEERING

0 0 0 119 132

F527626 SOLAR PV MAINTENANCE 554 MISCELLANEOUS GENERATION EXPENSES

0 0 0 0 77

F527649 SOLAR PV - 548 OPERATIONS EXPENSES 0 0 0 7 27

F527651 SOLAR PV MAINTENANCE 553 MAINTENANCE OF GENERATION & ELECTRICAL EQUIPMENT

0 0 0 48 408

F528076 SOLAR PV SITE 5 MAINTENANCE 553 MAINTENANCEGENERATION-ELECTRICAL EQUIPMENT

0 0 0 0 1

F528080 SOLAR PV MAINTENANCE 553 MAINTENANCEGENERATION-ELECTRICAL EQUIPMENT

0 0 0 0 1

F528084 SOLAR PV SITE 5 OPERATIONS 546 SUPERVISION-ENGINEERING

0 0 0 0 (2)

F528336 SOLAR PV SITE 2 MAINTENANCE 553 GENERATION-ELECTRICAL EQUIPMENT

0 0 0 0 1

Total 495 1,510 1,922 14,761 4,769

* * Due to rounding, totals m ay not tie to o ther workpaper pages.



FERC Account:

Activ ity:

Witness:



Rodolfo L Perez

APPENDIX B

Detail of Total Company Adjustments to Recorded




A ctiv ity : 549 - SOLAR PHOTOVOLTAIC PROGRAM


Detail o f Total Company Adjustm ents to Recorded Expenses

|Adjs - (Nominal $) $ (000)2008 2009 2010 2011 2012 2013 2014 2015

Labor 102 474 964 1,488 1,585 377 (1,176) (1,176)Non-Labor 348 798 759 1,306 1,289 2,498 (1,379) (1,379)Other 0 0 0 0 0 0 0 0

Total 450 1,272 1,723 2,794 2,874 2,875 (2,555) (2,555)

Company Wide Adjustment 1 GRC-JAB-CW-NONUTILCR

This adjustment reverses the non-utility affiliate credits related to expenses recorded in one or more of the final cost centers included in this activity and charged to non-utility affiliates. These adjustments are appropriate because all recorded non-utility affiliate credits were refunded to customers through the Base Revenue Requirement Balancing Account (BRRBA) pursuant to D.99-10-057. If these adjustments were not made, non-utility affiliate credits would be refunded to customers twice: (1) through adjustments to the BRRBA; and (2) through reductions to rates.

0 0 0 0 17 0 0LaborNon-LaborOtherTotal 18

Organizational Unit Adjustment 1 GRC-MJP.CPT-OUX-OTHER A&G TO SOLAR

Transfer from Other A&G FERC accounts 920/921 and 923 to FERC account 549 for expenses related to the Solar Photovoltaic activity where they are forecast.

LaborNon-LaborOther

102348

0

474831

0

964759

0

1,4121,214

0

1,222974

0

000

000

000

Total 450 1,305 1,723 2,626 2,196 0 0 0

Organizational Unit Adjustment 2 GBU-CPT-OU-SPVP ROLL UP TO 549

This adjustment transfers Solar costs from FERC 546, 548, 551, 553, and 554 to FERC 549 Operations.

Labor 0 0 0 81 343 0 0 0Non-Labor 0 0 0 92 303 0 0 0Other 0 0 0 0 0 0 0 0

Total 0 0 0 173 646 0 0 0

Organizational Unit Adjustment 3

This adjustment transfers equipment leases from FERC 550 to FERC 549.

GBU-CPT-OU-SPVP-EQUIPMENT LEASES TO 549


0110

11


o o 0 0 0 0 0

0 0 0 0 0 0 0






|Adjs - (Nominal $) $ (000)2008 2009 2010 2011 2012 2013 2014 2015


This adjustment transfers labor expenses from FERC 550 to FERC 549.

GBU-CPT-OU-SPVP - LABOR CORRECTION


(5)00

(5)


This adjustment removes one time expenses related to O&M from the Solar Photovoltaic Program.

GBU-CPT-OU-OTM ADJ


0(33)

0(33)


This future year adjustment is for changes to solar projects.

GBU-CPT-OU-FYA SPVP FUTURE ADJ

Labor 0 0 0 0 0 377 (1,176) (1,176)Non-Labor 0 0 0 0 0 2,498 (1,379) (1,379)Other 0 0 0 0 0 0 0 0Total 0 0 0 0 0 2,875 (2,555) (2,555)

3 0



End of Workpapers for:





Workpaper - Southern California Edison / 2015 GRC - APPLICATION18a

Southern California Edison 2015 GRC A.13-11-XXX

DATA REQUEST SET DRA-Verbal-010

To: DRA Prepared by: Anthony Kurpakus

Title: Manager Dated: 08/22/2013

Received Date: 08/22/2013

Question C.01:

Originator: Peter Morse

Solar, SCE 02, Volume 10

C.1. Provide additional explanation for the derivation of $24,310/MW forecast shown in the column titled "Revised Allocation" in Table III.3. (confidential testimony, p 14)

Response to Question C.01: Should be DC

In Table III-3, the $24,310/MW is based on the 2015 Test Year SPVP O&M, not including the Roof Lease costs. It is calculated by using the 2015 O&M forecast divided by the Solar AC Megawatt capacity. The calculation from the table is: $2.212 M, times 1 Million , divided by 91 MW, equals $24,308 /MW ($2.212M*1,000,000/91MW =$24,308/MW). The difference between the calculated $24,308/MW and the $24,310 from the table is due to rounding. Additional information has been provided to show the derivation of the 2015 test year expense forecast. See the attached fde, "Solar 2015 GRC O&M Detail".

□


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FERC Account: 550 Rents



Forecast Method Chosen

2012$ (000)

Recorded2012

Forecast2015

Labor N/A 0 0Non-Labor Last Recorded Year Adj. 2,127 2,084Other N/A 0 0Total 2,127 2,084


This activity shall include all rents of property of others used, occupied, or operated in connection with Solar Photovoltaic Program (SPVP) projects.

Final Cost Centers included in this activity (See Appendix A for additiona l detail):

F525698 F527650






DETERMINATION OF RECORDED/ADJUSTED

Recorded Period$ (000)

2008 2009 2010 2011 2012FERC Form 1 Recorded (Nominal $)

Labor 0 0 0 (5) 3Non-Labor 0 159 146 737 2,138Other 0_________ 0__________0__________0_________ 0Total 0 159 146 732 2,141

Adjustments- (Nominal $) - see Appendix B for additional detailLabor 0 0 0 5 (3)Non-Labor 0 0 0 0 (11)Other 0 0 0 0 0Total 0 0 0 5 (14)

Recorded/Adjusted (Nominal $)Labor 0 0 0 0 0Non-Labor 0 159 146 737 2,127Other 0 0 0 0 0Total 0 159 146 737 2,127

Escalation:Labor 1.1414 1.1070 1.0701 1.0327 1.0000

Non-Labor 1.0881 1.0814 1.0642 1.0254 1.0000

Other 1.0000 1.0000 1.0000 1.0000 1.0000

Recorded Adjusted 2008-2012 (2012$)

2,400

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□ Labor (std escl) Non-Labor (std escl) □ Other (not escl)






Forecasting Methods - Summary o f Res ults o f all Methods Studied - 2012$ (000)


COoCM ^r

oCM 2015 | sd** | ChosenLabor 0 0 0 0 noNon-Labor 1,441 1,441 1,441 686 noOther 0 0 0 0 noTotal 1,441 1,441 1,441 n/a n/a


COoCM ^r

oCM 2015 | r2* | Chosen 2013 | 2014 | 2015 | sd** | ChosenLabor 0 0 0 0.00 no 0 0 0 0 noNon-Labor 2,984 3,970 4,956 0.95 no 1,013 1,013 1,013 825 noOther 0 0 0 0.00 no 0 0 0 0 no

Total 2,984 3,970 4,956 n/a n/a 1,013 1,013 1,013 n/a n/a



COoCM r̂oCM 2015 | r2* | Chosen

COoCM r̂oCM 2015 | sd** | Chosen0 0 0 0.00 no 0 0 0 0 no

2,419 3,065 3,712 0.81 no 803 803 803 802 no0 0 0 0.00 no 0 0 0 0 no

2,419 3,065 3,712 n/a n/a 803 803 803 n/a n/a



COoCM ^roCM 2015 | r2* | Chosen

COoCM ^roCM 2015 | sd** | Chosen0 0 0 0.00 no 0 0 0 0 no

2,093 2,577 3,061 0.76 no 642 642 642 786 no0 0 0 0.00 no 0 0 0 0 no

2,093 2,577 3,061 n/a n/a 642 642 642 n/a n/a

Other Methods:

Last Recorded Year (LRY) Itemized Forecast (IF)


COoCM ^roCM 2015 1 | Chosen

COoCM ^roCM 2015 | | Chosen0 0 0 no 0 0 0 no

2,127 2,127 2,127 yes 0 0 0 no0 0 0 no 0 0 0 no

2,127 2,127 2,127 n/a 0 0 0 n/a

Forecast Adjustm ents:Base Forecast Method Adjustments*


Method

COoCM ^roCM 2015 |

COoCM ^roCM 2015 | |N/A 0 0 0 0 0 0LRY 2,127 2,127 2,127 (43) (43) (43)N/A 0 0 0 0 0 0

2,127 2,127 2,127 (43) (43) (43)

* r2 = R Squared (Based on recorded years data)

** sd = standard deviation (Based on recorded years data)

*** See Appendix B F o r Additional Detail





W itness: Rodolfo L Perez

Results:

Forecasting Results

Method Selected 2013 | 2014 | 2015 | |Labor N/A 0 0 0Non-Labor Last Recorded Year Adj. 2,084 2,084 2,084Other N/A 0 0 0Total 2,084 2,084 2,084


Analysis of Linear Trending Method:In D. 04-07-022 and D. 89-12-057, the CPUC stated that if costs have sh own a trend in a certain direction over three or more years, the last year recorded is an appropriate base estimate. Non-labor costs have been increasing each year, which provides a base for estimating the test year 2015. To this base we decreased costs for 2013, reflecting the decreased costs for roof leases.

Analysis of Averaging Method:In D. 04-07-022 and D. 89-12-057, the CPUC stated that for those accounts which have significant fluctuations in recorded expenses from year to year, an average of recorded expenses is approp riate. Recorded costs in this account have not fluctuated significantly from year to year, so an average is not an appropriate forecast.

Analysis of Last Recorded Year (2012):In D. 04-07-022 and D. 89-12-057, the CPUC stated that if recorded expenses in an account have been relatively stable for three or more years, the last recorded year is an appropriate base estimate. Costs in this account have not been stable, but use of this method is applicable because there is a historical trend of increasing costs. To this base we decreased expenses for non-repeating leases expenses.








2,400

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1,200

800

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0llll

2008 2009 2010 2011 2012 2013 2014 2015

□ Labor (std escl) Non-Labor (std escl) □ Other (not escl)

1 Recorded Period$ (000)

Forecast Expenses (constant 2012$) 2008 | 2009 | 2010 | 2011 | 2012 2013 | 2014 | 2015Labor (standard escalation) 0 0 0 0 0 0 0 0Non-Labor (standard escalation) 0 172 155 756 2,127 2,084 2,084 2,084Other (not escalatable) 0 0 0 0 0 0 0 0Total 0 172 155 756 2,127 2,084 2,084 2,084

Labor Prior year Total 0 0 0Change 0 0 0Total 0 0 0 0

Non-Labor Prior year Total 2,127 2,084 2,084ChangeTotal

(43) 0 02,127 2,084 2,084 2,084

Other Prior year Total 0 0 0Change 0 0 0Total 0 0 0 0

Total ChangeLabor 0 0 0Non-Labor (43) 0 0Other 0 0 0Total N/A (43) 0 0






This page shows the changes in Labor, Non-Labor, and Other expenditures forecast during 2013 through 2015, including reasons for the addition of personnel (labor), increased office supplies required due to an increase in activity (non-labor).

2012 - 2013

Labor: 0

Not applicable.

Non-Labor: (43)

Non-labor expense decreases due to non-repeating lease expenses.

Other: 0

Not applicable.






This page shows the changes in Labor, Non-Labor, and Oth er expenditures forecast during 2013 through 2015, including reasons for the addition of personne l (labor), increased office supplies required due to an increase in activity (non-labor).

2013 - 2014

Labor: 0

Not applicable.

Non-Labor: 0

Not applicable.

Other: 0

Not applicable.






This page shows the changes in Labor, Non-Labor, and Oth er expenditures forecast during 2013 through 2015, including reasons for the addition of personnel (labor), increased office supplies required due to an increase in activity (non-labor).

2014 - 2015_______________

Labor: 0

Not applicable.

Non-Labor: 0

Not applicable.

Other: 0

Not applicable.



FERC Account

A ctiv ity:

W itness:

550 Rents


Rodolfo L Perez

APPENDIX A

D e t a i l D e s c r i p t i o n o f F i n a l C o s t C e n t e r s

I n c l u d e d in T h r s A c t i v i t y




Activity: 550 - SOLAR PHOTOVOLTAIC p r o g r a m



F525698 PROJECT DEVELOPMENT - SOLAR PHOTOVOLTAIC PROGRAM - LEASESThis final cost center records the Project Development Solar Photovoltaic program lease expenses.

F527650 SOLAR PV MAINTENANCE 550 RENTSIncludes all rents of property of others used, occupied, or operated in connection with rooftop solar photovoltaic systems at SPVP Sites 2, 3, 5, 6, 7, 8, 9, 11, 12, 13, 16, 22 and 26.



FERC Account

Activ ity:

Witness:

Recorded/Adjusted (Cons tant 2012$) By Final Cost Center

$ (000)2008 2009 2010 2011 2012

550 Rents


Rodolfo L Perez

F525698 PROJECT DEVELOPMENT - SOLAR 0 172 155 756 2,127PHOTOVOLTAIC PROGRAM - LEASES

F527650 SOLAR PV MAINTENANCE 550 RENTS 0 0 0 0 0

Total 0 172 155 756 2,127

* * Due to rounding, totals m ay not tie to o the r workpaper pages.



FERC Account

A ctiv ity:

Witness:

550 Rents


Rodolfo L Perez

APPENDIX B

D e t a i l o f T o t a l C o m p a n y

A d j u s t m e n t s t o R e c o r d e d






Detail o f Total Company Adj ustments to Recorded Expenses

| Adjs - (Nominal $) $ (000)2008 2009 2010 2011 2012 2013 2014 2015

Labor 0 0 0 5 (3) 0 0 0Non-Labor 0 0 0 0 (11) (43) (43) (43)Other 0 0 0 0 0 0 0 0

Total 0 0 0 5 (14) (43) (43) (43)

Organizational Unit Adjustment 1 GBU-CPT-OU-FYA SPVP FUTURE ADJ

This future year adjustment is a reduction to the forecast due to n on-repeating lease expenses.

Labor 0 0 0 0 0 0 0 0Non-Labor 0 0 0 0 0 (43) (43) (43)Other 0 0 0 0 0 0 0 0

Total 0 0 0 0 0 (43) (43) (43)

Organizational Unit Adjustment 2 GBU-CPT-OU-SPVP - LABOR CORRECTION

This adjustment transfers labor expenses from FERC 550 to FERC 549.

Labor 0 0 0 5 (3) 0 0 0Non-Labor 0 0 0 0 0 0 0 0Other 0 0 0 0 0 0 0 0

Total 0 0 0 5 (3) 0 0 0

Organizational Unit Adjustment 3 GBU-CPT-OU-SPVP-EQUIPMENT LEASES TO 549

This adjustment transfers equipment leases from FERC 550 to FERC 549.

Labor 0 0 0 0 0 0 0 0Non-Labor 0 0 0 0 (11) 0 0 0Other 0 0 0 0 0 0 0 0

Total 0 0 0 0 (11) 0 0 0


Exhibit No. SCE-02 / Generation / Vol. 10 Witnesses: R. Perez, J. Rumble and A. Edeson

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E xhib it SCE-02, Volume 10 WORKPAPERS


O & M FERC Account 546

Witness: Rudy Perez




FERC Account: 546 Operation Supervision and Engineering




2012$ (000)

Recorded2012

Forecast2015

Labor N/A 0 0Non-Labor N/A 0 0Other N/A 0 0Total 0 0


This activity package has zero dollars; all costs have been transferred to other activities.

Final Cost Centers included in this activity (See Appendix A for additional detail):

F527623 F528084







R e c o rd e d P erio d

$ (0 0 0 )

2 0 0 8 2 0 0 9 2 0 1 0 2011 2 0 1 2

F E R C F o rm 1 R e c o rd e d (N o m in a l $)

Labor 0 0 0 3 (1)

Non-Labor 0 0 0 0 0

O ther 0 0 0 0 0

Total 0 0 0 3 (1)

A d ju s tm e n ts - (N o m in a l $)

Labor

s e e A p p e n d ix B fo r a d d it io n a l d e ta il

0 0 0 (3) 1

Non-Labor 0 0 0 0 0

O ther 0 0 0 0 0

Total 0 0 0 (3) 1


Labor 0 0 0 0 0

Non-Labor 0 0 0 0 0

O ther 0 0 0 0 0

Total 0 0 0 0 0

E sca la tio n

Labor 1.1414 1.1070 1.0701 1.0327 1.0000

Non-Labor 1.0881 1.0814 1.0642 1.0254 1.0000

O ther 1.0000 1.0000 1.0000 1.0000 1.0000


Labor 0 0 0 0 0

Non-Labor 0 0 0 0 0

O ther 0 0 0 0 0

Total 0 0 0 0 0


6

4

2

0

-2

-4

2 0 0 8 2 0 0 9 2 0 1 0 2 01 1 2 0 1 2

□ L a b o r (std e sc l) ■ N o n -L a b o r (s td e sc l) □ O th e r (n o t e s c l)



FERC Account:

Activ ity:

Witness:

546 Operation Supervision and Engineering


Rodolfo L Perez

APPENDIX A








2008 2009 2010 2011 2012

F527623 SOLAR PV OPERATIONS 546 0 0 0 0 0SUPERVISION & ENGINEERING

F528084 SOLAR PV SITE 5 OPERATIONS 546 0 0 0 0 0SUPERVISION-ENGINEERING

Total


0 0 0 0 0



FERC Account:

Activ ity:

Witness:



Rodolfo L Perez

APPENDIX B








|Adjs - (Nominal $) $ (000)2008 2009 2010 2011 2012 2013 2014 2015

Labor 0 0 0 (3) 1 0 0 0Non-Labor 0 0 0 0 0 0 0 0Other 0 0 0 0 0 0 0 0

Total 0 0 0 (3) 1 0 0 0



Labor 0 0 0 (3) 1 0 0 0Non-Labor 0 0 0 0 0 0 0 0Other 0 0 0 0 0 0 0 0

Total 0 0 0 (3) 1 0 0 0






Witness: Rudy Perez




FERC Account: 548 Generation Expenses




2012$ (000)

Recorded2012

Forecast2015





F527649







! R e c o rd e d P e rio d

$ (0 0 0 )

2 0 0 8 2 0 0 9 2 0 1 0 2011 2 0 1 2

F E R C F o rm 1 R e c o rd e d (N o m in a l $ )

Labor 0 0 0 7 26

N on-Labor 0 0 0 0 1

O the r 0______________0______________0_____________ 0_____________ 0

Total 0 0 0 7 27

A d ju s tm e n ts - (N o m in a l $) - s e e A p p e n d ix B fo r a d d it io n a l d e ta il

Labor 0 0 0 (7) (26)

Non-Labor 0 0 0 0 (1)

O ther 0 0 0 0 0

Total 0 0 0 (7) (27)


Labor 0 0 0 0 0

Non-Labor 0 0 0 0 0

O ther 0 0 0 0 0

Total 0 0 0 0 0

E sca la tio n :

Labor 1.1414 1.1070 1.0701 1.0327 1.0000

Non-Labor 1.0881 1.0814 1.0642 1.0254 1.0000

O ther 1.0000 1.0000 1.0000 1.0000 1.0000


Labor

N on-Labor

O ther

Total


2008 2009 2010 2011 2012

□ Labor (std escl) ■ Non-Labor (std escl) □ Other (not escl)



FERC Account

Activ ity:

Witness:

548 Generation Expenses


Rodolfo L Perez

APPENDIX A








2008 2009 2010 2011 2012

F527649 SOLAR PV - 548 OPERATIONS EXPENSES 0 0 0 0 0

Total 0 0 0 0 0




FERC Account:

Activ ity:

Witness:



Rodolfo L Perez

APPENDIX B








|Adjs - (Nominal $) $ (000)2008 2009 2010 2011 2012 2013 2014 2015

Labor 0 0 0 (7) (26) 0 0 0Non-Labor 0 0 0 0 (1) 0 0 0Other 0 0 0 0 0 0 0 0

Total 0 0 0 (7) (27) 0 0 0



Labor 0 0 0 (7) (26) 0 0 0Non-Labor 0 0 0 0 (1) 0 0 0Other 0 0 0 0 0 0 0 0

Total 0 0 0 (7) (27) 0 0 0





Activ ity:

