testimony in support of 2009 nuclear decommissioning cost …€¦ · 2010, p. 3; see also alj...

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Application No.: 09-04-009 Exhibit No.: SCE-14 Witnesses: Gregory Henry

(U 338-E)

Testimony In Support of 2009 Nuclear Decommissioning Cost Triennial Joint Application – Phase 2

Before the Public Utilities Commission of the State of California

Rosemead, CaliforniaOctober 15, 2010

Testimony In Support of 2009 Nuclear Decommissioning Joint Application – Phase II

Table Of Contents Section Page

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I. Introduction and Overview ..............................................................................................................1

II. Exhibits ............................................................................................................................................1

III. Testimony ........................................................................................................................................2

IV. Administration .................................................................................................................................2

V. Trust Fund Committees....................................................................................................................8

VI. Investments ....................................................................................................................................11

Appendix A The two most recent Nuclear Regulatory Commission filings made to report the status of the Trust Funds (per 10 CFR 50.75(f)(1))

* Appendix A also includes the “Report of the Southern California Company Nuclear Facilities Decommissioning Master Trust Committee to the California Public Utilities Commission on the 2009 Performance of the Trustee and Investment Managers For the Qualified and Non-Qualified Trusts.” This document was not requested by the Commission

Appendix B Graphs illustrating the actual performance of the individual investment funds as compared to the designated benchmark from 2000-2010, including the percentage of Trust Fund assets in each fund

Appendix C Graph illustrating estimated Trust Fund growth as set forth in the utility NDCTP applications filed since 1999, as compared to actual growth for each Trust Fund

* Liquidation values reported do not reflect the methodology for crediting back tax refunds approved In the Phase 1 settlement agreement. This adjustment will be made when SCE files its next NDCTP filing.

Appendix D List of current Committee members, their professional affiliations, and the duration of their terms, including prior appointments

Appendix E Southern California Edison Company Qualifications and Prepared Testimony of Gregory Henry

Testimony In Support of 2009 Nuclear Decommissioning Joint Application

Table Of Contents (Continued) Section Page

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Appendix F Southern California Edison Company Nuclear Facilities Qualified CPUC Decommissioning Master Trust Agreement, as amended and restated November 1, 2002

Appendix G Southern California Edison Company Nuclear Facilities Non-Qualified CPUC Decommissioning Master Trust Agreement, as amended and restated November 1, 2002

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I. 1

Introduction and Overview 2

The Triennial Nuclear Decommissioning Cost Triennial Proceeding (NDCTP) was divided into 3

two phases.1 Phase I considered the standard NDCTP issues and the procedure for review of cost 4

estimates.2 Phase 2 of this matter was designated by this Commission: 5

to review the administration and management of the decommissioning trust funds, 6 including associated costs and earnings, whether alternative asset classes should 7 be authorized, and development of a larger pool of potential fund managers, 8 including those who are [Women Minority Disabled Veterans Business 9 Enterprises] WMDVBEs, for consideration by each Trust Fund Committee 10 (Committee).3 11 12

For Phase 2 of this proceeding, the California Public Utilities Commission (Commission) 13

ordered that each of the three utilities – SCE, SDG&E, and PG&E – serve specified exhibits and 14

testimony. 15

II. 16

Exhibits 17

At the Commission’s request, SCE hereby provides the following exhibits:4 18

Appendix A The two most recent Nuclear Regulatory Commission 19 filings made to report the status of the Trust Funds (per 10 20 CFR 50.75(f)(1))5 21

22

1 On July 29, 2010, the Commission issued Decision (D.) 10-07-047, which concluded Phase I of Southern California

Edison Company’s (SCE), San Diego Gas & Electric Company (SDG&E), and Pacific Gas & Electric Company (PG&E) 2009 NDCTP.