W itness:


Rodolfo L Perez






Witness: Rudy Perez




FERC Account: 551 Maintenance Supervision and Engineering




2012$ (000)

Recorded2012

Forecast2015





F527625







I R e c o rd e d P e rio d

$ (0 0 0 )

2 0 0 8 2 0 0 9 2 0 1 0 2011 2 0 1 2


Labor 0 0 0 58 114

N on-Labor 0 0 0 58 18

O the r 0______________0_____________ 0______________ 0_____________0

Total 0 0 0 116 132


Labor 0 0 0 (58) (114)

Non-Labor 0 0 0 (58) (18)

O ther 0 0 0 0 0

Total 0 0 0 (116) (132)


Labor 0 0 0 0 0

Non-Labor 0 0 0 0 0

O ther 0 0 0 0 0

Total 0 0 0 0 0

E sca la tio n :

Labor 1.1414 1.1070 1.0701 1.0327 1.0000

Non-Labor 1.0881 1.0814 1.0642 1.0254 1.0000

O ther 1.0000 1.0000 1.0000 1.0000 1.0000


Labor

N on-Labor

O ther

Total


2008 2009 2010 2011 2012




FERC Account:

Activ ity:

Witness:

551 Maintenance Supervision and Engineering


Rodolfo L Perez

APPENDIX A








2008 2009 2010 2011 2012

F527625 SOLAR PV MAINTENANCE 551 SUPERVISION & ENGINEERING

0 0 0 0 0

Total 0 0 0 0 0




FERC Account:

Activ ity:

Witness:



Rodolfo L Perez

APPENDIX B








|Adjs - (Nominal $) $ (000)2008 2009 2010 2011 2012 2013 2014 2015

Labor 0 0 0 (58) (114) 0 0 0Non-Labor 0 0 0 (58) (18) 0 0 0Other 0 0 0 0 0 0 0 0

Total 0 0 0 (116) (132) 0 0 0

Organizational Unit Adjustment 1 GBU-CPT-OU-SPVP ROLL UPTO 549



Total 0 0 0 (116) (132) 0 0 0






Witness: Rudy Perez




FERC Account: 553 Maintenance of Generating and Electric Plant




2012$ (000)

Recorded2012

Forecast2015





F527651 F528076 F528080 F528336







|_____________________________________________________________ R e c o rd e d P e rio d _________________

$ (000)

2008 2009 2010 2011 2012


Labor 0 0 0 13 186

N on-Labor 0 0 0 34 225

O the r 0_____________ 0______________ 0______________0_____________0

Total 0 0 0 47 411


Labor 0 0 0 (13) (186)

Non-Labor 0 0 0 (34) (225)

O ther 0 0 0 0 0

Total 0 0 0 (47) (411)


Labor 0 0 0 0 0

Non-Labor 0 0 0 0 0

O ther 0 0 0 0 0

Total 0 0 0 0 0

E sca la tio n :

Labor 1.1414 1.1070 1.0701 1.0327 1.0000

Non-Labor 1.0881 1.0814 1.0642 1.0254 1.0000

O ther 1.0000 1.0000 1.0000 1.0000 1.0000


Labor

N on-Labor

O ther

Total


2008 2009 2010 2011 2012

□ L ab o r (s td esc l) ■ N o n -L abo r (s td e sc l) □ O the r (no t esc l)



FERC Account:

Activ ity:

Witness:

553 Maintenance of Generating and Electric Plant


Rodolfo L Perez

APPENDIX A








2008 2009 2010 2011 2012

F527651 SOLAR PV MAINTENANCE 553 MAINTENANCE OF GENERATION & ELECTRICAL EQUIPMENT

0 0 0 0 0

F528076 SOLAR PV SITE 5 MAINTENANCE 553 MAINTENANCEGENERATION-ELECTRICAL EQUIPMENT

0 0 0 0 0

F528080 SOLAR PV MAINTENANCE 553 MAINTENANCEGENERATION-ELECTRICAL EQUIPMENT

0 0 0 0 0

F528336 SOLAR PV SITE 2 MAINTENANCE 553 GENERATION-ELECTRICAL EQUIPMENT

0 0 0 0 0

Total 0 0 0 0 0




FERC Account:

Activ ity:

Witness:



Rodolfo L Perez

APPENDIX B








|Adjs - (Nominal $) $ (000)2008 2009 2010 2011 2012 2013 2014 2015


Total 0 0 0 (47) (411) 0 0 0

Organizational Unit Adjustment 1 GBU-CPT-OU-SPVP ROLL UPTO 549



Total 0 0 0 (47) (411) 0 0 0





Activ ity:

W itness:


Rodolfo L Perez






Witness: Rudy Perez




FERC Account: 554 Maintenance of Miscellaneous Other Power Generation Plant




2012$ (000)

Recorded2012

Forecast2015





F527626






D E TER M INA TIO N O F REC O R D ED /A D JU STED

Recorded Period

$ (0 0 0 )

2 0 0 8 2 0 0 9 2 0 1 0 2011 2 0 1 2

FERC Form 1 Recorded (N om inal $)Labor 0 0 0 0 18

Non-Labor 0 0 0 0 59

O ther 0 0 0 0 0

Total 0 0 0 0 77

A d justm ents- (Nom inal $)

Labor

see Appendix B fo r add itional detail0 0 0 0 (18)

Non-Labor 0 0 0 0 (59)

O ther 0 0 0 0 0

Total 0 0 0 0 (77)

Recorded/A d justed (Nom inal $)

Labor 0 0 0 0 0

Non-Labor 0 0 0 0 0

O ther 0 0 0 0 0

Total 0 0 0 0 0

E sca la tio n

Labor 1.1414 1.1070 1.0701 1.0327 1.0000

Non-Labor 1.0881 1.0814 1.0642 1.0254 1.0000

O ther 1.0000 1.0000 1.0000 1.0000 1.0000

R ecorded/A djusted (C onstan t 2012$)

Labor 0 0 0 0 0

Non-Labor 0 0 0 0 0

O ther 0 0 0 0 0

Total 0 0 0 0 0

Recorded A d justed 2008-2012 (2012$)

6

4

2

0

-2

-4

2008 2009 2010 2011 2012

□ Labor (std esc l) ■ N o n -L abo r (s td esc l) □ O the r (n o t e sc l)



FERC Account:

Activ ity:

Witness:

554 Maintenance of Miscellaneous Other Power Generation Plant


Rodolfo L Perez

APPENDIX A








2008 2009 2010 2011 2012

F527626 SOLAR PV MAINTENANCE 554 MISCELLANEOUS GENERATION EXPENSES

0 0 0 0 0

Total 0 0 0 0 0

** Due to rounding, totals may not tie to other workpaper pages.



FERC Account:

Activ ity:

Witness:



Rodolfo L Perez

APPENDIX B








|Adjs - (Nominal $) $ (000)2008 2009 2010 2011 2012 2013 2014 2015

Labor 0 0 0 0 (18) 0 0 0Non-Labor 0 0 0 0 (59) 0 0 0Other 0 0 0 0 0 0 0 0

Total 0 0 0 0 (77) 0 0 0



Labor 0 0 0 0 (18) 0 0 0Non-Labor 0 0 0 0 (59) 0 0 0Other 0 0 0 0 0 0 0 0

Total 0 0 0 0 (77) 0 0 0





Capital Expenditures

Witness: Rudy Perez



Southern California Edison Company

CA PITAL W O R K P A P E R S - 2015 G R C

O P E R A T IN G U N IT SU M M A R Y

(Nominal $000)

Operating Unit Summary: GEN - Solar PV

(1) OPERATING UNIT FORECAST CAPITAL EXPENDITURES: 2015 GRC

Item Testimony DescriptionForecast Capital Expenditures

2013 2014 2015 2016 2017 Total

1 Generation 31,500 0 C 0 0 31,500

2 Projects and Blanket Work Orders Under $1 Million 0 425 1,035 269 5,680 7,409

Total 31,500 425 1,035 269 5,680 38,909



S outhern C a lifo rn ia Ed ison C om pany

C A P ITA L W O R K P A P E R S - 2015 G R C

OPERATING UNIT SUMMARY

(Nominal $000)

Operating Unit Summary: G EN - So lar PV

(2) O PERA TIN G UNIT R E C O R D E D AND AU TH O RIZED C A P ITA L AND F O R E C A S T E X P EN D ITU R ES: 2015 GRC

DescriptionRecorded and Authorized Capital Expenditures Forecast Capital Expenditures

2008 2009 2010 2011 2012 2013 2014 2015 2016 2017

Authorized Expenditures 0 87,991

Recorded & Forecast Expenditures 11,159 9,316 121,315 161,619 32,186 31,500 425 1,035 269 5,680

Total Expenditure 335,594 38,909

Recorded, Authorized and Forecast Expenditures Graph

180,000

160.000

140.000

120.000

t)0,000

80,000

60,000

40.000

20.000

02008 2009 2010 2011 2012 2013 2014 2015 2016 2017

R e c o rd e d | j A u th o r iz e d F o reca s t




CAPITAL W O R K P A P E R S - 2015 G R C

P R O JE C T DETAIL W O R K S H E E T : SO LA R C O N S TR U C T IO N

Organizational Unit Summary: GEN - Solar PV Testimony Summary: SCE-02, Volume 10 Major Program: Generation Category: Gen - Solar Detail: Solar Construction Database ID: 1145 / RO Model ID: 13

1. WITNESS

2. PROJECT DETAILProgram Group

Program

P in #

W B S Element

3. PROJECT TYPE

Rudy Perez

P P D SP V P

S P E C IF IC -S C

6556

C G 0-00-P P -S C -000001

Select one

Compliance: Safety, Environmental, Licenses

Replacem ents in Kind

Upgrades

Blanket: FE, Tools, Spare Parts, Lab, Computer Equip

Select one

Customer Growth

Load Growth

Reliability

Capitalized Software

Various (See Below)

4. ASSET TYPE

5. CLOSE DATE

6. RIIM ELIGIBLE

Solar PV

12/1 /2013

N/A

20 1 5 GRC - C a p i t a l E x p e n d i t u r e s F o r e c a s t

25,000

20,000

15,000

10,000

2013 2014 2015 2016 2017

7. COST ESTIMATES (NOMINAL $000)

Yr SC E $

2013 31,500

2014 0

2015 0

2016 0

2017 0

Total 31,500

X

7(a). SYSTEM SHORT TEXT

7 (b). DETAILED DESCRIPTION

8. SCOPE

9. JUSTIFICATION

PP D S P V P Construction

Solar Photovoltaic Program (S P V P ) Construction - Capital expenditures in 2013 reflect the capital required to complete the construction of the S P V P final solar site, Redlands distribution center (RD C) 10.

Conclusion of the build out of the S P V P program, which includes installation of the Electrical Fault Protection System and the Emmerson Comm and and Control systems on all the S P V P facilities.

Capital is required to finish construction of S P V P Utility owned generation's (U O G ) final site and fulfill the Commission's build-out requirements per Decision 13-05-033. The Electrical Fault Protection and Em merson Comm and and Control systems are needed to ensure that the S P V P sites are operated, monitored, and maintained safely and effectively throughout their life.





P R O JE C T DETAIL W O R K S H E E T : SP A R E PA RTS BLANKET

Organizational Unit Summary: GEN - Solar PV Testimony Summary: SCE-02, Volume 10Major Program: Projects and Blanket Work Orders Under $1 MillionCategory: BlanketDetail: Spare Parts BlanketDatabase ID: 1146 / RO Model ID: 14

1. WITNESS2. PROJECT DETAIL

Program Group

Program

P in #

W B S Element

3. PROJECT TYPE

Rudy Perez

P P D S P V

BLAN KET S P V

7132

C G 0-00-P P -S P-000004

Select one



Upgrades


Select one

X

Customer Growth

Load Growth

Reliability


Various (See Below)

4. ASSET TYPE

5. CLOSE DATE

6. RIIM ELIGIBLE

Solar PV

Blanket

N/A


Yr SC E $

2013 0

2014 425

2015 1,035

2016 269

2017 5,680

Total 7,409

20 15 GRC - C a p i t a l E x p e n d i t u r e s F o r e c a s t

6 000

5.000

4000

3 000

2000

1000

02013 2014 2015 2016 2017

7(a). SYSTEM SHORT TEXT

7 (b). DETAILED DESCRIPTION

8. SCOPE

9. JUSTIFICATION

PPD Solar Photovoltaic 044-S pare Parts

S o la r Pho tovo lta ic (S P V ) 044 -S pare Parts - C ap ita l expend itu res in 2014 through 2017 reflect expend itu res ca tegorized as cap ita l under SCE accounting sys tem s; these expend itu res inc lude the rep lacem ent o f parts, p rim arily inverters and tran s fo rm ers utilized fo r pow er contro l in S P V system s.

Purchase o f cap ita l rep lacem ent parts, p rim arily inverte rs and tran s fo rm ers fo r O &M o f the SP VP utility ow ned genera tion (UO G ) fac ilities .

C ap ita l rep lacem ent pa rts are required to m ainta in the S o la r P ho tovo lta ic P rogram (SPV P) s ites in w orking cond ition . W ith o u t spare parts to replace fa iled com pone n ts , s ites w ould de terio ra te and not opera te at rated capacity .





D .09-06-049

Witness: Rudy Perez



COM /JB2/ avs Date of Issuance 6/2^2009

Decision 09-06-049 June 18, 2009

BEFORE THE PUBLIC UTILITIES COMMISSION OF THE STATE OF CALIFORNIA

Application of Southern California EdisonCompany (U338E) for Authority to Implement Application 08-03-015and Recover in Rates the Cost of its Proposed (Filed March 27,2008)Solar Photovoltaic (PV) Program.

DECISION ADDRESSING A SOLAR PHOTOVOLTAIC PROGRAM FOR SOUTHERN CALIFORNIA EDISON COMPANY

387876 - 1 -



A.08-03-015 COM/JB2/ avs

energy system."12 More recently, the California Air resources Board adopted a

scoping plan that specifically identified a target of 33% renewables by 2020 as a

key strategy that will help the state achieve its 2020 greenhouse gas emission

reduction goal. Consistent with these principles, and given the magnitude of the

state's renewable objectives, we find that the SPVP is a reasonable step to

encourage development of more distributed renewable resources in the one to

two MW range. The SPVP projects can be located near load, thus avoiding the

need to build new transmission facilities and help reduce local congestion. The

ability to deploy this technology quickly also can help advance California's

broad goal of developing renewable energy and specifically help make progress

tow ard the state's emphasis on developing distributed rooftop solar PV projects

while other options are being considered. Although we agree with the intent of

the SPVP, as discussed below, several modifications to the proposed SPVP are

necessary in order to allow more competition consistent with Commission

policies. The following sections address these issues.

4. Discussion of the Adopted Plan

4.1. Summary

In order to determine w hether to adopt the proposed program or a

modified proposal, we consider Commission policies applicable to this

application and the relevant statute.

12 Energy Action Plan I, p. 8

- 1 1 -

ExhibitNo. SCE-02/ Generation/ Vol. 10Witnesses: R. Perez, J. Rumble and A. Edeson


A.08-03-015 COM/JB2/ avs

incentives. Because of all these differences, the SPVP will not be counted

towards the CSI target.

Furthermore, to ensure there is no conflict between the CSI and the SPVP,

we adopt DRA's proposal and direct SCE to target project sites for the SPVP that

do not have sufficient on-site load to participate in the CSI program.

Solar Alliance supports this concept, but suggests we require a statement from

roof space owners acknowledging that they know and understand the benefits

offered through the CSI, but have chosen to lease their roof space for wholesale

power production instead.52 This requirement w ould provide clarity to the

process and may prevent future disputes. We find it appropriate and

incorporate it in the adopted SPVP.

We also decline to adopt Greenlining's proposal to require information on

supplier diversity and low-income enrollment as part of the adopted SPVP. The

Commission has separate processes for monitoring and examining utility

supplier diversity and also ensuring that the utilities comply w ith low-income

utility service requirements. The adopted SPVP is not the appropriate vehicle for

such review.

5. Cost Recovery

SCE expects to incur approximately $41.31 million (2008$) in O&M and

$875.0 million (2008$) in direct capital expenditures over the 2008 through

2014 program period, and requests that the Commission find reasonable up to

$962.5 million (2008$)in direct capital expenditures during the 2008 through

52 Solar Alliance comments at pp. 4-5.

-44 -

Exhibit No. SCE-02/ Generation/ Vol. 10Witnesses: R. Perez, J. Rumble and A. Edeson


A.08-03-015 COM /JB2/avs

2014 program period.53 SCE has also requested authority to establish the

Solar PV Program Balancing Account (SPVPBA) to record the difference

between: (1) the actual incremental O&M and capital-related revenue

requirement and; (2) the recorded Solar PV Program-related revenue. We find

these cost estimates reasonable.

DRA in comments to the PD recommends an annual review of SCE's plant

operation via a Tier 3 advice letter.54 DRA also suggests that SCE's lease costs

above $21,000/MW/Year (20% over SCE's estimate) and SCE's annual O&M

costs above $33,000/Year (20% over SCE's estimate) be disallowed.55 As

discussed below, we will review SCE's operation of SPVP (including SCE's

maintenance practices and performance of the facilities) in its ERRA proceeding,

and review all program costs (including O&M costs) in SCE's GRC. We direct

that SCE's lease costs and SCE's annual O&M costs be subject to reasonableness

review in SCE's GRC.

6. Scope and Timing of Reasonableness Review

6.1. Parties’ Positions

Greenlining argues that "the SPVP is a more costly and less certain means

of achieving progress toward the Million Solar Roofs goal, as compared to CSI,

and will not result in savings to Edison's ratepayers."56 Greenlining is concerned

that in contrast to the CSI, where the ratepayers only fund incentives given to

53 The $962.5 million includes a 10% adder.54 DRA Comments at p. 2.

55 Ibid.

56 Greenlining Opening Brief at p. 7.

- 4 5 -



A.08-03-015 COM/JB2/ avs

performance based on what it knew or should have known at the time.58 SCE

argues that if as part of this review, the Commission finds that the SPVP did not

operate in a prudent manner, the Commission could disallow recovery of the

replacement power costs (i.e., the replacement power costs w ould be borne by

SCE's shareholders rather than customers). SCE argues that no form of cost

sharing or additional incentives are necessary because the review process in

ERRA will create adequate incentives for prudent system performance.59

6.2. DiscussionSCE's claimed primary potential benefit of the SPVP is that this project

w ould provide additional MWs of renewable energy. However, several parties

contend that as proposed, there is no guarantee that any of the projected power

will be actually delivered. Parties are therefore concerned that the ratepayers

will be paying for an investment that may never produce the expected benefits,

and they encourage us to consider some protection in case the expected benefits

from the investments paid by ratepayers are never realized.

As a general matter, the Commission has an ongoing duty to ensure that

utility investments result in infrastructure that is used and useful. In the context

of utility owned generation, we have long-standing policies and procedures in

place under which utility projects are reviewed to make sure that approved

investments are being made in a reasonable m anner and that the resulting

facilities actually fulfill their stated purpose. As SCE points out, in the context of

utility generation projects, this review is done in the utilities' annual Energy

58 SCE Opening Brief at p. 29.

59 SCE Opening Brief at p. 29.

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A.08-03-015 COM/JB2/ avs

Resources Recovery Account proceedings. We see no compelling reason why in

the context of the SPVP we should stray from this existing process. While the

program is itself new there is nothing about the UOG portion of the program,

nor anything parties have presented, to suggest that the ERRA proceeding and

the after the fact reasonableness review of operations conducted therein is

insufficient to protect ratepayer interests. As SCE notes, should the Commission

find in the ERRA proceeding that SCE did not live up to its responsibilities or did

not prudently maintain and operate the solar facilities built pursuant to this

program, the Commission can disallow recovery of certain costs.

We decline to adopt TURN'S framework for sharing cost overruns between

ratepayers and shareholders in the event that installation costs exceed $3.85 a

watt. Reasonableness of capital costs, O&M costs and other UOG expenses are

typically addressed in a utility's GRC. We see no reason why review of SPVP

costs should be different than for other utility owned resources. However, as

discussed above, we will use the ERRA proceeding to review SCE's operation of

the SPVP plant.

In addition, to help the Commission better understand the impacts of this

program, and the comparative costs and benefits of UOG and IPP solar PV

generation, the Commission will monitor this program on an ongoing basis. As

part of this review, we will examine, among other measures, the result of the

competitive solicitation and the number of market participants competing for

access to the one to two MW market. We will also monitor the prices received

under the PPA portion of the program as well as the costs SCE incurs under the

UOG portion of the program. This will provide for a broader comparison

between utility owned renewable generation and generation projects that result

from the competitive solicitation. Because SCE's GRC occurs only every

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A.08-03-015 COM/JB2/ avs

three years, in order for the Commission to have timely data to evaluate this

program and consistent with the requirements of Pub. Util. Code § 2775.5, SCE

shall file an annual compliance report in this proceeding. SCE shall consult with

Energy Division to develop the format and content of the report. The

information provided in these reports shall be reviewed by Energy Division and

shall be reflected in the Commission's reports to the legislature on the RPS

program.

The first report shall be filed on July 1, 2010. The report shall include, at a

minimum, the following:

• All solicitations issued for PPA contracts;

• A description of all bids received from the PPA solicitations, including name of bidder, location of bid, bid price, and description of proposed facility (generating capacity, type of technology, host customer, host tenant, and on-site load). SCE should indicate the winning bids;

• The total electrical output for all SPVP systems under PPS contract that are currently selling electricity to SCE, for each m onth of the previous year.

• A calculation of the LCOE for each SCE-owned facility that is completed and interconnected to the grid. SCE should accompany this calculation w ith workpapers showing actual amounts for all cost and electrical output entries that are used to calculate LCOE;

• Electrical output by m onth for the previous year for each SCE-owned facility that is completed and interconnected to the grid; and

• A description of all facilities for which work has been initiated or completed in the previous year, including: capital and O&M expenses; generating capacity; description of the site (host customer, host tenant, lease cost and on-site load); progress toward completion.

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A.08-03-015 COM/JB2/ avs

Resolution E-4182 authorized SCE to establish a m em orandum account to

record the incremental O&M and capital-related revenue requirement associated

w ith the first $25 million of direct capital expenditures in the SPVP (SPVPMA).

Ordering Paragraph 4 states that the Commission will address rate recovery of

the amounts recorded in the SPVPMA when it acts on SCE's SPVP application.

SCE shall transfer the balance in the SPVPMA to the SPVPBA for future rate

recovery after the Commission reviews the balance in the ERRA proceeding.

7. Rate of Return Issues

7.1. Parties’ Position

SCE requests that its investment earn 100 basis points above its authorized

ROR. SCE claims that D.06-05-039 allows the Commission to authorize this

increase for utility-owned renewable generation.60 SCE first m ade its request as

follows:

"As authorized in D.06-05-039, SCE calculated the rate of return on rate base using SCE's current authorized rate of return of 8.75%, plus 1%, since this new plant will be utility-owned renewable generation."61

SCE later in its rebuttal testimony noted that its proposal meets the

requirements of § 454.3(c), because it will develop a segment of the market that

currently lacks production.62

DRA and TURN oppose SCE's request on the basis that it does not meet

any one of the requirements of § 454.3, although TURN in its opening brief notes

that the minimum 50 basis points could be justified, albeit "under the most

60 Exhibit SCE-1 at p. 55.

61 Id at p. 54.

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A.08-03-015 COM /JB2/avs

7. The energy generated from the SPVP projects should be counted toward

SCE's RPS goal.

8. The UOG portion of the SPVP should be subject to cost of service

regulation.

9. Review of all SPVP costs should be conducted in SCE's GRC proceeding

and review of SPVP performance and SCE's operation of the facilities should be

conducted in SCE's annual ERRA proceeding.

10. Costs above $3.85/W should be subject to a reasonableness review.

11. SCE should be authorized to establish a balancing account to record the

difference between the SPVP's actual and recorded expenses and revenues.

12. The Commission should monitor the SPVP on an ongoing basis to assess

the progress and impacts of the program on the wholesale distributed solar

energy market. A full review of the SPVP should occur in SCE's GRC

proceeding.

13. The adopted SPVP does not meet the criteria of Pub. Util. Code § 454.3 for

an increase of 100 basis points.

14. Within 30 days of the effective date of this decision, SCE should file an

advice letter w ith the Energy Division delineating the criteria for selection of the

bids, and containing a draft standard 20-year PPA contract for use in the RFO.

15. SCE should file an annual compliance report as described in Section 6.2 of

this decision. The first report should be due on July 1, 2010, and subsequent

reports filed on July 1 every year thereafter. The filing of the compliance report

does not re-open the proceeding.

16. A.08-03-015 should be closed.

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A.08-03-015 COM/JB2/ avs

O R D E R

IT IS ORDERED that:

1. Southern California Edison Company's solar photovoltaic program is

modified as follows:

• 250 megawatt of utility-owned distributed generation (about 50 megawatt annually). Southern California Edison Company to own, install, operate and maintain distributed solar photovoltaic projects primarily in the one to two megawatts, located in Southern California Edison Company's service territory on existing commercial rooftops. Projects cost target at $3.50/Watt w ith a 10% contingency.

• 250 megawatt of distributed generation owned by independent power producers (about 50 megawatt annually) to be solicited at least once per year. Bids capped at Southern California Edison Company's estimated levelized costs of electricity. An Independent Evaluator should be secured to oversee the solicitation for the first two years of the program and thereafter if a utility affiliate participates in that process. Contracts will be based on standard 20-year power purchase agreement contracts.

• A five-year program.

• Cost of service treatment for utility-owned generation portion of the program.

• No increase in authorized rate of return.

• Costs in excess of $3.85 per watt subject to a reasonableness review.

2. Within 30 days of the effective date of this decision, Southern California

Edison Company shall file an Advice Letter w ith the Energy Division delineating

the criteria and process for evaluating offers received and containing a draft

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A.08-03-015 COM/JB2/ avs

standard 20-year power purchase agreement contract for use in the request for

offer.

3. Southern California Edison Company shall transfer the balance in the

Solar Photovoltaic Program M emorandum Account to the Solar Photovoltaic

Program Balancing Account for future rate recovery after Commission's review

of the balance in the energy resource recovery account reasonableness

proceeding.

4. Southern California Edison Company shall file an annual compliance

report in this proceeding as described in Section 6.2 of this decision. The first

report shall be filed on July 1, 2010, and subsequent reports filed on July 1

thereafter. The filing of the compliance report does not re-open the proceeding.

5. Application 08-03-015 is closed.

This order is effective today.

Dated June 18,2009, at San Francisco, California.

MICHAEL R. PEEVEY President

DIAN M. GRUENEICH JOHN A. BOHN RACHELLE B. CHONG TIMOTHY ALAN SIMON

Commissioners

I reserve the right to file a concurrence.

/ s / Dian M. Grueneich Commissioner

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106aWorkpaper - Southern California Edison / 2015 GRC - APPLICATION

Att D R A Verbal 008 G01 Page 1

BEFORE THE PUBLIC UTILITIES COMMISSION OF THE F I L E DSTATE OF CALIFORNIA 03-27-08

08:49 AM

Application of Southern California Edison Company (U 338-E) for Authority to Implement and Recover in Rates the Cost of its Proposed Solar Photovoltaic (PV) Program.

A

A0803015

APPLICATION OF SOUTHERN CALIFORNIA EDISON COMPANY (U 338-E) FOR AUTHORITY TO IMPLEMENT AND RECOVER IN RATES THE COST OF ITS

PROPOSED SOLAR PHOTOVOLTAIC (PV) PROGRAM

DOUGLAS K. PORTER CAROL A. SCHMID-FRAZEE ANNETTE GILLIAM

Attorneys forSOUTHERN CALIFORNIA EDISON COMPANY

2244 Walnut Grove Avenue Post Office Box 800 Rosemead, California 91770 Telephone: (626) 302-1337Facsimile: (626) [email protected]


Dated: March 27, 2008

mailto:[email protected]

Workpaper - Southern California Edison / 2015 GRC - APPLICATION106b


BEFORE THE PUBLIC UTILITIES COMMISSION OF THE

STATE OF CALIFORNIA


A.08-03-

APPLICATION OF SOUTHERN CALIFORNIA EDISON COMPANY (U 338-E) FOR AUTHORITY TO IMPLEMENT AND RECOVER IN RATES THE COST OF

ITS PROPOSED SOLAR PHOTOVOLTAIC (PV) PROGRAM

I.

SUMMARY OF REQUEST

Pursuant to Rule 3.2 of the California Public Utilities Commission (Commission or

CPUC) Rules of Practice and Procedure, Southern California Edison Company (SCE) hereby

submits this application requesting the Commission to:

(1) Find it reasonable for SCE to implement a Solar Photovoltaic (PV) Program that

would consist of up to 250 megawatts (MW)l of utility-owned solar PV

generating facilities of approximately 1 to 2 MW2 each over the next five years;

(2) Establish ratemaking for SCE’s Solar PV Program, specifically including:

1 U n less o therw ise specified , any reference to energy ou tpu t in th is filing fo llow s the com m on convention w ithin the P V industry , w hich is to refe r to ou tpu t as P V panel d irec t curren t (dc) output. A dditionally , SCE proposes using installed dc ou tpu t in reasonab leness rev iew s because installa tion occurs in dc panels. T he conversion facto r o f 0.90 w ill be used to convert from M W dc to M W alternating curren t (ac) based on sam ple calculations using the C a lifo rn ia E nergy C om m ission ’s ac M W to conversion (i.e., m ultip ly M W dc by 0.90 to obtain M W C E C -ac Rating).

2 SCE envisions the ind iv idual Solar P V Program installa tions to be in the 1 to 2 M W range. A s the programproceeds, how ever, som e installa tions m ay be larger o r sm aller than th is range due to ro o f size o r c ircu it loadingconsiderations.

1


106cWorkpaper - Southern California Edison / 2015 GRC - APPLICATION


Table III-1Solar P V Program Estimated Base Case Capital Costs

(2008$ 000)

YearCapital

(Million $)MW

Installed Estimated Time Frame

0 $25 5 2008

1 $174 50 2009

2 $174 50 2010

3 $174 50 2011

4 $174 50 2012

5 $154 45 2013

Total $875 250

The Solar PV Program base case direct capital cost forecast is $875 million. The

average cost of the solar PV facilities should be about $3.50/W.12 At present, the average cost of

solar PV facilities above 900 kilowatts (kW) range from $6.56-7.08/W. SCE anticipates

achieving lower costs than the present average through economies of scale and improvements in

technology and efficiency.

b) O&M Costs

As noted previously, O&M costs consist of three components: (1) roof lease

payments; (2) other O&M costs; and (3) SCE staffing costs. With regard to the roof lease

payments, this is a new opportunity for the large rooftop owners. So, it is difficult to estimate

expected leasing rates. However, SCE anticipates that the maximum price paid for these roof

12 O n average, the reasonab leness th resho ld is 10% h igher than the base case estim ate o r about $3 .85/W . The reasonab leness th resho ld is h igher than th is am oun t in early years o f the Solar P V P rogram and low er in lateryears, as show n in T able IV -2 below .

13


Workpaper - Southern California Edison / 2015 GRC - APPLICATION106d


BEFORE THE PUBLIC UTILITIES COMMISSION OF THE F I L E DSTATE OF CALIFORNIA 02-11-11

04:59 PM

Application of Southern California Edison )Company (U 338-E) for Authority to Implement )and Recover in Rates the Cost of its Proposed )Solar Photovoltaic (PV) Program _ )

Application 08-03-015

SOUTHERN CALIFORNIA EDISON COMPANY’S (U 338-E) PETITION FOR MODIFICATION OF DECISION 09-06-049

PUBLIC VERSION

DOUGLAS K. PORTER ANGELICA M. MORALES


2244 Walnut Grove Avenue Post Office Box 800 Rosemead, California 91770 Telephone: 626-302-6160Facsimile: 626-302-6962E-mail:[email protected]


Dated: February 11, 2011

1772791


106eWorkpaper - Southern California Edison / 2015 GRC - APPLICATION


for utility-owned generation (“UOG”) and 250 MW of the Solar PV Program was to be owned, installed,

operated, and maintained by Independent Power Producers (“IPPs”).3

SCE is the nation’s leader in purchasing renewable energy on behalf of its customers. In fact, in

2009, SCE purchased roughly 80% of all solar power generated in the United States. From this experience,

SCE has witnessed firsthand the benefits that can accrue to customers because of greater competition.

Therefore, in order to permit greater competition among bidders and thus reduce the overall Solar PV

Program costs for SCE’s customers, the instant Petition requests that the Commission restructure SCE’s

existing 500 MW Solar PV Program in two ways:

1.) Reassign 250 MW to a separate competitive solicitation within the Solar PV Program that will

not be subject to the current parameters of the IPP portion (“IPP Revised”);4 and,

2.) Reduce the current UOG and original IPP portions of the Program respectively to an amount of

no more than 125 MW each.

Thus, if the Commission adopts this Petition, the 500 MW5 Program will be designated as follows:

1) no more than 125 MW as UOG;6 2) 125 MW for IPPs under the original solicitation process;7 and, 3)

250 MW for an IPP Revised solicitation.

Based on the success of the existing Solar PV Program and other procurement mechanisms, SCE

believes that the revisions proposed in this Petition will significantly reduce the costs of the Solar PV

Program going forward. The Commission has recognized that SCE’s Solar PV Program and its other

procurement efforts “suggest[] that the market for smaller scale projects appears robust with a significant

number of competing sellers.”8 Indeed, in a recent solicitation, outside of the Solar PV Program, SCE

3 D.09-06-049, Ordering Paragraph No. 1, p. 58.4 Among other things, SCE specifically recommends that the Commission designate the IPP Revised portion of the Solar PV

Program for distributed solar PV of up to 20 MW, without any limitation on ground-mounted installations.5 500 MW is an approximate number of projects installed. Final installed MW will depend on the engineering design

specifications of projects.6 SCE proposes that the Commission reduce the UOG portion of the Solar PV Program to “no more than” 125 MWs in order to

accommodate SCE’s existing obligations. The final UOG build out will depend on project specific engineering design specifications, but will be no more than 125 MW.

7 See D.09-06-049 and Resolution E-4299.8 D.10-12-048, p. 17 (decision adopting a Commission-approved procurement process for large investor-owned utilities- the

Renewable Auction Mechanism (“RAM”)).

2


Workpaper - Southern California Edison / 2015 GRC - APPLICATION106f


procured 259 MW(ac), most of which was solar PV,9 at more competitive prices than received for bids in

the Solar PV Program.10 Current renewable energy trends have shown a significant market response for

solar PV systems. SCE’s entrance into the solar PV market through implementation of the Program has

encouraged development of solar generated electric power by, among other things, increasing the options

available for installing and operating commercial solar PV. Therefore, due to recent developments in the

solar market, including the results achieved through the Solar PV Program, the Commission should modify

D.09-06-049 as recommended in this Petition.

The Solar PV Program objectives remain achievable in a reduced-size UOG Program or have

already been satisfied. Indeed, SCE’s knowledge transfer related to PV technology is well underway and

has already resulted in positive industry changes.11 Moreover, solar power procured in the revised Program

would be consistent with the State’s goal of aggressively expanding the renewable industry in an

economically efficient manner. SCE believes it is in its customers’ best interests to revise the process

whereby it procures solar PV generation through its existing Solar PV Program. SCE’s current estimate

shows that revising the Solar PV Program as recommended in this Petition could result in a Present Value of

Revenue Requirements (PVRR) savings of approximately $300 million to all of SCE’s customers (as

compared to the cost of continuing the existing Program). This result is based on the assumption of

continued market availability at current price indications.12 Given that the Commission’s objectives have

been or appear likely to be met at reduced overall cost through the revised Program, modifying the Decision

is reasonable, justified, and in the public interest.13 Accordingly, the Commission should grant the Petition

and approve the modified Program as set forth in this Petition.

9 Subsequent to executing contracts from this solicitation, one contract has since terminated. The remaining 20 contracts are for 239 MW(ac) all from solar PV projects.

10 SCE procured these MW through its voluntary Renewable Standard Contract (“RSC”) Program solicitation. SCE is nolonger authorized to utilize its RSC Program for procurement of projects up to 20 MW in size. See D.10-12-048, Conclusionof Law No. 5, pp. 86-87 (“The IOUs should be required to use RAM exclusively for the procurement of system-side renewable projects up to 20 MW in size with the exception o f other Commission-approved programs such as the utility solar photovoltaic programs already authorized by the Commission and annual RPS solicitations; IOUs should not use voluntary programs that target the same market segment or bilateral negotiations.”) (Emphasis added.)

11 See Declaration of M. Nelson, ^ 3-14, attached as Appendix B.12 See Declaration of B. Hodges at ^ 6, attached as Appendix C.13 See D.10-10-029, p. 19 and Appendix A to D.10-10-029, p. 1 (granting SCE’s Petition for Modification of a power purchase

agreement (“PPA”) approved in D.08-09-041 on the basis that the requested changes were “reasonable, justified and in theContinued on the next page

3


106gWorkpaper - Southern California Edison / 2015 GRC - APPLICATION


BEFORE THE PUBLIC UTILITIES COMMISSION OF T ffll L E D07-27-12

STATE OF CALIFORNIA 04:59 PM


Application 08-03-015

(Filed March 27, 2008)

SOUTHERN CALIFORNIA EDISON COMPANY’S (U 338-E) PETITION FOR MODIFICATION OF DECISION NO. 12-02-035

DOUGLAS K. PORTER GLORIA M. ING


2244 Walnut Grove Avenue Post Office Box 800 Rosemead, California 91770 Telephone: (626) 302-1999Facsimile: (626) 302-3990E-mail:[email protected]

Dated: July 27, 2012

LIM S-310-1452



Workpaper - Southern California Edison / 2015 GRC - APPLICATION106h



STATE OF CALIFORNIA

Application of Southern California Edison )Company (U 338-E) for Authority to Implement ) Application 08-03-015and Recover in Rates the Cost of its Proposed )Solar Photovoltaic (PV) Program. ) (Filed March 27, 2°°9)

SOUTHERN CALIFORNIA EDISON COMPANY’S (U 338-E)PETITION FOR MODIFICATION OF DECISION NO. 12-02-035

I.

INTRODUCTION

Pursuant to Rule 16.4 of the California Public Utilities Commissions’ (“CPUC” or

“Commission”) Rules of Practice and Procedure and the direction in the June 13, 2012 letter from the

CPUC’s Energy Division denying SCE’s Advice Letter 2724-El Southern California Edison Company

(“SCE”) submits this Petition for Modification of Decision No. 12-02-035.

A. SCE’s Request in this Petition for Modification

In this Petition, SCE requests modification to Decision No. 12-02-035:

(1) SCE requests that the Commission permit SCE to reduce the utility-owned generation

(“UOG”) portion of the Solar Photovoltaic Program (“SPVP”) from 125 MW to 91 MW,2

which is based on SCE’s current UOG commitments of approximately 7 MW of Solar

Photovoltaic (“SPV”) ground-mount projects that have been energized and 84 MW of SPV

rooftop projects that have been energized, are in construction, or are expected to be built.

1 A copy o f the June 13, 2012 letter is attached as A ttachm en t A.2 A pprox im ate ly 72 M W o f the 91 M W are from SPV pro jects th a t have energized . T he balance o f 19 M W relate to SPV

pro jects th a t are e ither in construction o r are expected to be built. T he actual M W in S C E ’s U O G portion o f the SPVP m ay thus vary sligh tly w hen the 19 M W o f pro jects energize due to final design constraints.

1


106iWorkpaper - Southern California Edison / 2015 GRC - APPLICATION


(2) SCE also proposes that the megawatts it does not procure through the UOG portion of the

SPVP be added to SCE’s megawatt requirement in the Renewable Auction Mechanism

(“RAM”) program, such that the 34 DC MW from the SPVP be reassigned to RAM (which

would be the equivalent of 31 AC MW in RAM), similar to the CPUC’s reassignment in

Decision No. 12-02-035.3

(3) As discussed in Section I.B, SCE requests that the Commission under Rule 16.4(h) issue an

immediate order staying SCE’s obligations under Decision No. 12-02-035 to develop a 125

MW UOG SPVP, pending disposition of this Petition for Modification. SCE also requests

that the Commission expedite its decision on this Petition for Modification.

The Commission in Decision No. 12-02-035 has already permitted the reduction of the UOG SPVP to

reflect SCE’s February 2011 SPVP commitments. As of July 2012, SCE’s commitments have again

changed, which has prompted the need for relief from the Commission through this Petition.

Fundamentally, SCE submits that the UOG portion of the SPVP has been successful with

approximately 84 MW of solar rooftops already energized, under construction, or expected to be built, in

addition to approximately 7 MW of ground mount SPV facilities that have been energized. When SCE

proposed the SPVP in 2008, the SPV market was much smaller in California than it is today and was not

competitive with other renewable generating sources such as wind and geothermal sources. Since 2008,

the market has transformed and SPV is now a competitive technology, with SCE having over 2000 MW

of SPV contracts executed.