2 ALJ Ruling Requesting Additional Briefing and Separating Trust Fund Review Issues Into Phase 2 dated August 3, 2009, p. 3. 3 Phase 2 Scoping Memo and Ruling of Assigned Commissioner and Administrative Law Judge dated August 31,

2010, p. 3; see also ALJ Ruling Requesting Additional Briefing and Separating Trust Fund Review Issues Into Phase 2 dated August 3, 2009, Scoping Ruling No. 3.

4 Phase 2 Scoping Memo and Ruling of Assigned Commissioner and Administrative Law Judge dated August 31, 2010, pp. 7-8 and Ruling No. 3, p. 9.

5 Appendix A also includes the “Report of the Southern California Edison Company Nuclear Facilities Decommissioning Master Trust Committee to the California Public Utilities Commission on the 2009 Performance of the Trustee and Investment Managers For the Qualified and Non-Qualified Trusts.” This document was not requested by the Commission

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Appendix B Graphs illustrating the actual performance of the individual 1 investment funds as compared to the designated benchmark 2 from 2000-2010, including the percentage of Trust Fund 3 assets in each fund. 4

5 Appendix C Graphs illustrating estimated Trust Fund growth as set forth 6

in the utility NDCTP applications filed since 1999, as 7 compared to actual growth for each Trust Fund. 8

Appendix D A list of current Committee members, their professional 9 affiliations, and the duration of their terms, including prior 10 appointments. 11

III. 12

Testimony 13

The Commission directed that each of the three utilities provide testimony in response to specific 14

questions: Part A of the requested testimony consists of twenty-three questions to be answered by a 15

utility employee.6 Part B of the requested testimony consists of fourteen questions to be answered by a 16

non-utility Committee member.7 Part B of the requested testimony is served concurrently with the 17

instant testimony as SCE-15. 18

In response to Part A of the Commission’s questions, the following testimony of Gregory Henry, 19

Manager of Investments in the Investments Division, Treasurer’s Department, on behalf of SCE, is 20

hereby submitted. Mr. Henry’s witness qualifications are attached to this testimony as Appendix E. 21

IV. 22

Administration 23

Q1: Describe the steps the utility takes to document entitlement to, and gain actual receipt of, a 24

disbursement of Trust funds to pay for decommissioning activities. 25

A1: The process of disbursement of funds for Southern California Edison’s (SCE’s) 26

decommissioning of San Onofre Nuclear Generating Site (SONGS) Units 1, 2 and 3 and Palo 27

Verde Units 1, 2 and 3 is overseen by the Commission and governed by the Trust Agreements. 28 6 Phase 2 Scoping Memo and Ruling of Assigned Commissioner and Administrative Law Judge dated August 31, 2010, pp. 3-5 and Ruling No. 3, p. 9. 7 Id., pp. 6-7 and Ruling No. 3, p. 9.

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The Commission has established the NDCTP “to set the annual revenue requirements for the 1

decommissioning trusts for the nuclear power plants owned by [SCE], [SDG&E], and [PG&E], 2

to verify the utilities are in compliance with prior decisions applicable to decommissioning, and 3

to determine whether actual expenditures by the utilities for decommissioning activities are 4

reasonable and prudent.” (Decision (D.) 10-07-047, p. 2, citing D.07-01-003.) 5

Authority for decommissioning activities requires one-year advance notice.8 The process 6

(previously done monthly but due to small withdrawal amounts this is now done quarterly) 7

related to SONGS 1 decommissioning for requesting funding is outlined in the Trust 8

Agreements.9 An example of the process is as follows: A request for advance funding of 9

decommissioning expenses is sent from SONGS to the investment staff. This request is in the 10

form of a worksheet which shows the gross need and the unencumbered (i.e., unspent) funds 11

from a prior request. The invoices that relate to the prior request are checked by the investment 12

staff in order to verify the available unencumbered funds. The gross need is reduced by the 13

unencumbered funds and adjusted for interest, bank charges, and taxes to arrive at the net 14

amount to be withdrawn from the Trust. The worksheet is then checked and signed by the 15