Further, continuing circumstances have made it difficult and less economical to build SPV

projects through the UOG portion of the SPVP when SCE could buy renewable energy, generated from

SPV technology, at a lower cost through other programs. Since the inception of the SPVP, SCE has

been receiving competitive offers of SPV bids primarily through the Renewable Standard Contract

(“RSC”) program and the RAM, which are preferable alternatives to the UOG portion of the SPVP. As

3 D ecision N o. 12-02-035, m im eo pp. 22-24. In accordance w ith foo tno te 23 o f D ecision N o. 12-02-035, SCE has used a 0.9 conversion facto r to convert the D C M W from the U O G portion o f the SPV P to A C M W in the RAM .

2


Workpaper - Southern California Edison / 2015 GRC - APPLICATION106j


A.10-11-015 A L J/M D 2/lil/gd2/jt2

extent consistent w ith the foregoing discussion, findings of fact, and conclusions

of law.

6. Southern California Edison Company shall continue the Authorized Base

Revenue Requirement Balancing Account.

7. Because the Commission and the public should be able to track the

progress of previously authorized large capital projects from one general rate

case to the next, for Generation and Transmission and Distribution Business Unit

capital expenditures in excess of $1 million, Southern California Edison

Company shall submit with its direct testimony in its next general rate case,

tables which provide historical and forecast California Public Utilities

Commission jurisdictional amounts by sub-categories, as follows:

(1) The table for each business unit shall provide five years (2008-2012) of recorded costs, 2012 authorized capital spending, and Southern California Edison Company's 2013, 2014, and 2015 capital requests by organization within these business units.

(2) For the Generation table, the data shall be presented by generation source categories; for the Transmission and Distribution table, the data should be presented by organization (e.g.,Infrastructure Replacement, Capital Maintenance, etc.).

8. W ith Southern California Edison Company's (SCE) next general rate case

application, SCE shall provide an explanation of the workload analysis used to

develop estimated labor increases.

9. W ith Southern California Edison Company's (SCE) next general rate case

application, SCE shall provide a summary of San Onofre Nuclear Generating

Station-Safety Culture programs, achievements, and three years of recorded

expenses.

10. Southern California Edison Company (SCE) shall establish a San Onofre

Nuclear Generating Station M emorandum Account (SONGSMA), effective

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D .12-02-035

Witness: Rudy Perez



ALJ/ MEB/ avs Date of Issuance 2/23/2012

Decision 12-02-035 February 16, 2012


Application of Southern California EdisonCompany (U338E) for Authority to Implement Application 08-03-015and Recover in Rates the Cost of its Proposed (Filed March 27,2008)Solar Photovoltaic (PV) Program.

DECISION PARTIALLY GRANTING SOUTHERN CALIFORNIA EDISON COMPANY’S PETITION FOR MODIFICATION OF

DECISION 09-06-049 (SPVP) AND MAKING CONFORMING CHANGES TO DECISION 10-12-048 (RAM)

575888 - 1 -



A.08-03-015 ALJ/MEB/avs

4. Conclusion

We approve the petition to the extent provided herein, and deny it in

every other respect. Specifically, we modify D.09-06-049 and D.10-12-048 to

accomplish the following:

1. Reduce the 250 MW UOG portion to no more than125 MW, with the maximum amount of ground-mounted facilities increased from 10% to 20% (25 MW), but other parameters unchanged; require SCE to file an advice letter for authorization if UOG procurement will be less than 115 MW by the end of year five.

2. Reduce the 250 MW IPP portion to no more than 125 MW, w ith the maximum amount of ground-mounted facilities increased from 10% to 20% (25 MW), but other parameters unchanged; require SCE to file an advice letter for authorization if IPP procurement will be less than 115 MW by the end of year five.

3. Procure the remaining amount of SPVP through 225 MW of RAM, w ith an increase in SCE's total RAM allocation from 498.4 MW to 723.4 MW. (SCE has applied 144 MW procured via its 2010 RSC program to RAM, leaving a net initial RAM procurement of 354.4 MW, or net adjusted579.4 MW when increased by the 225 MW transferred here.) All other RAM parameters and protocols are unchanged (e.g., projects up to 20 MW; any eligible renewable technology; commercial operation within18 months from Commission approval of the PPA, subject to a one-time six m onth extension).

4. Reduce the reasonable cost estimates for 125 MW of UOG over the 2008 to 2014 program period to approximately $20,655 million (2008 dollars) in O&M expenses, and $481.25 million (2008 dollars) in direct capital expenditures ($427.5 million (2008 dollars) direct capital plus a10% contingency). These costs are based on $3.50 per W att ($3.85 per W att including contingency), w ith costs in excess of $3.85 per W att subject to a reasonableness review.If SCE develops less that 125 MW of UOG, the reasonable

- 2 7 -




total cost estimates are based on the number of Watts times $3.50 per Watt ($3.85 per Watt including contingency), w ith costs in excess of $3.85 per W att subject to a reasonableness review.

Because this decision only changes the SPVP and RAM programs going

forward, we do not need to change the language in D.09-06-049 or D.10-12-048.

Rather, to implement the changes adopted today, we only need to modify each

program effective today. We do that by adopting appendices attached to this

order that summarize each program, as modified.

Finally, we also direct SCE to file and serve a Tier 2 advice letter to specify

the amount of each product it will solicit in each remaining RAM auction for the

225 MW of capacity added to RAM via today's order, along w ith identifying the

resulting amount of each product in its new RAM total of 723.4 MW.

5. Comments on Proposed Decision

The proposed decision of the Administrative Law Judge (ALJ) in this

matter was mailed to the parties in accordance with Section 311 of the Public

Utilities Code and comments were allowed under Rule 14.3 of the Commission's

Rules of Practice and Procedure. Comments were filed on January 31,2012 by

eight parties (SCE, DRA, IEP, SEIA, Silverado Power, Clean Coalition, Basic

Crafts Alliance, and Southern California District Council of Laborers). Reply

comments were filed on February 6, 2012 by two parties (SCE, and the Coalition

of California Utility Employees). As required by our rules, comments must focus

on factual, legal, or technical errors and, in citing such errors, m ust make specific

references to the record. Comments which fail to do so, or which merely reargue

positions taken in the proceeding, are given no weight (Rule 14.3.) We similarly

give no weight to new facts first asserted in comments. Specific contract clauses

- 2 8 -




and labor issues are not within the scope of the petition for modification, and we

decline to address them here.27

We make limited changes based on comments. For example, we clarify

that the contract we expect parties to use for the additional 225 MW solicited via

RAM is the RAM contract in effect at the time of contracting (not the contract

used for the first RAM solicitation "frozen" over time even if changes to the

RAM contract are later m ade by the Commission). We clarify that the 20%

limitation on ground-mounted facilities in the remaining UOG and IPP portions

of SPVP is up to a total of 50 MW (25 MW each in the UOG and IPP portions).

We adjust the capacity transferred to RAM from the 250 MW cited in the

proposed decision to 225 MW here to reflect the conversion from DC to AC

output. We also more clearly state the MW for the remaining three RAM

auctions (see Attachment 2).

6. Assignment of Proceeding

Mark J. Ferron is the assigned Commissioner and Maryam Ebke is the

assigned ALJ in this proceeding.

Findings of Fact

1. Since SPVP was approved in 2009, solar PV costs have fallen, the economic

dow nturn has slowed development opportunities, and other programs have

been created or modified that provide support for the one to two MW market

segment, including rooftop solar PV facilities.

2. Modifications to SPVP are necessary to offer the best opportunity to secure

savings for ratepayers resulting from falling PV costs, and may be designed to

complement changes in other conditions and programs.

27 Specific SPVP contract issues are addressed in draft Resolution E-4453.

- 2 9 -




3. SPVP, as modified, neither cancels SPVP nor completely disrupts the

market.

4. SPVP, as modified, still targets 200 MW for rooftop solar PV in the one to

two MW size range.

5. The economic dow nturn has reduced the economic availability of rooftops.

6. SPVP, as modified, increases competitive pressure on rooftop owners and

rooftop PV plants to reduce costs to compete with ground-mounted PV and

other renewable facilities.

7. Reducing the UOG and IPP portions of SPVP (from 250 MW each to no

more than 125 MW each, but at least 115 MW each absent additional

authorization) provides the best opportunity to capture savings while continuing

to secure several advantages of SPVP, including the maintenance of large enough

UOG and IPP pieces to permit reasonable data collection.

8. The current trend of industry price reductions, and SCE's recent successes

in bringing down costs, support a directly proportional reduction in the costs

previously found reasonable by the Commission for the UOG portion of SPVP.

9. The Commission, upon its adoption of SPVP, considered and dismissed a

range of ratemaking proposals to address limiting costs, sharing costs, or setting

performance requirements, and nothing new on these matters is presented here.

10. Increasing the percentage from 10% (in the original SPVP) to 20% (in the

UOG and IPP portions of SPVP as modified) maintains the same allowance for

up to 50 MW ground-mounted facilities, thereby permitting SCE to

accommodate existing obligations.

11. Retaining SPVP, as modified, at 500 MW promotes a reasonable degree of

continuity and consistency w ith market expectations created by the original

SPVP.

- 3 0 -




2. Utility-Owned Generation

SCE is authorized to own, develop, install, maintain and operate up to 125 MW (but no less than 115 MW absent additional authorization) of solar PV projects in the one to two MW range, located in SCE's service area, primarily on rooftops, over a five year program (about 25 MW annually, although SCE is encouraged to accelerate the development if practical and not adverse to program costs).Project costs are subject to cost of service ratemaking treatment, and are capped at $3.50 per Watt w ith a 10% contingency. Costs in excess of $3.85 per Watt are subject to reasonableness review. No more than 20% (25 MW) may be ground- m ounted facilities, and the bulk of SPVP projects m ust be in range of one to two MW. SCE shall develop 125 MW, or as close to 125 MW as reasonable. SCE shall explain in periodic SPVP reports why it is not on target to achieve 125 MW of UOG if that is the case, and explain w hat steps it is taking to achieve 125 MW. SCE shall, no later than 180 days before the end of the five year SPVP program, file a Tier 2 advice letter for authorization if UOG procurement will be less than 115 MW by the end of year five.

3. Independent Power Producer

SCE is authorized to procure via competitive solicitation up to 125 MW (but no less than 115 MW absent additional authorization) of solar PV generation owned by independent power producers. The solicitations shall be at least once per year. The generation shall primarily be from rooftop solar PV projects in the one to two MW range, located in SCE's service area, over a five year program (about 25 MW annually, although SCE is encouraged to accelerate the procurement if practical and not adverse to program costs). Bids are capped at SCE's estimated levelized cost of electricity ($0.26 per kilowatthour). No more than 20% (25 MW) may be ground-mounted facilities, and the bulk of SPVP projects m ust be in range of one to two MW. SCE shall procure 125 MW, or as close to 125 MW as reasonable. SCE shall explain in periodic SPVP reports w hy it is not on target to achieve 125 MW of IPP if that is the case, and explain w hat steps it is taking to achieve 125 MW. SCE shall, no later than 180 days before the end of the five year SPVP program, file a Tier 2 advice letter for authorization if IPP procurement will be less than 115 MW by the end of year five.

- 2 -





D.13-05-033

Witness: Rudy Perez



COM/ MF1 / acr/ jt2 Date of Issuance 6/3/2013

Decision 13-05-033 May 23, 2013


Application of Southern California Edison Company (U338E) for Authority toImplement and Recover in Rates the Cost Application 08-03-015of its Proposed Solar Photovoltaic (PV) (Filed March 27, 2008)Program.

DECISION PARTIALLY GRANTING SOUTHERN CALIFORNIA EDISON COMPANY’S PETITION FOR MODIFICATION OF DECISION 12-02-035

(SOLAR PHOTOVOLTAIC PROGRAM)

1. Summary

This decision partially grants Southern California Edison Company's

(SCE) petition for modification of Decision (D.) 12-02-035 regarding the Solar

Photovoltaic Program (SPVP).

The SPVP, adopted in 2009 (D.09-06-049), is a 500 megawatt (MW) solar

photovoltaic generation program, w ith 250 MW utility-owned generation (UOG)

and 250 MW owned by independent power producers (IPP). As modified by

D.12-02-035, the total program remains at 500 MW, but w ith no more than

125 MW designated for utility ownership, no more than 125 MW designated for

IPP ownership, and 250 MW transferred to the Renewable Auction Mechanism

(RAM) program.

SCE now petitions to reduce the utility ownership portion from 125 MW to

91 MW, with the 34 MW differential transferred to the RAM program. We grant

the petition as to the reduction of the UOG portion of the SPVP and the

reallocation of the 34 MW to RAM. As modified, the UOG portion of the

66060035 - 1 -



A.08-03-015 C O M /M F l/acr/jt2

6. Conclusion

We approve the petition to the extent provided herein, and deny it in

every other respect. Specifically, we modify D.09-06-049, D.10-12-048 and

D.12-02-035 to accomplish the following:

1. Reduce the 125 MW UOG portion to no more than 91 MW, with the other parameters unchanged; require SCE to file a Tier 2 advice letter for authorization if UOG procurement will be less than 91 MW by the end of year five.

2. Procure the remaining amount of UOG SPVP through the 34 DC MW (31 MW AC) of RAM procurement, with an increase in SCE's total RAM allocation from 723.4 MW to754.4 MW. All other RAM parameters and protocols are unchanged.

3. Reduce the reasonable cost estimates for 91 MW of UOG over the 2008 to 2014 program period to approximately $15,036 million (2008 dollars) in O&M expenses, and $350.35 million (2008 dollars) in direct capital expenditures ($318.5 million (2008 dollars) direct capital plus a 10% contingency). These costs are based on $3.50 per watt ($3.85 per w att including contingency), with costs in excess of $3.85 per w att subject to a reasonableness review. If SCE develops less that 91 MW of UOG, the reasonable total cost estimates are based on the number of watts times $3.50 per w att ($3.85 per w att including contingency), w ith costs in excess of $3.85 per w att subject to a reasonableness review.

Because this decision only changes the SPVP and RAM programs going

forward, we do not need to change the language in D.09-06-049, D.10-12-048 and

D.12-02-035. Rather, to implement the changes adopted today, we only need to

modify each program effective today. We do that by adopting appendices

attached to this order that summarize each program, as modified.

- 1 6 -



A.08-03-015 C O M /M F l/acr/jt2

7. Comments on Alternate Proposed Decision

On April 23, 2013, the alternate proposed decision of Commissioner Florio

in this matter was mailed to the parties in accordance w ith Section 311 of the

Public Utilities Code and comments were allowed under Rule 14.3 of the

Commission's Rules of Practice and Procedure. On May 13, 2013, opening

comments on the alternate proposed decision were filed by DRA, SCE,

Independent Energy Producers and SEIA. Clean Coalition filed reply comments

on May 17, 2013. The length of Clean Coalition's reply comments were not in

compliance w ith Commission's Rules and therefore only a portion was

considered. On May 20, 2013, reply comments were filed. As required by our

rules, comments must focus on factual, legal, or technical errors and, in citing

such errors, must make specific references to the record. Comments which fail to

do so, or which merely reargue positions taken in the proceeding, are given no

weight (Rule 14.3.) We have reviewed the comments and determined that there

is a need to make one change to the alternate proposed decision. Clean Coalition

indicated that the RAM program no longer allows projects under 3 MW. The

alternate proposed decision has been changed to reflect this.

8. Assignment of ProceedingMark J. Ferron is the assigned Commissioner and Maryam Ebke is the

assigned Administrative Law Judge in this proceeding.

Findings of Fact1. Since the SPVP was approved in 2009, Solar PV costs have fallen and other

programs have been created or modified that provide support for the one to

two MW market segment, including rooftop Solar PV facilities.

- 1 7 -



A.08-03-015 C O M /M F l/acr/jt2

2. Modifications to SPVP are necessary to offer the best opportunity to secure

savings for ratepayers resulting from falling PV costs, and may be designed to

complement changes in other conditions and programs.

3. SPVP, as modified, neither cancels the SPVP nor completely disrupts the

market.

4. SPVP, as modified, still targets a minimum of 173 MW for rooftop Solar PV

in the one to two MW size range.

5. SPVP, as modified, increases competitive pressure on rooftop owners and

rooftop PV developers to reduce costs to compete w ith ground-m ounted PV and

other renewable facilities.

6. The current trend of industry price reductions, and SCE's recent successes

in bringing down costs, supports a directly proportional reduction in the costs

previously found reasonable by the Commission for the UOG portion of SPVP.

7. Consolidating 34 MW DC (equal to 31 MW AC) of SPVP w ith RAM will

reduce developer confusion and enhance administrative efficiency.

8. Using RAM protocols promotes simplicity, efficiency and continuity.

9. Nothing presented here justifies reconsidering recently adopted

solicitation parameters, or consideration of other solicitation parameters in a new

advice letter.

Conclusions of Law

1. Petitioner reasonably justifies why the petition was not filed within

12 months of the effective date of the decision proposed to be modified.

2. The Commission should reasonably, responsibly, and appropriately

respond to market and industry changes, including changes that permit SPVP

modifications to enhance downward pressure on costs and prices for all

renewable projects across a range of sizes and technologies, and should take

- 1 8 -





Recorded Cost Reasonableness

Witness: Rudy Perez



SPVP Recorded Cost Reasonableness 2008-2012 Capital $

2008 - 2012 SPVP Capital Cost:

2008 2009 2010 2011 2012 Total

Nom inal $ $11,162,901 $9,315,688 $121,525,252 $161,523,768 $32,196,409 $335,724,018M W Com pleted 2.45 1.26 27.04 41.19 12.77 84.71Nom inal $ Per

W att $3.96

2008 2009 2010 2011 2012 Total

Cap is $3.85

2 008$ $11,162,901 $9,233,445 $118,857,219 $154,679,215 $30,299,695 $324,232,475MW Com pleted 2.45 1.26 27.04 41.19 12.77 84.712008 $ Per W att $4.56 $7.33 $4.39 $3.76 $2.37 $3.83

Year 0 Year 1 Year 2 Year 3$20,396,346

3.715.50



S P V P Recorded Cost Reasonableness

2008 -2012 O & M $

YearO &M recorded ($) - Exclude

LeaseOperating Lease Recorded ($) Non-Operating Lease TOTAL O&M

2008 $450,712 $0 $450,7122009 $1,452,857 $126,311 $1,579,1682010 $1,822,317 $122,472 $1,944,7892011 $14,385,463 $681,745 $55,161 $15,122,3692012 $4,712,263 $1,877,386 $250,000 $6,839,649Grand Total $22,823,611 $2,807,915 $305,161 $25,936,687



SPVP Recorded Cost Reasonableness Escalation

Used in order to change nom inal dollars to 2008 dollars.

Note: JPGDP Escalation Factor

2008 2009 2010 2011 2012 2013 2014 2015

1.000 1.009 1 .022 1.044 1.063 1.077 1 .096 1.113

2008 1.00000 1.00891 1.02245 1.04425 1.06260 1.07680 1.09603

2009 0 .99117 1.00000 1.01342 1.03503 1.05322 1.06730 1.08635

2010 0 .97805 0 .98676 1.00000 1.02132 1.03927 1.05316 1.07196

2011 0 .95763 0 .96615 0.97912 1.00000 1.01757 1.03117 1.04958

2012 0 .94109 0.94947 0.96221 0 .98273 1.00000 1.01337 1.03146

2013 0 .92868 0 .93695 0.94952 0.96977 0.98681 1.00000 1.01785

2014 0 .91239 0.92051 0.93287 0 .95276 0 .96950 0 .98246 1.00000



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S P V P Recorded Cost Reasonableness

M W by Site and by Year

M W Comoletion Bv Site

SPVP Number Site Status 2008 2009 2010 2011 2012 Total001 SG 1 Complete 2.45 2.45002 SG 7 Peaker and Solar Division 1.26 1.26003 SG 7 Peaker and Solar Division 1.2621 1.2621005 SG 7 Peaker and Solar Division 3.3962 3.3962006 SG 7 Peaker and Solar Division 2.5502 2.5502007 SG 7 Peaker and Solar Division 3.1978 3.1978008 SG 7 Peaker and Solar Division 2.8465 2.8465009 SG 7 Peaker and Solar Division 1.4104 1.4104010 SG 1 Complete 2.2508 2.2508O il SG 7 Peaker and Solar Division 5.0176 5.0176012 SG 7 Peaker and Solar Division 0.7728 0.7728013 SG 7 Peaker and Solar Division 4.928 4.928015 SG 1 Complete 2.25 2.25016 SG 7 Peaker and Solar Division 1.7488 1.7488017 SG 1 Complete 4.4979 4.4979018 SG 1 Complete 1.9417 1.9417022 SG 7 Peaker and Solar Division 3.0912 3.0912023 SG 1 Complete 3.864 3.864026 SG 7 Peaker and Solar Division 8.6016 8.6016027 SG 4 Complete 2.62 2.62028 SG 1 Complete 4.8563 4.8563032 SG 1 Complete 1.7066 1.7066033 SG 1 Complete 1.2719 1.2719042 SG 1 Complete 6.7684 6.7684044 SG 1 Complete 10.15 10.15048 SG 2 In-Construction 6.77

TOTAL 2.45 1.26 27.04 41.19 12.77 91.48




Fuel Cell Program


Witness: Jonathan Rumble





A ctiv ity: 549 -FUEL CELL

Witness: Jonathan L. Rumble

Forecast Method

Chosen

2012$ (000)

Recorded

2012

Forecast

2015

Labor Itemized Forecast 5 113

Non-Labor Itemized Forecast 1 556

O ther N/A 0 0

Total 6 669


The Fuel Cell Program w as approved in D .10-04-028 to install utility owned fuel cells on the University of California and

California State University campuses.

Final Cost Centers included in this activity (S ee Appendix A for additional detail):

F528939




A ctiv ity : 549 - FUEL CELL


DETER M INA TIO N O F R E C O R D ED /A D JU STED

I Recorded Period$ (000)

2008 2009 2010 2011 2012

FERC Form 1 Recorded (Nom inal $)Labor 0 0 0 0 0

Non-Labor 0 0 0 0 0

O ther 0 0 0 0 0

Total 0 0 0 0 0

A d justm ents- (N om inal $) - see Appendix B fo r additional detail

Labor 0 0 0 0 5

Non-Labor 0 0 0 0 1

O ther 0 0 0 0 0

Total 0 0 0 0 6

R ecorded/A djusted (Nom inal $)

Labor 0 0 0 0 5

Non-Labor 0 0 0 0 1

O ther 0 0 0 0 0

Total 0 0 0 0 6

E sca la tio n :

Labor 1.1414 1.1070 1.0701 1.0327 1.0000

Non-Labor 1.0881 1.0814 1.0642 1.0254 1.0000

O ther 1.0000 1.0000 1.0000 1.0000 1.0000

Recorded/A d justed (C onstan t 2012S)

Labor 0 0 0 0 5

Non-Labor 0 0 0 0 1

Other 0___________ 0___________ 0___________ 0__________ ^Total 0 0 0 0 6


6 -----------------------------------------------------------------------5 -------------------------------------------------------------------------------------------------

4 -------------------------------------------------------------------------------------------------

3 -------------------------------------------------------------------------------------------------

2 -----------------------------------------------------------------------

1 ------------------------------------------------------------

0 , , ---------2008 2009 2010 2011 2012





Activity: 549 - FUEL CELL


Forecasting Methods - Summary of Results of all Methods Studied - 2012$ (000)


COoCM 2014 | 2015 | sd** | ChosenLabor 3 3 3 3 noNon-Labor 1 1 1 1 noOther 0 0 0 0 noTotal 4 4 4 n/a n/a

3 Recorded Years (2010 -2012):Results of Linear Trending (T3) Results of Averaging (A3)


2013 2014 2015 r2 * Chosen1220

0.75 no0.75 no0.00 no

14 n/a n/a

2013 2014 2015 sd* Chosenno

n/a n/a



COoCM 2014 | 2015 | r2* I Chosen 2013 | 2014 | 2015 | sd** | Chosen5 7 8 0.60 no 1 1 1 2 no1 1 2 0.60 no 0 0 0 0 no0 0 0 0.00 no 0 0 0 0 no6 8 10 n/a n/a 1 1 1 n/a n/a


2013 I 2014 | 2015 | r2* I Chosen

COoCM r̂oCM 2015 | sd** | ChosenLabor 4 5 6 0.50 no 1 1 1 2 noNon-Labor 1 1 1 0.50 no 0 0 0 0 noOther 0 0 0 0.00 no 0 0 0 0 noTotal 5 6 7 n/a n/a 1 1 1 n/a n/a

Other Methods:


COoCM 2014 | 2015 | | Chosen 2013 | 2014 | 2015 | | Chosen_abor 5 5 5 no 113 113 113 yesSion-Labor 1 1 1 no 267 518 556 yesOther 0 0 0 no 0 0 0 no

Total 6 6 6 n/a 380 631 669 n/a

Forecast Adjustments:Base Forecast Method Adjustments***

Method 2013 | 2014 | 2015 | 2013 | 2014 | 2015 | |Labor IF 113 113 113 0 0 0Non-Labor IF 267 518 556 0 0 0Other N/A 0 0 0 0 0 0

Total 380 631 669 0 0 0

* r2 = R Squared (Based on recorded years data)** sd = standard deviation (Based on recorded years data)*** See Appendix B For Additional Detail




Activ ity: 549 - FUEL CELL


Results:

Forecasting Results

Method Selected 2013 | 2014 | 2015 | |Labor Itemized Forecast 113 113 113Non-Labor Itemized Forecast 267 518 556Other N/A 0 0 0Total 380 631 669


Analysis of Linear Trending Method:SCE's Fuel Cell Program has very little O&M recorded data to use as a starting point from which to develop a forecast estimate. Since the UCSB site was not operational until September 2012, the 2012 O&M recorded data does not represent an entire year and does not include any costs associated with the manufacturer's long term service agreement for this project.The fuel cell project at CSUSB is expected to be operational in 2013, therefore the 2012 O&M recorded data does not include any costs for the CSUSB site. Because of this, the most appropriate O&M forecasting methodology is an itemized forecast.

Analysis of Averaging Method:In D.04-07-022 and D.89-12-057, the CPUC stated that for those accounts have significant fluctuations in recorded expenses from year to year, and average of recorded expenses is appropriate. The Fuel Cell Program has no recorded O&M expenses until 2012, so an average is not an appropriate forecasting method.

Analysis of Last Recorded Year (2012):In D.04-07-022 and D.89-12-057, the CPUC stated that if recorded expenses in account have been relatively stable forthree or more years, the last recorded year is an appropriate base estimate. The Fuel Cell Program had no recorded O&M expenses until 2012 and 2012 did not include a full year of costs. Therefore, the last recorded year is not an applicable forecasting method.

Analysis of Itemized Forecast Method:SCE used the itemized forecast method for Fuel Cell Program labor and non-labor because SCE's Fuel Cell Program has very little O&M recorded data to use as a starting point from which to develop a forecast estimate. SCE has signed Long Term Service Agreements (LTSA) with the manufacturers of each of the fuel cell units, as well as with some other providers of services necessary to operate the fuel cells. The Fuel Cell Program has no recorded O&M expenses until 2012. Therefore, an itemized forecast is the most appropriate for labor and non-labor for FERC 549, the Fuel Cell Program.






1 R e c o rd e d P e rio d

$ (0 0 0 )

Forecast Expenses (constant 2012$) 2 0 0 8 | 2 0 0 9 | 2 0 1 0 | 201 1 | 2 0 1 2 2 0 1 3 | 2 0 1 4 | 2 0 1 5

Labor (s tan dard esca la tion ) 0 0 0 0 5 113 113 113

N o n-L abo r (s tandard esca la tion ) 0 0 0 0 1 267 518 556

O ther (no t e sca la tab le ) 0 0 0 0 0 0 0 0

Total 0 0 0 0 6 380 631 669

Labor Prior year Total 5 113 113

Change 108 0 0

Total 5 113 113 113

Non-Labor Prior year Total 1 267 518

Change 266 251 38

Total 1 267 518 556

O ther Prior year Total 0 0 0

Change

Total

0 0 0

0 0 0 0

Total C hange |

Labor 108 0 0

Non-Labor 266 251 38

O ther 0 0 0

Total N/A 374 251 38




Activ ity: 549 -FUELC ELL


This page shows the changes in Labor, Non-Labor, and O ther expenditures forecast during 2013 through 2015, including reasons fo r the addition o f personnel (labor), increased office supp lies required due to an increase in activity (non-labor).

2012 -2 0 1 3

Labor: 108

2013 w ill be the firs t year in which the UC Santa Barbara u n itw ill operate fo r a fu ll year, and the CSU San Bernardino unit w ill operate fo r approxim ately ha lf o f 2013, which results in increased labor costs.

Non-Labor: 266

Expenditures increases, as various O&M service contracts will go into service w ith the com m issioning of the second unit in 2013.

Other: 0

Not applicable.







2013 -2014

Labor: 0

Not applicable.

Non-Labor: 251

The increase reflects LTSA O&M for the first full year of operation for both fuel cell units.

Other: 0

Not applicable.







2014-2015

Labor: 0

Not applicable.

Non-Labor: 38

The change in non-labor represents the average of the 2015, 2016, 2017 prices for one LTSA. Three years were averaged for test year 2015 in order to reflect anticipated LTSA expenditures for the remaining years of the rate case cycle.

Other: 0

Not applicable.



FERC Account

A ctiv ity:

Witness:


549 - FUEL CELL

Jonathan L. Rumble

APPENDIX A





A c tiv ity : 549 - FUEL CELL



F528939 FUEL CELLSThis account includes the cost of labor, materials used and expenses incurred in the operation of Fuel Cells which are not specifically provided for or are not readily assignable to other generation expense accounts. This includes general management and administration, safety, noise and water compliance, labor relations costs, community information technology costs, reliability and efficiency expenses, training and grounds management.







2008 2009 2010 2011 2012

F528939 FUEL CELLS 0 0 0 0 6

Total 0 0 0 0 6




FERC Account:

Activ ity:

Witness:


549 - FUEL CELL

Jonathan L. Rumble

APPENDIX B





A ctiv ity : 549 - FUEL CELL



|Adjs - (Nominal $) $ (000)2008 2009 2010 2011 2012 2013 2014 2015


Total 0 0 0 0 6 0 0 0

Organizational Unit Adjustment 1 GRC-MJP.CPT-OUX-FUEL CELLS

To transfer expenses related to fuel cells from Other A&G to 549 - Fuel Cell.


Total 0 0 0 0 6 0 0 0





A ctiv ity: 549 - FUEL CELL




Fuel Cell Program

Capital Expenditures





CAPITAL WORKPAPERS - 2015 GRC

OPERATING UNIT SUMMARY (Nominal $000)

Operating Unit Summary: GEN - Fuel Cells



2013 2014 2015 2016 2017 Total

1 711 C C 0 0 711

Total 711 C C 0 0 711




CAPITAL W O R K P A P E R S - 2015 G RC

OPERATING UNIT SUMMARY

(Nominal $000)

Operating Unit Sum m ary: GEN - Fuel Cells

(2) OPERATING UNIT RECORDED AND AUTHORIZED CAPITAL AND FORECAST EXPENDITURES: 2015 GRC


2008 2009 2010 2011 2012 2013 2014 2015 2016 2017

Authorized Expenditures 0 3,977

Recorded & Forecast Expenditures 0 0 227 5,944 5,040 711 0 0 0 0

Total Expenditure 11,211 711

7.000

6.000

5.000

4.000

3.000

2.000

1.000

0


. . : - .. n

2013 2014 2015 2016



Southe rn C a lifo rn ia E d ison C om pany

C A P IT A L W O R K P A P E R S - 2015 G R C

P R O JE C T D E TA IL W O R K S H E E T

Organizational Unit Summary: GEN - Fuel Cells Testimony Summary: SCE-02, Volume 10 Major Program:Category: Facilities Infrastructure Detail:Database ID: 1647 / RO Model ID: 12

1. WITNESS2. PROJECT DETAIL

P rogram G roup

P rogram

P in #

W B S E lem ent

3. PROJECT TYPE

Jona than R um ble

FU E L C E LL

G E N E R A L - O TH E R

6965

C G 0-00-G P -P S -000070

S e lec t one

C o m plian ce : S a fe ty , Environm enta l, L icenses

R e p lace m en ts in K ind

U pgrades

B lanket: FE, T oo ls , S p are P arts, Lab, C o m pu te r Equip

S e lect one

C u s to m e r G row th

Load G row th

R e liab ility

C ap ita lized S o ftw are

V a rious (See Below )

4. ASSET TYPE

5. CLOSE DATE

6. RIIM ELIGIBLE

Fuel Cell

7 /1 /2013

N /A


Y r SC E $

2013 711

2014 0

2015 0

2016 0

2017 0

Tota l 711

2 0 15 GRC - C a p i ta l E x p e n d i tu r e s F o r e c a s t

400

20 0

02013 2014 2015 2016 2017

7 (a). SYSTEM SHORT TEXT Pjct Dev-Fuel Cell Pro ject

7 (b). DETAILED DESCRIPTION C a p ita l fo r cons truc tion o f th e fu e l ce ll p rogram , a s au thorized by D. 10-04-028.

8. SCOPE C ons is ts o f the cap ita l required to insta ll and com m iss ion S C E ’s fue l ce lls at C a lifo rn ia StateU nivers ity San B e rna rd ino (C SU SB ) and U nivers ity o f C a lifo rn ia Santa B arbara (UC SB).

9. JUSTIFICATION S C E ’s Fue l C e ll P rog ram , app roved by th e C o m m iss ion in D .10-04-028, supp o rts E xecu tive O rde rS-20-04, G overnor S ch w arzenegg e r’s G reen Build ing A ction Plan fo r S ta te fac ilitie s , and fu rthe rs S tate leg is la tive po lic ies fo r reducing G reenhouse G as (G H G ) em iss ion under A sse m b ly B ill (AB) 32 and utiliz ing c le ane r sources of d is tribu ted genera tion techno logy under S enate B ill (SB) 1298. Because the fue l cell fac ilit ie s are being insta lled at s ta te un ivers ities, the Fuel C ell P rogram will a lso enhance the S ta te ’s overa ll in te llectua l cap ita l regarding fue l cell techno logy . A s a u tility- ow ned asset, SCE is ga in ing expe rience in operating fue l ce lls to the d irect benefit o f S C E ’s cus tom ers . The pow er output of the fue l ce lls is de livered d irectly to S C E ’s d is tribu tion system which a lso benefits S C E ’s cus tom ers . SCE com ple ted construction , and com m iss ioned the fuel cell at UC SB in 2012. SCE expects to com p le te construction and com m iss ion the fue l cell at C S U S B in 2013 . P e r D. 10-04-028, O rde ring P a rag raph No. 4.b, S C E re co rd s ac tua l cap ita l and O & M in a Fue l C e ll P rog ram M em o ran dum A cco u n t (FC P M A ). S C E w ill inc lude th e cap ita l expend itu res and assoc ia ted cap ita l revenue requ irem ent fo r the Fuel C e ll P ro ject in its A p ril 1, 2014 ER R A rev iew p roceed ing and w ill dem onstra te tha t the cap ita l expend itu res are consis tent w ith th e requ irem ents o f D. 10-04-028.


150aWorkpaper - Southern California Edison / 2015 GRC - APPLICATION

C O M /M P l/lil Date o f Issuance 4/14/2Q1Q

Decision 10-04-028 April 8, 2010


Application of Pacific Gas and Electric Company for Approval and Recovery of Costs Associated w ith its Fuel Cell Project.

Application of Southern California Edison Company for Authority to Implement an d Recover in Rates the Cost of its Proposed Fuel Cell Installation Program for State Universities.

Application 09-02-013 (Filed February 20, 2009)

Application 09-04-018 (Filed April 27, 2009)

DECISION AUTHORIZING FUEL CELL PROJECTS

1. Summary

This decision approves, w ith modi fications, the applications of Pacific Gas

and Electric Company (PG&E) and Southern California Edison Company (SCE)

for approval of each utility's Fuel Cell Project to install utility-owned fuel cells on

several University of California and California State University campuses. The

decision finds it reasonable for the utilities to proceed w ith their respective Fuel

Cell Projects, as long as the projects are modified in two respects. First, PG&E

and SCE shall each reduce their project capital costs to reflect a lower

contingency percentage. Second, PG&E shall remove contingency costs and

education and outreach labor costs from its estimated non-fuel operations and

maintenance costs.

420634 - 1 -


Workpaper - Southern California Edison / 2015 GRC - APPLICATION150b

A.09-02-013, A.09-04-018 C O M /M P l/lil

utilities may seek recovery of any difference in either a petition to modify this

decision or a separate application.

16. PG&E should correct notice defects in future applications and ensure

notice is timely given and provides all information required by Rule 3.2.

O R D E R

IT IS ORDERED that:

1. The application of Pacific Gas and Electric Company for approval of its

Fuel Cell Project, is approved as modified to reduce capital costs to $20.3 million

and reduce non-fuel operations and maintenance costs from $5.79 million to

$4.71 million to remove any contingency and to exclude costs for education and

outreach labor.

2. The application of Southern California Edison Company for approval of its

Fuel Cell Installation Program is approved as modified to reduce capital costs to

$19.1 million, to clarify that stranded costs shall be recovered in accordance w ith

Decision 08-09-012, and to prohibit Southern California Edison from using

Self-Generation Incentive Program funds for the project.

3. The ratemaking for Pacific Gas and Electric Company's Fuel Cell Project is

approved as follows:

a. Pacific Gas and Electric Company may accrue the initial revenue requirement, as adjusted in this decision based on capital costs and operations an d maintenance cost reductions, in its Utility Generation Balancing Account on the commercial operation date of the Fuel Cell Project.

b. Pacific Gas and Electric Company shall file an advice letter w ithin 90 days of this decision to establish a Fuel Cell Project M emorandum Account to track the difference between

- 39 -


150cWorkpaper - Southern California Edison / 2015 GRC - APPLICATION

A.09-02-013, A.09-04-018 C O M /M P l/lil

estimated and actual capital costs and estimated and actual operations and maintenance costs.

c. After the commercial operation date of the Fuel Cell Project, if actual capital costs are less than $20.3 million, Pacific Gas and Electric Company shall file an advice letter to update the revenue requirem ent to reflect actual capital costs.

d. After each year of operation, Pacific Gas and Electric Company shall file an advice letter to adjust the previous year's Utility Generation Balancing Account entries to reflect actual operations and maintenance expenses, as long as they are no higher than $4.71 million for the first four years of plant operation.

e. Pacific Gas and Electric Company may seek recovery of reasonably incurred amounts above the estimated capital costs and operations and maintenance costs approved in this decision through either a petiti on for modification or a separate application.

f. Pacific Gas and Electric Company may seek recovery of fuel costs for the Fuel Cell Project through the Energy Resource Recovery Account.

4. The ratemaking for Southern California Edison Company's Fuel Cell

Installation Program is approved as follo ws:

a. Southern California Edison Company shall file an advice letter w ithin 90 days of this decision to establish a Fuel Cell Program M emorandum Accou nt.

b. Southern California Edison Company shall record actual capital costs and operation and maintenance costs in the Fuel Cell Program M emorandum Account and transfer the balance monthly to the generation sub-account of Base Revenue Requirement Balancing Account, as long as the amounts are no higher than the estimates approved in this decision. If actual capital expenditures and actual annual operations and maintenance expenses are less than approved in this decision, then the recorded direct capital expenditures and operations and maintenance expenses are reasonable.

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Workpaper - Southern California Edison / 2015 GRC - APPLICATION150d

A.09-02-013, A.09-04-018 C O M /M P l/lil

c. If capital costs are less than or equal to $19.1 million, and total operations and maintenance costs are less than or equal to $8.9 million, review of Southern California Edison Company's Fuel Cell Program M emorandum Account shall occur in Southern California Edison Company's annual Energy Resource Recovery Account Reasonableness proceeding. If costs exceed these amounts, Southern California Edison Company may file either a petition for modification or a separate application to seek recovery of the excess.

5. Pacific Gas and Electric Company and Southern California Edison

Company may each recover stranded costs associated w ith their respective Fuel

Cell Projects through a non-bypassable charge for a 10-year period following

commercial operation of the fuel cells, consistent w ith Commission

determinations in Decision 08-09-012.

6. Pacific Gas and Electric Company and Southern California Edison

Company shall install metering and monitoring equipm ent at each project

sufficient to provide the following projec t-specific information: electrical output

(15 m inute interval basis); thermal outpu t (15 minute interval basis); fuel

consumption (15 m inute interval basis); system electrical efficiency; and overall

system efficiency.

7. Beginning April 30, 2011 and every year thereafter, Pacific Gas and Electric

Company and Southern California Edison Company shall each submit annual

compliance reports to Energy Division providing an overview the performance

of each project deployed pursuant to this decision. The information provided in

these reports should include each project's annual capacity factor, system

availability during system peak hours, annual fuel consumption, annual

electrical output, annual thermal output, overall electrical efficiency for the year,

and overall system efficiency for the year, as well as any other information that

- 41 -



Fuel Cell Program

A.09-04-018 Fuel Cell Program Testimony




Application No.: Exhibit No.: Witnesses:

A.09-04-SCE-01J. Rumble G. Schoonyan D.Snow D. Pasaporte

■SOUTHERN CALIFORNIA

EDISONAn EDISON INTERNATIONAL Company

(U 338-E)

I Southern California Edison Company’s Fuel Cell Testimony

Before the

Public Utilities Commission of the State of California

Rosemead, California April 27, 2009


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installation activities during the school year will be mutually disruptive for both students and

construction workers.

The table below shows the expected schedule for the Fuel Cell Program.