Director of Investments and a manager of SONGS. A Withdrawal Certificate10 is then prepared 16

by SONGS, signed by a Vice President of SONGS, and attested to by another SONGS member 17

of staff. The Withdrawal Certificate is then sent to the investment staff. A direction letter, signed 18

by the Director of Investments and a member of the Committee, along with the Withdrawal 19

Certificate, is sent to the Trustee. This letter instructs the Trustee to transfer funds to a bank 20

account, specifically to be used for decommissioning costs, which is separate from the 21

company’s other bank accounts from which decommissioning charges are paid. 22

8 See Appendix F, Southern California Edison Company Nuclear Facilities Qualified CPUC Decommissioning Master

Trust Agreement, as amended and restated November 1, 2002; see also, Appendix G, Southern California Edison Company Nuclear Facilities Non-Qualified CPUC Decommissioning Master Trust Agreement, as amended and restated November 1, 2002 (collectively, the “Trust Agreements”), §§ 2.01 & 6.01. Note that the Commission is a signatory to the Trust Agreements and any amendments must be approved by the Commission.

9 Trust Agreements, Appendices F-G, §§ 2.01 & 6.01. 10 Trust Agreements, Appendices F-G, Exhibit C to both appendices.

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Q2: What happens to an overpayment when a utility has received interim reimbursement for 1

an approved estimated cost, but the Commission concludes the cost was excessive and 2

approves a reduced expense amount in a subsequent NDCTP? 3

A2: This scenario has not occurred. Based on the limited information provided via this question, 4

SCE anticipates that it would return to the Trust any sum that was disallowed by the 5

Commission. SCE has not analyzed the tax consequences or necessary tax adjustments that 6

would need to occur if this scenario occurred. 7

Q3: Describe the process for selection of vendors for non-investment, administrative functions 8

like tax preparation, auditors, etc. 9

A3: The Trust Agreements provide that the Committee has responsibility for choosing vendors, the 10

tax preparer, and other business providers.11 The Trust documents state that “[u]nless otherwise 11

directed by the Committee, the Trustee shall assume responsibility for employing independent 12

certified public accountants to audit the Master Trust financial statements.”12 13

SCE has traditionally recommended that the Committee use the firm that audits its financial 14

statements filed with the Securities Exchange and Commission, currently, 15

PricewaterhouseCoopers LLP, for Nuclear Decommissioning Trust (NDT) audits. There are 16

efficiencies in this approach; for example, NDT-related audit procedures performed and matters 17

addressed in conjunction with SCE's annual audit may be used when performing the NDT audits. 18

PricewaterhouseCooper’s familiarity of the NDT Trust audited financial statements allows it to 19

more efficiently adjust the financial numbers to the required tax numbers. In 2009, Simpson & 20

Simpson, a minority-owned firm, was retained to prepare the financial statements for the Trusts. 21

Q4: What cost control measures are used to minimize administrative costs? 22

A4: The major components for administrative costs are fees paid to investment managers and the 23

Trustee. Maximum investment management fees are specified by the Commission. To ensure 24

cost competitiveness, the Trust provides that every three years, on a rotating basis, potential 25

11 Trust Agreements, Appendices F-G, §§ 3.04, 3.05 & 4.05. 12 Trust Agreements, Appendices F-G, §§ 3.05 & 4.05.

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substitutes for Trustee and investment manager assignments are reviewed via a Request for 1

Proposal (RFP).13 2

As fiduciaries, SCE is also obligated to periodically review the fee arrangements to ensure cost 3

competitiveness. For example, in 2008, SCE hired a consultant, Kohlberg & Associates, to 4

review the fee arrangement with the Trustee, Bank of New York Mellon (BNY Mellon). This 5

resulted in a fee reduction. A fee reduction was also secured from an equity manager, PanAgora, 6

as a result of the 2009 triennial equity manager review. 7

Q5: Who provides tax advice to the Committee regarding investment decision? If it is the 8

Trustee, does the utility or committee review the advice in light of actual trading decisions? 9