Table 11-1Estimated Fuel Cell Program Schedule

Date Event

April 2009 SCE files its application with the CPUC

Spring/Summer 2009 SCE issues RFPs for bids for fuel cell technology and

installation

After Fuel Cell Program

Approval by the CPUC

SCE finalizes lease agreements with selected host sites



SCE finalizes contracts for the procurement of fuel cell

technology and for the installation of the fuel cell systems



SCE will arrange for installation of up to three MW (total) of

fuel cell generation at State Universities

3. Selection of Facilities

SCE’s Fuel Cell Program seeks to promote the benefits of fuel cells with cogeneration

and electric-only fuel cell technology in California. Before refining its search for state-owned facilities

to utilize these specific technologies, however, SCE conducted an initial review of numerous

state-owned facilities, including universities, executive branch office buildings, developmental and

university hospitals, prisons, veterans homes, and state National Guard facilities. SCE’s initial search

focused on the following required criteria: (1) the facility must be owned by the State of California; (2)

for interconnection convenience, cost savings, and safety considerations, the facility must have a large

and continuous electrical load to ensure that energy output from the installed fuel cell is used entirely by

the host facility (reducing the overall demand on the electric grid); and (3) the selected facility would

provide a strong platform for community education.

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After a cursory review of a number of state facilities within our service territory, SCE

selected the following eleven facilities as potential candidates based on its initial search:

• California State University at Long Beach;

• California State University at San Bernardino;

• California State University at Fullerton;

• California State Polytechnic University at Pomona;

• University of California at Santa Barbara;

• University of California at Irvine;

• University of California at Irvine Medical Center;

• Fairview Developmental Center;

• Porterville Developmental Center.

• Los Alamitos - California National Guard; and

• California State Veterans’ Home at Barstow.

In the second phase of its search, SCE narrowed its search criteria to focus on a host

facility’s ability to utilize the specific fuel cell technologies being advanced by the program, i.e., fuel

cells with cogeneration and electric-only. SCE’s process for selecting final sites, which included site

visits and/or teleconferences, is discussed below in detail.

a) Fuel Cell with Potential Cogeneration Host Sites

One of the goals of the Fuel Cell Program is to demonstrate the ability of fuel

cells to operate at high efficiencies in large, utility-scale (i.e., greater than one MW) installations. To

meet this goal, SCE evaluated each site’s potential to host a fuel cell installation with cogeneration

capabilities of one MW or greater electrical capacity.

Utility-scale fuel cell systems are usually installed with cogeneration capabilities,

where the host site uses both the electricity and heat generated by the fuel cell system. The heat

exhausted from the fuel cell is typically integrated with the host site’s thermal energy systems (building

air conditioning and water heating systems), to provide supplemental heat for HVAC systems or for pre

Exhibit No. SCE-02/ Generation/ Vol. 10Witnesses: R. Perez, J. Rumble and A. Edeson

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heating feed water for boilers. Other innovative uses of waste heat include heating swimming pools or

creating C02-rich warm air for tropical plant facilities.

In order to achieve the highest operating efficiency for a fuel cell/cogeneration

system, the host facility must have the ability to use all of the generated exhaust heat at all times.

Therefore, SCE reviewed each of the sites to determine if the facility would have consistent demand for

the fuel cell’s heat exhaust.

In addition, SCE evaluated each site’s ability to accommodate the space

requirements for large fuel cell systems “on-campus.” Systems of this size typically require up to

10,000 square feet of nearly contiguous outdoor space for the fuel cell and auxiliary equipment, as well

as room for installation, general operations, and maintenance activities. In addition to space

requirements, SCE also evaluated the ease of interconnecting the fuel cell’s mechanical systems with the

host site’s existing physical plant facilities and the ease of interconnecting the fuel cell with gas utilities,

and the site’s electrical distribution system.

Finally, SCE requested each potential host site to provide site-specific

information pertaining to its demand for exhaust heat, gas and electric utility interconnections, and area

available to host a fuel cell.

Utilizing the foregoing information, SCE narrowed its field of candidate locations

to four campuses to participate in a feasibility study (“Feasibility Study”) performed by an engineering

consultant, Black & Veatch (“B&V”). The four sites selected to participate in the study were:

• California State University at San Bernardino;

• California State Polytechnic University at Pomona;

• California State University at Long Beach; and

• California State University at Fullerton.

The Feasibility Study provided an analysis of each site’s potential to host a fuel

cell/cogeneration installation. In particular, the Feasibility Study took into account the following

considerations:

• Fuel cell operation characteristics;

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• Conceptual design - thermal system interaction;

• Conceptual design - electrical system interaction;

• Conceptual equipment arrangement and/or building requirements;

• Order of magnitude total installed cost estimates; and

• Analysis of findings.

The Feasibility Study was completed in November 2008. Based on the results,

SCE selected Cal State San Bernardino and Cal State Long Beach as the two optimal locations for

development of fuel cell/cogeneration systems. SCE selected these two sites because they offered the

potential for highest total system efficiency for fuel cell/cogeneration facilities, as well as the simplest

means of integrating the fuel cells with the mechanical operations of the site’s physical plant facilities.

Feasibility Study findings are discussed further below.

Cal State San Bernardino: SCE proposes to locate a fuel cell/cogeneration facility

at the north end of the campus, adjacent to the university’s central heating and cooling plant. The fuel

cell’s exhaust heat would be mechanically integrated with the central plant’s high temperature heating

water system and domestic hot water system, both of which serve most of the campus. Based on the

results of the Feasibility Study, SCE estimates that the overall efficiency of this fuel cell installation

could approach 72%, the highest of all sites evaluated in the study.

Cal State Long Beach: SCE proposes to locate the fuel cell cogeneration facility

at the central part of the campus, adjacent to its swimming pool complex in the southern-most part of the

surrounding athletic fields. The fuel cell’s exhaust heat would be mechanically integrated with the

heating water system that serves much o f the central campus. Based on the results of the Feasibility

Study, SCE estimates that the overall efficiency of this fuel cell installation could approach 70%, also

among the highest of any site evaluated in the study,

b) Electric Only Host Site

Another goal of the Fuel Cell Program is to demonstrate the potential capability

of various types of utility-scale fuel cell technologies. As discussed above, most utility-scale fuel cell

installations are coupled with cogeneration facilities, where the heat exhausted from the fuel cell is

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captured and used on-site in HVAC systems or in the production of steam and hot water. As part of its

Fuel Cell Program, SCE has also chosen to demonstrate and examine the operation and benefits of a

novel design, an electric-only fuel cell system, where the heat exhaust from the fuel cell is recycled

within the fuel cell itself to generate electricity at a much higher efficiency than is standard for the

industry, potentially as high as 60%. SCE believes this effort will be worthwhile because this

technology has not yet been as well-studied as the larger fuel cell/cogeneration options. If successful,

there are many locations where this type and size of equipment could be used and potentially improve

service at a lower cost to electric customers. The commercially available electric-only fuel cell units

tend to be produced as smaller-sized modules than typical fuel cell/cogeneration units. Since they do

not need to be mechanically integrated with a host facility’s physical plant to achieve relatively high

efficiencies, they provide greater flexibility to host sites.

Accordingly, concurrent with the Feasibility Studies performed by B&V for four

potential cogeneration sites, B&V also performed a Feasibility Study for an electric-only fuel cell

installation at UC Santa Barbara, taking into account the following considerations:

• The fuel celFs operational characteristics;

• Conceptual design - electrical system interaction;

• Conceptual equipment arrangement and/or building requirements;

• Order of magnitude of total installed cost estimates; and

• Analysis of findings.

The Feasibility Study was completed in November 2008. Base upon the results of

the Feasibility Study, SCE concluded that UC Santa Barbara would be a strong host facility for an

electric-only fuel cell installation. SCE continues to work with the administration and staff at UC Santa

Barbara to identify the ideal location to place the fuel cell system to maximize the strong environmental

stewardship platform that UC Santa Barbara offers,

c) Selected Host Sites

Following the analysis provided by the Feasibility Study in November 2008, SCE

notified Cal State San Bernardino, Cal State Long Beach, and UC Santa Barbara that SCE selected each

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to participate in the Fuel Cell Program.^ The parties appear to have a general understanding regarding

the following details of SCE’s proposed Fuel Cell Program:

• SCE will own and operate the fuel cell and all supporting equipment placed on the

host site;

• SCE will be responsible for fuel costs and O&M for the fuel cell module itself;

• The host site will be responsible for any and all O&M on the equipment that will

integrate the exhaust heat from the fuel cell with the host site’s physical plant;

• The host site will provide access to the fuel cell system to SCE and related third-

parties given reasonable notice;

• Adequate promotional signage and visibility will be given to the program and

SCE’s ownership of the facilities;

• The required space for the fuel cell system will be provided to SCE through a

lease arrangement;

• The electrical power produced by the fuel cell will be metered and provided to the

host facility per its existing tariff service arrangements with SCE;

• The sites with fuel cell/cogeneration facilities will receive and utilize the heat

exhausted from the fuel cell without additional charge; and

• Host sites will be responsible for any and all costs associated with backup thermal

systems necessary to support the thermal/mechanical loads during outages of the

fuel cell.

Both SCE and the selected host sites understand that the Fuel Cell Program must

first be approved by the Commission before the program can proceed, and before detailed negotiations

can be concluded to execute lease agreements. However, preliminary discussions indicate the parties’

are committed to successfully implement the program if it is approved by the Commission. Ultimately,

— SCE has also notified the two non-selected sites of its decision. SCE indicated that it would re-consider pursuing installation at one ofthese sites if the Fuel Cell Program does not move forward at one o f the selected host sites.

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SCE may negotiate a single agreement with the California State University system for CSU San

Bernardino and CSU Long Beach, and a separate agreement for UC Santa Barbara.

4. Selection of Turn-Key Installation Vendors

SCE will procure the fuel cell units and turn-key installation services through an open

request for proposal (“RFP”) process. There will be two distinct RFPs for each potential host site. The

first round of RFPs will be for the procurement of a fuel cell unit for each host site; the results of this

RFP will be made available to the Commission. The second round of RFPs will be for turn-key

engineering, procurement, and construction services for the procured fuel cell units at each respective

potential host site.

The first round of RFPs will specifically address the procurement of fuel cell unit

technology. Based on the responses to its solicitation, SCE will select the fuel cell technology that not

only provides the highest potential total system efficiency as measured by total utilized net electrical and

thermal output, but also the most commercially reasonable terms. SCE has chosen to issue a separate

RFP for each potential host site in order to account for the significant differences between each site’s

mechanical and electrical requirements and the work required to integrate a fuel cell system. For

example, the conceptual integration of the exhaust heat at Cal State San Bernardino requires that the fuel

cell system be integrated both with the central plant’s high temperature heating water system and

domestic hot water system. This is different from the conceptual integration of the exhaust heat at Cal

State Long Beach, which requires only that waste heat be integrated with a heating water system.

Additionally, the proposed electric-only fuel cell represents a different technology with its own siting

and integration issues. Upon selection o f fuel unit vendors for each of the three potential host sites, SCE

will update the Commission on the selection results as an addendum to this application. SCE will not

enter into any binding agreements with the fuel cell unit vendors until the approval of this application by

the Commission.

The second round of RFPs will seek bids for the engineering, procurement, and

construction of the fuel cell systems at each potential host site using the selected fuel cell unit

technology for that respective potential host site. The conceptual designs provided in the Feasibility

15



A.10-11-015 - 2012 GRC Update Testimony - SCE 84Page 10




Application No.: Exhibit No.: Witnesses:

A .10-11-015SCE-84 R. Worden D.Snow P. Phelan A. Riddle P. Wong G. Bridges T. Cameron

SOUTHERN CALIFORNIA

EDISON8

An E D ISO N INTERN ATIO N AL® Company

(U 338-E)

|SCE UPDATE TESTIMONY

Before the

Public Utilities Commission of the State of California

Rosemead, California October 24, 2011


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- Southern California Edison / 2015 GRC - APPLICATION164

IV.

FUEL CELL CAPITAL AND O&M FORECAST

This chapter presents SCE’s update to its Fuel Cell capital expenditure and expense

forecasts. In Chapter III of Exhibit SCE-02, Volume 10, SCE provided its forecast for operation

and maintenance (O&M) expenses and capital expenditures for three fuel cell installations that

SCE would own, operate, and maintain at the University of California Santa Barbara (UC Santa

Barbara), California State University San Bernardino (CSU San Bernardino), and California

State University Long Beach (CSU Long Beach)A SCE’s capital forecast was as follows: $6.3

million (2010), $12.8 million (2011), and $0 million (2012). SCE’s 2012 O&M forecast was

$105,000 in labor expenses and $785,000 in non-labor expenses A

Subsequent to SCE submitting its direct testimony, SCE determined that it would not be

going forward with the fuel cell installation at CSU Long Beach. In SCE’s Reply Brief and in

data request responses to TURN, SCE indicated that appropriate rate base adjustments for the

Fuel Cell program would be made during the update hearing phase of the GRC. Therefore, in this

update testimony; SCE has included the forecast of fuel cell capital expenditures for only the UC

Santa Barbara and CSU San Bernardino installations in its revenue requirement. Since SCE will

not be going forward with the fuel cell installation at CSU Long Beach, SCE’s revised capital

forecast is as follows: $208,119 (2010), $6.6 million (2011), and $3.8 million (2012). Further,

SCE’s revised 2012 test year O&M forecast is $90,000 for labor and $393,333 for nonlabor. The

$90,000 forecasted for 2012 O&M labor expenses and the $393,333 forecasted for 2012 O&M

nonlabor expenses represents an average of forecasted O&M expenses over

2012-2014A

— Pursuant to page B26 of the Commission’s rate case plan (D. 89-01-040), other than electric rate design changes, update testimony is limited to changes in the cost of labor based on contract negotiations, changes in non-labor escalation factors, and known changes due to governmental actions. While the fuel cell update testimony does not fit within the boundaries of page B26 of Decision No. 89-01-040, we assume that the other parties will not object to this testimony, which would result in a decrease in SCE’s 2012 O&M and capital forecasts.

— All O&M expenses are in constant 2009 dollars.

— Fuel Cell Program O&M labor forecast of $90,000 is the average of $50,000 in 2012, $110,000 in 2013, and $110,000 in 2014, forecasted labor. Fuel Cell Program O&M non-labor forecast of $393,333 is the average of $200,000 in 2012, $490,000 in 2013, and $490,000 in 2014, forecasted non-labor.

10



A.09-02-013 A.09-04-018 Fuel Cell - Report of Southern California Edison Company (U 338-E) Regarding Efforts to Identify an Alternative Fuel Cell

Site Pursuant to D. 12-04-011





STATE OF CALIFORNIA

Application of Pacific Gas and Electric Company (U39E) For Approval and Recovery of CostsAssociated with its Fuel Cell Project.___________Application of Southern California Edison Company (U338-E) for Authority to Implement and Recover in Rates the Cost of its Proposed Fuel Cell Installation Program for State Universities.

A. 09-02-013 (Filed February 20, 2009)

A. 09-04-018 (Filed April 27, 2009)

REPORT OF SOUTHERN CALIFORNIA EDISON COMPANY (U 338-E) REGARDING EFFORTS TO IDENTIFY AN ALTERNATIVE FUEL CELL SITE PURSUANT TO

DECISION 12-04-011

DOUGLAS K. PORTER WALKER A. MATTHEWS III


2244 Walnut Grove Avenue Post Office Box 800 Rosemead, California 91770 Telephone: (626) 302-6879Facsimile: (626) 302-3990E-mail: [email protected]

Dated: May 30, 2013





STATE OF CALIFORNIA

Application of Pacific Gas and Electric Company (U39E) For Approval and Recovery of Costs Associated with its Fuel Cell Project.Application of Southern California Edison Company (U338-E) for Authority to Implement and Recover in Rates the Cost of its Proposed Fuel Cell Installation Program for State Universities.

A. 09-02-013 (Filed February 20, 2009)

A. 09-04-018 (Filed April 27, 2009)

REPORT OF SOUTHERN CALIFORNIA EDISON COMPANY (U 338-E) REGARDING EFFORTS TO IDENTIFY AN ALTERNATIVE FUEL CELL SITE PURSUANT TO

DECISION 12-04-011

In compliance with Decision (D.) 12-04-011 and in accordance with direction provided

by California Public Utilities Commission (Commission) staff. Southern California Edison

Company (“SCE”) serves this report to the service list for Application (A.) 09-04-018 regarding

SCE’s efforts to identify an alternative fuel cell site pursuant to D .12-04-11. Because

A. 09-04-018 is a closed proceeding, this report is not being fded with the Commission.

I.

INTRODUCTION

The California Public Utilities Commission (Commission) approved SCE’s Fuel Cell

Program in D. 10-04-028, authorizing SCE to install fuel cell facilities at the following University

of California (UC) and California State University (CSU) campuses: 1) UC Santa Barbara, 2)

CSU San Bernardino, and 3) CSU Long Beach. After SCE and CSU Long Beach were unable to

reach an agreement for a reasonable ground lease, SCE cancelled the CSU Long Beach project

and only developed facilities at UC Santa Barbara and CSU San Bernardino, in accordance with

l



D. 10-04-028. In D. 12-04-011, the Commission granted FuelCell Energy, Inc.'s (FCE) petition to

modify D .10-04-028 to require SCE to seek an alternate host site for the cancelled CSU Long

Beach project. Specifically, Ordering Paragraph (OP) 3 of D. 12-04-011 directed SCE to “make

a reasonable effort to identify an alternative site for the California State University Long Beach

fuel cell project,” within the same budget limits and conditions set in D .10-04-028. The

Commission further required SCE to complete this effort by April 19, 2013 (within a year of the

effective date of D .12-04-011). This report includes SCE’s findings regarding its efforts to

identify an alternative site.

II.

REPORT

Decision D. 12-04-011, OP 3, states, “within 12 months of the effective date of this order.

Southern California Edison Company shall make a reasonable effort to identify an alternative

site for the California State University Long Beach fuel cell project approved in Decision 10-04

028.”

SCE has made a reasonable effort within the 12 month timeframe to identify an

alternative site for the abandoned CSU Long Beach fuel cell project. Specifically, SCE updated

and reviewed information for potential fuel cell installations at California State Polytechnic

University at Pomona and CSU Fullerton, which were two sites originally shortlisted for fuel cell

development. This evaluation included, among other things, conducting site visits; meeting with

staff at each potential host sites; and assessing electrical interconnection, waste-heat integration,

and other related technical issues. Based on the results from its evaluation, SCE has concluded

that a fuel cell project could not be developed at either site within the budget limits and

2



conditions set forth in D. 10-04-028. Accordingly, SCE will not be requesting authority to

implement the project at a third site.

Respectfully submitted,

DOUGLAS K. PORTER WALKER A. MATTHEWS III

/s / Walker A. Matthews IIIBy: WALKER A. MATTHEWS III


2244 Walnut Grove Avenue Post Office Box 800 Rosemead, California 91770 Telephone: (626) 302-6879Facsimile: (626) 302-3990E -mail: walker ,matthews@sce. com

Dated: May 30, 2013

3





A ctiv ity : 549.140 - CATALINA GENERATION - OPERATIONS AND MAINTENANCE OF GENERATIONFACILITIES

Witness: Anthony P. Edeson


2012$ (000)

Recorded2012

Forecast2015

Labor Five Year Average 2,234 1,915Non-Labor Five Year Average 1,963 2,680Other N/A 0 0Total 4,197 4,595


Catalina Generation - Operations and Maintenance of Generation Facilities - Includes the cost of labor, materials used and expenses incurred in the operation and maintenance of power generating facilities on Catalina Island. Includes labor such as: general supervision; operation of prime movers, generators, and auxiliary apparatus; maintenance of generating equipment; and other miscellaneous activities. Includes non-labor such as: parts for maintaining generating equipment; miscellaneous supplies; transportation expenses; meals, traveling and incidental expenses; utilities; water for fire protection or general use; and miscellaneous small tools.

See Appendix C for Final Cost Centers included in this activity.







I R e c o rd e d P e rio d

$ (000)

2008 2009 2010 2011 2012F E R C F o rm 1 R e c o rd e d (N o m in a l $ )

Labor 614 579 754 615 570

Non-Labor 1,063 2,047 1,620 1,385 1,141

O ther 0 0 0 0 0

Total 1,677 2,626 2,374 2,000 1,711


Labor 914 851 1,099 1,354 1,664

Non-Labor 1,104 1,117 1,547 845 822

O ther 0 0 0 0 0

Total 2,018 1,968 2,646 2,199 2,486


Labor 1,528 1,430 1,853 1,969 2,234

Non-Labor 2,167 3,164 3,167 2,230 1,963

O ther 0 0 0 0 0

Total 3,695 4,594 5,020 4,199 4,197

E sca la tio n :

Labor 1.1414 1.1070 1.0701 1.0327 1.0000

Non-Labor 1.0881 1.0814 1.0642 1.0254 1.0000

O the r 1.0000 1.0000 1.0000 1.0000 1.0000


Labor 1,744 1,583 1,983 2,033 2,234

N on-Labor 2 ,358 3,422 3,370 2,287 1,963

O the r_________________________________ 0______________0______________0______________0_____________0_

Total 4 ,102 5,005 5,353 4,320 4,197

6,000

5.000

4.000

3.000

2.000

1,000

0



■ l l l l2008 2009 2010 2011 2012




A ctiv ity: 549.140 - CATALINA GENERATION - OPERATIONS AND MAINTENANCE OF GENERATIONFACILITIES


Forecasting Methods - Summary o f Results o f all Methods Studied - 2012$ (000)


2013 | 2014 | 2015 | sd** | Chosen_abor 2,134 2,134 2,134 100 no''Jon-Labor 2,125 2,125 2,125 162 noOther 0 0 0 0 noTotal 4,259 4,259 4,259 n/a n/a


2013 2014 | 2015 | r2* I Chosen 2013 | 2014 | 2015 | sd** | Chosen_abor 2,335 2,460 2,586 0.89 no 2,083 2,083 2,083 108 no'Jon-Labor 1,133 429 (274) 0.91 no 2,540 2,540 2,540 602 noOther 0 0 0 0.00 no 0 0 0 0 no

Total 3,468 2,889 2,312 n/a n/a 4,623 4,623 4,623 n/a n/a

4 Recorded Years (2009 - 2012):Results of Linear Trending (T4)


2013 2014 2015 r2* Chosen2,4591,395

0

2,660850

0

2,860304

0

0.900.890.00

3,854 3,510 3,164 n/a n/a


sd** | Chosen2014 20151,9582,760

0

1,9582,760

0

1,9582,760

0

236 no646 no

0 no4,718 4,718 4,718 n/a n/a



COoCM 2014 | 2015 | r2* I Chosen

COoCM 2014 | 2015 | sd** | Chosen2,345 2,488 2,631 0.79 no 1,915 1,915 1,915 228 yes2,102 1,910 1,717 0.21 no 2,680 2,680 2,680 600 yes

0 0 0 0.00 no 0 0 0 0 no4,447 4,398 4,348 n/a n/a 4,595 4,595 4,595 n/a n/a

Other Methods:



2013 | 2014 | 2015 | | Chosen 2013 | 2014 | 2015 | | Chosen2,234 2,234 2,234 no 0 0 0 no1,963 1,963 1,963 no 0 0 0 no

0 0 0 no 0 0 0 no4,197 4,197 4,197 n/a 0 0 0 n/a

Forecast Adjustments:Base Forecast Method Adjustments*’


Method 2013 | 2014 | 2015 | 2013 | 2014 | 2015 | |A5 1,915 1,915 1,915 0 0 0A5 2,680 2,680 2,680 0 0 0N/A 0 0 0 0 0 0

4,595 4,595 4,595 0 0 0

r2 = R Squared (Based on recorded years data) sd = standard deviation (Based on recorded years data) See Appendix B For Additional Detail




Activ ity: 549.140 - CATALINA GENERATION - OPERATIONS AND MAINTENANCE OF GENERATIONFACILITIES


Results:

Forecasting Results



Analysis of Linear Trending Method:In D.89-12-057, the CPUC stated that if costs have shown a trend in a certain direction over three or more years, the last year recorded is an appropriate base estimate. As described in testimony, the use of a five-year average is more appropriate because of the fluctuations in recorded costs.

Analysis of Averaging Method:In D.89-12-057, the CPUC stated that for those sub-accounts which have significant fluctuations in recorded year expenses from year to year, an average of recorded expenses is appropriate. As described in testimony, the use of a five-year average is an appropriate forecast method because of the fluctuations in recorded costs.

Analysis of Last Recorded Year (2012):In D. 89-12-057, the CPUC stated that if costs have shown a trend in a certain direction over three or more years, the last year recorded is an appropriate base estimate. Costs in this sub-account show a four-year trend, but the use of a five-year average is more appropriate for the work activities included in this sub-account.


Method Selected 2013 | 2014 | 2015 | |Five Year Average 1,915 1,915 1,915Five Year Average 2,680 2,680 2,680

N/A 0 0 04,595 4,595 4,595






6,000

5.000

4.000

3.000

2.000

1,000

0


■ I I 1 ■ - I I I2008 2009 2010 2011 2012 2013 2014 2015

□ Labor (std escl) ■ Non-Labor (std escl) □ Cither (not escl)

1 R e c o rd e d P e rio d

$ (0 0 0 )

Forecast Expenses (constant 2012$) 2 0 0 8 | 2 0 0 9 | 2 0 1 0 | 2011 | 2 0 1 2 2 0 1 3 | 2 0 1 4 | 2 0 1 5

Labor (standard escalation) 1,744 1,583 1,983 2,033 2 ,234 1,915 1,915 1,915

Non-Labor (standard escalation) 2,358 3,422 3,370 2,287 1,963 2,680 2,680 2,680

Other (not escalatable) 0 0 0 0 0 0 0 0

Total 4,102 5 ,005 5,353 4,320 4 ,197 4,595 4,595 4,595

Labor Prior year Total 2,234 1,915 1,915

Change (319) 0 0

Total 2 ,234 1,915 1,915 1,915

Non-Labor Prior year Total 1,963 2,680 2,680

Change 717 0 0

Total 1 ,963 2,680 2,680 2,680

O ther Prior year Total 0 0 0

Change 0 0 0

Total 0 0 0 0

Total C hange |

Labor (319) 0 0

Non-Labor 717 0 0

Other 0 0 0

Total N/A 398 0 0



FERC Account:

Activ ity:

Witness:


549.140 - CATALINA GENERATION - OPERATIONS AND MAINTENANCE OF GENERATION FACILITIESAnthony P. Edeson

APPENDIX A





Activity: 549.140 - CATALINA GENERATION - OPERATIONS AND MAINTENANCE OF GENERATIONFACILITIES



* See Appendix C for Summary Final Cost Centers__________________

•SUMMARY MAINTENANCE OF FUEL HOLDERS, PRODUCERS AND ACCESSORIESIncludes payroll, automotive, and other costs incurred in repairing items in plant account 342.000, including storage tanks, pumps, and pipe system.

•SUMMARY MAINTENANCE OF MISCELLANEOUS POWER PLANT EQUIPMENTIncludes payroll and other costs incurred in repairing miscellaneous equipment in and about the Catalina diesel plant which is available for general use. Includes such items in plant account 346.000 as compressors, cranes, foundations, station maintenance equipment, and ventilation equipment.

•SUMMARY MAINTENANCE OF PRIME MOVERS AND GENERATORSIncludes payroll and other costs of employees and chief engineer incurred in repairing the Catalina diesel plant prime movers, generators, and accessory electric equipment.

•SUMMARY MISCELLANEOUS DIESEL PLANT EXPENSESIncludes payroll costs incurred in miscellaneous diesel plant operations not includable in the foregoing final cost centers, such as general clerical work, watchman, building service, etc. Also includes costs incurred for materials and expenses, such as miscellaneous supplies, utility costs such as telephone, gas, and water, and other miscellaneous diesel plant expenses not assignable to other final cost centers.

•SUMMARY SAFETYIncludes labor, material, contract, chargebacks and other non-labor costs incurred in providing and attending employee safety/crew meetings, first aid meetings, safety congresses, safety fairs, safety stand-downs, and fire extinguisher demonstration meetings. Also includes costs associated with audio metric testing of employees, first aid supplies, safety equipment, and associated travel time, and board and lodging.

•SUMMARY TRAINING SEAT-TIMEIncludes payroll, automotive, and other expenses incurred by employees engaged in compliance training activities or classes. Training activities may include company classes, seminars, orientation, video/DVD and web-based classes. Also includes payroll, automotive, and other expenses of employees engaged in training activities whether it be on-the-job training or off-the-job participation in department/division/district training programs.

F502476 SUPERVISION OF DIESEL PLANT OPERATIONSIncludes a portion of the total payroll and other costs of the general foreman incurred in the general supervision and direction of the operation of the Catalina diesel plant.

F502477 OPERATE PRIME MOVERS/ GENERATORSIncludes payroll and other costs incurred in operating prime movers, generators and auxiliary apparatus, and handling diesel fuel oil. Also includes handling parts, cost and treatment of water for cooling diesel engines, and cost of lubricating oil and grease.

F502480 TOOL EXPENSE CATALINA DIESELIncludes payroll, automotive, and other expenses incurred in ordering, returning, receiving, storing, issuing, repairing, and inventorying tools. Also includes the following: tool inventories; the cost of tool items of small value or short life; material costs in connection with tool repair; testing rubber goods; all other expenses directly connected with the accounting and handling of tools; the preparation and inventory of tools on trucks; and debits and/or credits for annual inventory adjustments.




Activity: 549.140 - CATALINA GENERATION - OPERATIONS a n d m a in te n a n c e o f g e n e r a t io nFACILITIES



* See Appendix C for Summary Final Cost Centers___________________________

F502481 EMISSION CONTROL COSTSIncludes payroll, automotive, and other expenses incurred in installing and operating emission control systems for Catalina diesel generation. Includes costs for Air Quality Management Department (AQMD) permit fees.

F502482 SUPERVISION OF DIESEL PLANT MAINTENANCEIncludes a portion of the total payroll and other costs of the general foreman incurred in the general supervision and direction of the maintenance of the Catalina diesel plant.

F502958 TOXIC WASTE CATALINA DIESELIncludes payroll, automotive, and other expenses incurred in the inspection, sampling, testing, and cleaning of oil products or polychlorinated biphenyl (PCB) contamination caused by leakage and/or spillage. Includes cost of tools and special clothing used in the sampling and clean-up process.

F502976 CATALINA FUEL EXPENSEFuel expense for Catalina diesel operations.

F528318 AIR QUALITY CONTROL EQUIPMENTIncludes payroll, automotive, and other expenses incurred in installing and operating emission control systems for Catalina diesel generation. Includes costs for Air Quality Management Department (AQMD) permit fees.

F528319 MISCELLANEOUS MAINTENANCE OF BUILDING AND GROUNDSIncludes cost of labor, materials used, and expenses incurred in maintaining substationstructures and grounds. Includes such items as: heating and air conditioning equipment and filters; sanitation facilities, including plumbing, inside the structure; all lighting fixtures; fire protection equipment; elevators, cranes, hoists, etc., and the machinery for their operation; sump pumps and pits inside structures; renovating lawns, replacing shrubbery and unlandscaped properties; repairing driveways, walks, and fences; fences and gates; water tanks; and grounding fences.

F900549 MOUNTAINVIEW 8. PEAKER CORPORATE ADJUSTMENT - 546, 548, 549, 550 AND 553OPERATIONS SUPPORT AND ENGINEERINGIncludes payroll costs incurred in miscellaneous diesel plant operations not includable in the foregoing final cost centers, such as general clerical work, watchman, building service, etc. Also includes costs incurred for materials and expenses, such as miscellaneous supplies, utility costs such as telephone, gas, and water, and other miscellaneous diesel plant expenses not assignable to other final cost centers.




Activ ity: 549.140 - CATALINA GENERATION - OPERATIONS AND MAINTENANCE OF GENERATIONFACILITIES


Recorded/Adjusted (Constant 2012$ By Final Cost Center

$ (0 0 0 )* See Appendix C for Summary Final Cost Centers 2008 2009 2 0 1 0 2 0 1 1 2 0 1 2

•SUMMARY MAINTENANCE OF FUEL HOLDERS, PRODUCERS AND ACCESSORIES

2 19 96 1 1 0 159

•SUMMARY MAINTENANCE OF MISCELLANEOUS POWER PLANT EQUIPMENT

71 115 33 344 376

•SUMMARY MAINTENANCE OF PRIME MOVERS AND GENERATORS

1,379 1,344 1,887 773 550

•SUMMARY MISCELLANEOUS DIESEL PLANT EXPENSES 1,072 967 1,172 890 805

•SUMMARY SAFETY 0 0 0 0 0

•SUMMARY TRAINING SEAT-TIME 0 0 0 0 0

F502476 SUPERVISION OF DIESEL PLANT OPERATIONS

166 48 6 6 282 435

F502477 OPERATE PRIME MOVERS / GENERATORS 741 764 773 771 755

F502480 TOOL EXPENSE CATALINA DIESEL 25 16 53 38 19

F502481 EMISSION CONTROL COSTS 1,079 1,638 1,134 1,067 915

F502482 SUPERVISION OF DIESEL PLANT MAINTENANCE

69 94 140 45 42

F502958 TOXIC WASTE CATALINA DIESEL 2 0 0 0 0

F502976 CATALINA FUEL EXPENSE 28 0 0 0 0

F528318 AIR QUALITY CONTROL EQUIPMENT 0 0 0 0 118

F528319 MISCELLANEOUS MAINTENANCE OF BUILDING AND GROUNDS

0 0 0 0 23

F900549 MOUNTAINVIEW& PEAKER CORPORATE ADJUSTMENT - 546, 548, 549, 550 AND 553 OPERATIONS SUPPORT AND ENGINEERING

(532) 0 0 0 0

Total 4,102 5,005 5,354 4,320 4,197




FERC Account:

Activ ity:

Witness:



APPENDIX B






W itness: Anthony P. Edeson

Detail o f Total Company Adjustments to Recorded Expenses

|Adjs - (Nominal $) $ (0 0 0 )2008 2009 2 0 1 0 2 0 1 1 2 0 1 2 2013 2014 2015

Labor 914 851 1,099 1,354 1,664 0 0 0Non-Labor 1,104 1,117 1,547 845 822 0 0 0Other 0 0 0 0 0 0 0 0Total 2,018 1,968 2,646 2,199 2,486 0 0 0

Organizational Unit Adjustment 1 GBU-CPT.IDP-OUX-GENOTHERPEBBLY-549

This adjustment transfers dollars which belong to Pebbly Beach from FERC 547 to FERC 549.

Labor 0 0 0 0 0 0 0 0Non-Labor 0 35 0 0 0 0 0 0Other 0 0 0 0 0 0 0 0Total 0 35 0 0 0 0 0 0

Organizational Unit Adjustment 2 TDBU-IDP-OU-REMAPP.J O ..549.140

This adjustment consolidates expenses for Catalina Diesel in activity 549.140 where they will be forecast. Costs weretransferred from FERC 546, 548, 551, 552, 553 and 554 to FERC 549.

Labor 1,019 970 1,189 1,403 1,722 0 0 0Non-Labor 1,165 1 , 2 1 2 1,618 855 736 0 0 0Other 0 0 0 0 0 0 0 0Total 2,184 2,182 2,807 2,258 2,458 0 0 0

Organizational Unit Adjustment 3 TDBU-IDP-OU-REMAPP.J O ..566.250

This consolidation adjustment re-maps the expenses from activity 549.140, 553.140, 560.281, 561.170, 562.170, and569.281 to 566.250.

Labor (105) (119) (90) (49) (58) 0 0 0Non-Labor (61) (130) (71) (1 0 ) 8 6 0 0 0Other 0 0 0 0 0 0 0 0Total (166) (249) (161) (59) 28 0 0 0



FERC Account:

Activ ity:

Witness:


549.140 - CATALINA GENERATION - OPERATIONS AND MAINTENANCE OF GENERATION FACILITIES

Anthony P. Edeson

APPENDIX C

Final Cost Centers Included in This Activity






Final Cost Centers included in this activity:

‘ Summary Final Cost Centers:

MAINTENANCE OF FUEL HOLDERS, PRODUCERS AND ACCESSORIES

F502191 F528377

MAINTENANCE OF MISCELLANEOUS POWER PLANT EQUIPMENT

F502193 F528320 F528323

MAINTENANCE OF PRIME MOVERS AND GENERATORS

F502192 F528317 F528321 F528322 F528324 F528325 F528326 F528378 F528379 F528380

MISCELLANEOUS DIESEL PLANT EXPENSES

F502478 F520683

SAFETY

F522074 F528327

TRAINING SEAT-TIME

F521281 F523365




A c tiv ity : 549.140 - CATALINA GENERATION - OPERATIONS AND MAINTENANCE OF GENERATIONFACILITIES


Individual Final Cost Centers:

F502476 F502477 F502480 F502481 F502482 F502958 F502976 F528318 F528319 F900549




FERC Account:

Activ ity:

W itness:






CAPITAL WORKPAPERS - 2015 GRC

OPERATING UNIT SUMMARY (Nominal $000)

Operating Unit Summary: GEN - Pebbly Beach



2013 2014 2015 2016 2017 Total

1 OTHER 2,480 5,465 42C 310 60 8,735

Total 2,480 5,465 42C 310 60 8,735





O P E R A T IN G U N IT S U M M A R Y

(N om ina l $000)

Operating Unit Summary: G EN - Pebbly Beach

(2) O PERA TIN G UNIT R E C O R D E D AND AU TH O RIZED C A P ITA L AND F O R E C A S T E X P EN D ITU R ES: 2015 GRC


2008 2009 2010 2011 2012 2013 2014 2015 2016 2017

Authorized Expenditures 3,016 3,366

Recorded & Forecast Expenditures 2,628 3,078 7,980 16,931 4,494 2,480 5,465 420 310 60

Total Expenditure 35,110 8,735


2,000 - ■ m-■ ■ ■ m“ 2008 2009 2010 201 1 2012 2013 2014 2015 2016 2017

□





P R O J E C T DETAIL W O R K S H E E T : VA R IO U S C A TA LIN A C A PITA L PR O JEC TS

Organizational Unit Summary: GEN - Pebbly Beach Testimony Summary: SCE-02, Volume 10 Major Program: Catalina Capital Expenditures Category: CapitalDetail: Various Catalina Capital Projects Database ID: 679 / RO Model ID: 11

Anthony Edeson1. WITNESS2. PROJECT DETAIL

Program Group

Program

P in #

W B S Element

3. PROJECT TYPE

O T H E R - TDBU

C A TA LIN A D IES EL

4049

C E T-P D -O T-C D -C A TD S L

Select one



Upgrades


Select one

Customer Growth

Load Growth

Reliability


Various (See Below)

4. ASSET TYPE

5. CLOSE DATE

6 . RIIM ELIGIBLE

Pebbly Beach

Specific Blanket

No


Y : SC E $

2013 2,480

2014 5,465

2015 420

2016 310

2017 60

Total 8,735

20 1 5 GRC - C a p i t a l E x p e n d i t u r e s F o r e c a s t

6,000

5.000

4.000

3.000

2 .0 0 0

1,000

0

2013 2014 2015 2016 2017

7(a). SYSTEM SHORT TEXT Catalina Diesel

7 (b). DETAILED DESCRIPTION Pebbly Beach Generation Automation System and projects less than $1 million.

8 . SCOPE S ee workpaper for details

9. JUSTIFICATION S ee workpaper for details

X



Catalina Plant Autom ation Project To Be Completed by Dec, 20142013, May - Dec

Remaining Design, Specification, Bid & PO, Complete 1 Unit

2014 Jan - Dec Construction &

Startup: 5 Units, 33 MT, NaS Battery

2013 - 2014 Cost

2012 & Prior Cost

Project Total Cost

TASK COST COST TotalA. HOME OFFICE Construction Management $30,000 $300,000 $330,000

Starup Management $20,000 $200,000 $220,000

Remaining Design $80,000 $80,000

Project Engineer $40,000 $50,000 $100,000

Engineering support fo r Construction $15,000 $80,000 $95,000

Engineering support fo r startup $15,000 $150,000 $175,000

O&M Training $100,000 $100,000

As Built and Turn Over package $50,000 $50,000 $120,000

Project Management $40,000 $50,000 $100,000

Specification. Bid. POs $50,000 $60,000

Cost & Schedule $20,000 $40,000 $60,000

Misc. $20,000 $100,000 $120,000HO Subtotal $400,000 $1,160,000 $1,560,000

B. MATERIALS Cables/trays/conduits by SCE $20,000 $80,000 $100,000

Others by SCE $100,000 $100,000

Material Subtotal $20,000 $180,000 $200,000C. CONSTRUCTION $0Construction Contractor Re bid $100,000 $500,000 $600,000Programing Contractor Negotiate w ith the contractor

(Dynaelectric) used in 2012 To Complete Programming and Conduct Startup

$100,000 $250,000 $350,000

Test Tech A $30,000 $370,000 $400,000SSID For Diesel Units. MT. Battery $15,000 $85,000 $100,000

Onsite Technical Specialist (Contingent Worker)

For Diesel Units. MT. Battery $20,000 $100,000 $120,000

Other Station Personnel For Diesel Units. MT. Battery $10,000 $50,000 $70,000

Stored Material Shipping $20,000 $20,000IMMs $2,000 $2,000

Construction Subtotal $297,000 $1,365,000 $1,660,000

TOTAL WITHOUT CONTINGENCY $717,000 $2,705,000 $3,422,000CONTINGENCY $83,000 $800,000 $883,000TOTAL $800,000 $3,505,000 $4,305,000 $5,631,000 $9,936,000





Activ ity: 546.140 - CATALINA DIESEL GENERATION OPERATION SUPERVISION ANDENGINEERING


Forecast Method

Chosen

201 2$ (000)

Recorded

2012

Forecast

2015Labor N/A 0 0

Non-Labor N/A 0 0

Other N/A 0 0

Total 0 0


Catalina Generation Operation Supervision and Engineering - Includes the cost of labor and expenses incurred in the general

supervision and direction of the operation of other power generating station. This activity package has zero dollars; all costs

have been transferred to activity 549 .140 .


F502476




A ctiv ity : 546.140 - CATALINA DIESEL GENERATION OPERATION SUPERVISION ANDENGINEERING



! R e c o rd e d P e rio d

$ (000)

2008 2009 2010 2011 2012F E R C F o rm 1 R e c o rd e d (N o m in a l $ )

Labor 134 53 49 272 426

N on-Labor 12 (79) 13 1 9

O the r 0______________0______________0______________ 0_____________0

Total 146 (26) 62 273 435


Labor (134) (53) (49) (272) (426)

Non-Labor (12) 79 (13) (1) (9)

O ther 0 0 0 0 0

Total (146) 26 (62) (273) (435)


Labor 0 0 0 0 0

Non-Labor 0 0 0 0 0

O ther 0 0 0 0 0

Total 0 0 0 0 0

E sca la tio n :

Labor 1.1414 1.1070 1.0701 1.0327 1.0000

Non-Labor 1.0881 1.0814 1.0642 1.0254 1.0000

O ther 1.0000 1.0000 1.0000 1.0000 1.0000


Labor

N on-Labor

O ther

Total


2008 2009 2010 2011 2012




FERC Account:

Activ ity:

Witness:


546.140 - CATALINA DIESEL GENERATION OPERATION SUPERVISION AND ENGINEERING

Anthony P. Edeson

APPENDIX A





546.140 - CATALINA DIESEL GENERATION OPERATION SUPERVISION AND ENGINEERINGAnthony P. Edeson

Recorded/Adjusted (Constant 2012$) By Final Cost Center$ (0 0 0 )

2008 2009 2 0 1 0 2 0 1 1 2 0 1 2

F502476 SUPERVISION OF DIESEL PLANT OPERATIONS

0 0 0 0 0

Total 0 0 0 0 0


FERC Account:

Activity:

Witness:



FERC Account:

Activ ity:

Witness:


546.140 - CATALINA DIESEL GENERATION OPERATION SUPERVISION AND ENGINEERINGAnthony P. Edeson

APPENDIX B





A ctiv ity: 546.140 - CATALINA DIESEL GENERATION OPERATION SUPERVISION ANDENGINEERING



|Adjs - (Nominal $) $ (0 0 0 )2008 2009 2 0 1 0 2 0 1 1 2 0 1 2 2013 2014 2015

Labor (134) (53) (49) (272) (426) 0 0 0Non-Labor ( 1 2 ) 79 (13) ( 1 ) (9) 0 0 0Other 0 0 0 0 0 0 0 0Total (146) 26 (62) (273) (435) 0 0 0

Organizational Unit Adjustment 1 TDBU-IDP-OU-CAT_ACCTADJ_546.140

This adjustment is for one time expenses for Catalina water and gas sales in 2009.

Labor 0 0 0 0 0 0 0 0Non-Labor 0 6 8 0 0 0 0 0 0Other 0 0 0 0 0 0 0 0

Total 0 6 8 0 0 0 0 0 0

Organizational Unit Adjustment 2 TDBU-IDP-OU-REMAPP_TO_549.140

This adjustment consolidates expenses for Catalina Diesel in activity 549.140 where they will be forecast. Costs were transferred from FERC 546, 548, 551, 552, 553 and 554 to FERC 549.

Labor (134) (53) (49) (272) (426) 0 0 0Non-Labor ( 1 2 ) 1 0 (13) ( 1 ) (9) 0 0 0Other 0 0 0 0 0 0 0 0Total (146) (43) (62) (273) (435) 0 0 0




FERC Account:

Activ ity:

W itness:


546.140 - CATALINA DIESEL GENERATION OPERATION SUPERVISION AND ENGINEERING

Anthony P. Edeson





Activ ity: 548.140 - CATALINA GENERATION - OPERATION OF PRIME MOVER (TURBINE)



201 2$ (000)

Recorded2012

Forecast2015

Labor N/A 0 0

Non-Labor N/A 0 0

Other N/A 0 0

Total 0 0


Catalina Generation - Operation of Prime Mover (Turbine) - Includes the cost of labor, materials used and expenses incurred in operating prime movers, generators and electric equipment on Catalina Island. This activity package has zero dollars; all costs have been transferred to activity 549.140.


F502477 F528318




A ctiv ity : 548.140 - CATALINA GENERATION - OPERATION OF PRIME MOVER (TURBINE)



Recorded Period$ (000)

2008 2009 2010 2011 2012


Non-Labor 45 67 56 63 148

O ther 0 0 0 0 0

Total 651 692 722 747 873

A d justm ents- (Nom inal $) see Appendix B fo r add itional detail

Labor (606) (625) (666) (684) (725)

Non-Labor (45) (67) (56) (63) (148)

O ther 0 0 0 0 0

Total (651) (692) (722) (747) (873)


Labor 0 0 0 0 0

Non-Labor 0 0 0 0 0

O ther 0 0 0 0 0

Total 0 0 0 0 0

E sca la tio n :

Labor 1.1414 1.1070 1.0701 1.0327 1.0000

Non-Labor 1.0881 1.0814 1.0642 1.0254 1.0000

O ther 1.0000 1.0000 1.0000 1.0000 1.0000


Labor 0 0 0 0 0

Non-Labor 0 0 0 0 0

O ther 0 0 0 0 0

Total 0 0 0 0 0


6

4

2

0

-2

-4

2008 2009 2010 2011 2012




FERC Account:

Activ ity:

Witness:


548.140 - CATALINA GENERATION - OPERATION OF PRIME MOVER (TURBINE)

Anthony P. Edeson

APPENDIX A





Activ ity: 548.140 - CATALINA GENERATION - OPERATION OF PRIME MOVER (TURBINE)



2008 2009 2 0 1 0 2 0 1 1 2 0 1 2

F502477 OPERATE PRIME MOVERS / GENERATORS

0 0 0 0 0

F528318 AIR QUALITY CONTROL EQUIPMENT 0 0 0 0 0

Total 0 0 0 0 0




FERC Account:

Activ ity:

Witness:


548.140 - CATALINA GENERATION - OPERATION OF PRIME MOVER (TURBINE)

Anthony P. Edeson

APPENDIX B





A ctiv ity: 548.140 - CATALINA GENERATION - OPERATION OF PRIME MOVER (TURBINE)



|Adjs - (Nominal $) $ (0 0 0 )2008 2009 2 0 1 0 2 0 1 1 2 0 1 2 2013 2014 2015

Labor (606) (625) (6 6 6 ) (684) (725) 0 0 0Non-Labor (45) (67) (56) (63) (148) 0 0 0Other 0 0 0 0 0 0 0 0Total (651) (692) (722) (747) (873) 0 0 0

Organizational Unit Adjustment 1 TDBU-IDP-OU-REMAPP_TO_.549.140


Labor (606) (625) (6 6 6 ) (684) (725) 0 0 0Non-Labor (45) (67) (56) (63) (148) 0 0 0Other 0 0 0 0 0 0 0 0Total (651) (692) (722) (747) (873) 0 0 0





A ctiv ity: 548.140 - CATALINA GENERATION - OPERATION OF PRIME MOVER (TURBINE)






Activ ity: 551.140 - CATALINA GENERATION - SUPERVISION OF PLANT MAINTENANCE


Forecast Method

Chosen

201 2$ (000)

Recorded2012

Forecast2015

Labor N/A 0 0

Non-Labor N/A 0 0

Other N/A 0 0

Total 0 0


Catalina Generation - Supervision of Plant M aintenance - Includes the cost of labor and expenses incurred in the general supervision and direction of the m aintenance of power generating facilities on Catalina Island. This activity package has zero

dollars; all costs have been transferred to activity 549 .140 .


F502482




A ctiv ity : 551.140 - CATALINA GENERATION - SUPERVISION OF PLANT MAINTENANCE



I Recorded Period$ (0 0 0 )

2 0 0 8 2 0 0 9 2 0 1 0 2011 2 0 1 2

FERC Form 1 Recorded (Nom inal $)

Labor 59 40 80 32 9

Non-Labor 2 46 51 12 33

O ther 0 0 0 0 0

Total 61 86 131 44 42

A d justm ents- (Nom inal $) - see Appendix B for additional detailLabor (59) (40) (80) (32) (9)

Non-Labor (2) (46) (51) (12) (33)

O ther 0 0 0 0 0

Total (61) (86) (131) (44) (42)


Labor 0 0 0 0 0

Non-Labor 0 0 0 0 0

O ther 0 0 0 0 0

Total 0 0 0 0 0

E sca la tio n :

Labor 1.1414 1.1070 1.0701 1.0327 1.0000

Non-Labor 1.0881 1.0814 1.0642 1.0254 1.0000

O ther 1.0000 1.0000 1.0000 1.0000 1.0000

R ecorded/A d justed (C onstan t 2012$)

Labor

Non-Labor

OtherTotal


2008 2009 2010 2011 2012




FERC Account:

Activ ity:

Witness:


551.140 - CATALINA GENERATION - SUPERVISION OF PLANT MAINTENANCE

Anthony P. Edeson

APPENDIX A





Activ ity: 551.140 - CATALINA GENERATION - SUPERVISION OF PLANT MAINTENANCE



2008 2009 2 0 1 0 2 0 1 1 2 0 1 2

F502482 SUPERVISION OF DIESEL PLANT MAINTENANCE

0 0 0 0 0

Total 0 0 0 0 0




FERC Account:

Activ ity:

Witness:


551.140 - CATALINA GENERATION - SUPERVISION OF PLANT MAINTENANCE

Anthony P. Edeson

APPENDIX B





A ctiv ity: 551.140 - CATALINA GENERATION - SUPERVISION OF PLANT MAINTENANCE



|Adjs - (Nominal $) $ (0 0 0 )2008 2009 2 0 1 0 2 0 1 1 2 0 1 2 2013 2014 2015

Labor (59) (40) (80) (32) (9) 0 0 0Non-Labor (2 ) (46) (51) (1 2 ) (33) 0 0 0Other 0 0 0 0 0 0 0 0Total (61) (8 6 ) (131) (44) (42) 0 0 0

Organizational Unit Adjustment 1 TDBU-IDP-OU-REMAPP_TO_.549.140


Labor (59) (40) (80) (32) (9) 0 0 0Non-Labor (2 ) (46) (51) (1 2 ) (33) 0 0 0Other 0 0 0 0 0 0 0 0Total (61) (8 6 ) (131) (44) (42) 0 0 0





A ctiv ity: 551.140 - CATALINA GENERATION - SUPERVISION OF PLANT MAINTENANCE





FERC Account: 552 Maintenance of Structures

A ctiv ity : 552.140 - CATALINA GENERATION - MAINTENANCE OF GENERATION STRUCTURES



2 0 1 2 $ (000)

Recorded2 0 1 2

Forecast2015



Catalina Generation - Maintenance of Generation Structures - Includes the cost of labor, materials used and expenses incurred in maintenance of facilities used in other power generation such as structures and improvements and fuel holders, producers and accessories. This activity package has zero dollars; all costs have been transferred to activity 549.140.








R e c o rd e d P e rio d

$ (0 0 0 )

2 0 0 8 2 0 0 9 2 0 1 0 2011 2 0 1 2

F E R C F o rm 1 R e c o rd e d (N o m in a l $)

Labor 0 5 33 49 77

Non-Labor 2 12 57 58 105

O ther 0 0 0 0 0

Total 2 17 90 107 182


Labor 0 (5) (33) (49) (77)

Non-Labor (2) (12) (57) (58) (105)

O ther 0 0 0 0 0

Total (2) (17) (90) (107) (182)


Labor 0 0 0 0 0

Non-Labor 0 0 0 0 0

O ther 0 0 0 0 0

Total 0 0 0 0 0

E sca la tio n :

Labor 1.1414 1.1070 1.0701 1.0327 1.0000

Non-Labor 1.0881 1.0814 1.0642 1.0254 1.0000

O ther 1.0000 1.0000 1.0000 1.0000 1.0000


Labor

N on-Labor

O ther

Total


2008 2009 2010 2011 2012

□ L a b o r (s td e sc l) ■ N o n -L a b o r (s td e s c l) □ O th e r (n o t e sc l)



FERC Account:

Activ ity:

Witness:

552 Maintenance of Structures

552.140 - CATALINA GENERATION - MAINTENANCE OF GENERATION STRUCTURES

Anthony P. Edeson

APPENDIX A





Activ ity: 552.140 - CATALINA GENERATION - MAINTENANCE OF GENERATION STRUCTURES




•SUMMARY MAINTENANCE OF FUEL HOLDERS, PRODUCERS AND ACCESSORIES

0 0 0 0 0

F528319 MISCELLANEOUS MAINTENANCE OF BUILDING AND GROUNDS

0 0 0 0 0

Total 0 0 0 0 0




FERC Account:

Activ ity:

Witness:

552 Maintenance of Structures

552.140 - CATALINA GENERATION - MAINTENANCE OF GENERATION STRUCTURES

Anthony P. Edeson

APPENDIX B








|Adjs - (Nominal $) $ (0 0 0 )2008 2009 2 0 1 0 2 0 1 1 2 0 1 2 2013 2014 2015

Labor 0 (5) (33) (49) (77) 0 0 0Non-Labor (2 ) (1 2 ) (57) (58) (105) 0 0 0Other 0 0 0 0 0 0 0 0Total (2 ) (17) (90) (107) (182) 0 0 0

Organizational Unit Adjustment 1 TDBU-IDP-OU-REMAPP._TO_549.140


Labor 0 (5) (33) (49) (77) 0 0 0Non-Labor (2 ) (1 2 ) (57) (58) (105) 0 0 0Other 0 0 0 0 0 0 0 0Total (2 ) (17) (90) (107) (182) 0 0 0





A ctiv ity: 552.140 - CATALINA GENERATION - MAINTENANCE OF GENERATION STRUCTURES






A ctiv ity : 553.140 - CATALINA GENERATION - MAINTENANCE OF GENERATION PRIME MOVERS



2012$ (000)

Recorded2012

Forecast2015



Catalina Generation - Maintenance of Generation Prime Movers - Includes the cost of labor, materials used and expenses incurred in maintenance of prime movers, generators, and accessory electric equipment. This activity package has zero dollars; all costs have been transferred to activity 549.140.








Recorded Period

$ (000)

2008 2009 2010 2011 2012


Non-Labor 1,046 1,001 1,428 522 265

O ther 0 0 0 0 0

Total 1,257 1,238 1,771 752 576

A d justm ents- (Nom inal $) see Appendix B fo r add itional detailLabor (211) (237) (343) (230) (311)

Non-Labor (1,046) (1,001) (1,428) (522) (265)

O ther 0 0 0 0 0

Total (1,257) (1,238) (1,771) (752) (576)


Labor 0 0 0 0 0

Non-Labor 0 0 0 0 0

O ther 0 0 0 0 0

Total 0 0 0 0 0

E sca la tio n :

Labor 1.1414 1.1070 1.0701 1.0327 1.0000

Non-Labor 1.0881 1.0814 1.0642 1.0254 1.0000

O ther 1.0000 1.0000 1.0000 1.0000 1.0000


Labor 0 0 0 0 0

Non-Labor 0 0 0 0 0

O ther 0 0 0 0 0

Total 0 0 0 0 0


6

4

2

0

-2

-4

2008 2009 2010 2011 2012




FERC Account:

Activ ity:

Witness:


553.140 - CATALINA GENERATION - MAINTENANCE OF GENERATION PRIME MOVERS

Anthony P. Edeson

APPENDIX A





Activ ity: 553.140 - CATALINA GENERATION - MAINTENANCE OF GENERATION PRIME MOVERS




•SUMMARY MAINTENANCE OF PRIME MOVERS AND GENERATORS

0 0 0 0 0

F523311 TRAINING SEAT-TIME 0 0 0 0 0

F526142 TOXIC WASTE DISPOSAL 0 0 0 0 0

Total 0 0 0 0 0




FERC Account:

Activ ity:

Witness:


553.140 - CATALINA GENERATION - MAINTENANCE OF GENERATION PRIME MOVERS

Anthony P. Edeson

APPENDIX B








|Adjs - (Nominal $) $ (0 0 0 )2008 2009 2 0 1 0 2 0 1 1 2 0 1 2 2013 2014 2015

Labor (2 1 1 ) (237) (343) (230) (311) 0 0 0Non-Labor (1,046) (1 ,0 0 1 ) (1,428) (522) (265) 0 0 0Other 0 0 0 0 0 0 0 0Total (1,257) (1,238) (1,771) (752) (576) 0 0 0


This consolidation adjustment re-maps the expenses from activity 553.140 to 573.250.

Labor 0 0 0 0 (3) 0 0 0Non-Labor 0 0 0 0 (23) 0 0 0Other 0 0 0 0 0 0 0 0Total 0 0 0 0 (26) 0 0 0



Labor (211) (237) (343) (230) (308) 0 0 0Non-Labor (1,046) (1,001) (1,428) (522) (242) 0 0 0Other 0 0 0 0 0 0 0 0Total (1,257) (1,238) (1,771) (752) (550) 0 0 0





A ctiv ity: 553.140 - CATALINA GENERATION - MAINTENANCE OF GENERATION PRIME MOVERS






A ctiv ity : 554.140 - CATALINA GENERATION - MAINTENANCE OF OTHER POWER GENERATIONPLANT



201 2$ (000)

Recorded2012

Forecast2015

Labor N/A 0 0

Non-Labor N/A 0 0

Other N/A 0 0

Total 0 0


Catalina Generation - Maintenance of Other Power Generation Plant - Includes the cost of labor, materials used and expenses incurred in miscellaneous maintenance of power generation plant on Catalina Island. This activity package has zero dollars; all costs have been transferred to activity 549.140.








! Recorded Period$ (000)

2008 2009 2010 2011 2012


N on-Labor 58 96 13 199 199

O the r 0______________0______________ 0_____________ 0_____________ 0

Total 67 106 31 335 376

A d justm ents- (Nom inal $) - see Appendix B for additional detail

Labor (9) (10) (18) (136) (177)

Non-Labor (58) (96) (13) (199) (199)

O ther 0 0 0 0 0

Total (67) (106) (31) (335) (376)


Labor 0 0 0 0 0

Non-Labor 0 0 0 0 0

O ther 0 0 0 0 0

Total 0 0 0 0 0

E sca la tio n :

Labor 1.1414 1.1070 1.0701 1.0327 1.0000

Non-Labor 1.0881 1.0814 1.0642 1.0254 1.0000

O ther 1.0000 1.0000 1.0000 1.0000 1.0000

R ecorded/A d justed (C onstan t 2012$)

Labor

N on-Labor

O ther

Total


2008 2009 2010 2011 2012




FERC Account:

Activ ity:

Witness:


554.140 - CATALINA GENERATION - MAINTENANCE OF OTHER POWER GENERATION PLANT

Anthony P. Edeson

APPENDIX A





Activ ity: 554.140 - CATALINA GENERATION - MAINTENANCE OF OTHER POWER GENERATIONPLANT



$ (000)* See Appendix C for Summary Final Cost Centers 2008 2009 2010 2011 2012

•SUMMARY MAINTENANCE OF MISCELLANEOUS POWER PLANT EQUIPMENT

0 0 0 0 0

F502958 TOXIC WASTE CATALINA DIESEL 0 0 0 0 0

Total 0 0 0 0 0




FERC Account:

Activ ity:

Witness:


554.140 - CATALINA GENERATION - MAINTENANCE OF OTHER POWER GENERATION PLANTAnthony P. Edeson

APPENDIX B








|Adjs - (Nominal $) $ (000)2008 2009 2010 2011 2012 2013 2014 2015

Labor (9) (10) (18) (136) (177) 0 0 0Non-Labor (58) (96) (13) (199) (199) 0 0 0Other 0 0 0 0 0 0 0 0Total (67) (106) (31) (335) (376) 0 0 0



Labor (9) (10) (18) (136) (177) 0 0 0Non-Labor (58) (96) (13) (199) (199) 0 0 0Other 0 0 0 0 0 0 0 0Total (67) (106) (31) (335) (376) 0 0 0




FERC Account:

Activ ity:

W itness:


554.140 - CATALINA GENERATION - MAINTENANCE OF OTHER POWER GENERATION PLANT

Anthony P. Edeson


s02v02p01 - app...expenditures forecast of $875 million, plus the 10 percent contingency, for a...

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