How is this communicated to Investment Managers (Managers)? 10

A5: Investment decisions of the Committee are focused primarily on sound investment strategies that 11

are consistent with the purpose of the nuclear decommissioning trusts. Tax implications are not 12

primary drivers of the Committee’s investment decisions and, as such, no formal tax advice is 13

provided to the Committee. There is only one federal income tax rate of 20% that is applicable 14

to all dividend income and capital gain associated with qualified nuclear decommissioning trust 15

funds. To the extent there may be any tax related issues, they may typically be focused on the 16

management of capital gains or losses associated with ongoing investment experience. The 17

investment staff work with investment managers to manage tax positions of the Trust on an on 18

going basis. When the dollar amounts are large as was the case in 2008 due to significant market 19

decline, the issue was discussed with the Committee. Managers must demonstrate a high level of 20

competence in managing taxable assets prior to being considered for NDT assignments. 21

Q6: What kinds of concerns have there been with the performance of the Trustee since 2005, 22

and how have these issues been resolved? 23

A6: Any and all issues that SCE has identified concerning the Trustee’s performance since 2005 have 24

been communicated to the Commission via SCE’s annual reports. The issues that had a negative 25

13 Trust Agreements, Appendices F-G, §§ 3.05 & 4.05.

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impact on the Trustee’s performance were accuracy and timeliness of reporting due to evolving 1

Sarbanes Oxley and Financial Accounting Standards (FAS) requirements.14 Personnel changes 2

were made by the Trustee and performance subsequently improved. 3

Q7: Is it feasible and useful for the Committee and Trustee to segregate funds for long-term 4

storage of Spent Nuclear Fuel and for ISFSI for each nuclear facility, particularly in order 5

to match Nuclear Regulatory Commission funding assurance requirements? 6

A7: The very nature of funds, whether in the form of cash or in the form of securities, that are in a 7

trust are inherently fungible. While it may be feasible for the Committee and Trustee to allocate 8

or assign these fungible amounts into “segregate funds for long-term storage of Spent Nuclear 9

Fuel and for ISFSI for each nuclear facility,” this allocation process would not appear to provide 10

any truly meaningful benefit to SCE’s customers. Investing Trust funds in a pool gives rise to 11

economies of scale that are unavailable for segregated funds. A different investment strategy 12

would necessarily have to be applied to each category of segregated funds due to differences in 13

the anticipated timeframe for withdrawal of funds and size of the assets in each fund, both of 14

which would necessarily impact the investment strategy. Each investment manager would have 15

its own fee schedule based on these differences. Therefore, segregating funds in the manner 16

identified would have cost consequences that would be detrimental to SCE’s customers. Given 17

that SCE’s customers are responsible for funding the entire decommissioning obligation, it is not 18

“useful” to generate more fees to accomplish that end result. 19

The issue of segregating funds first arose in NDCTP, Phase I. The Utility Reform Network 20

(TURN) recommended that SCE, SDGE&E and PG&E (collectively, the Utilities) allocate Trust 21

Funds into separate subaccounts for NRC license termination, non-NRC related site restoration, 22

and spent nuclear fuel management.15 The Utilities reached a compromise settlement with 23

14 FAS Accounting Standards Codification (ASC) 820 “Fair Value Measurements and Disclosures” (Statement of FAS

No. 157); ASC 320 “Investments-debt and equity securities” (Statement of FAS No. 115) 15 See TURN 1R (recommending allocation or “decommingling” of Trust Funds into separate accounts).

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TURN on this issue that was then approved by the Commission.16 Under the terms of the 1

Settlement Agreement, no segregation of funds is required.17 2

Q8: For purposes of regulatory reporting, how do you calculate the liquidation value of the 3

Trust Fund, e.g., treatment of unrealized capital gains and losses, etc.? 4

A8: The Decision in Phase 1 of the instant proceeding approved the settlement agreement wherein 5

SCE (along with SDG&E and The Utility Reform Network) agreed to a specific calculation of 6

the liquidation value and to credit back potential tax refunds to increase the liquidation value.18 7

In particular, the following agreement was made: 8

For Investments Held in the Decommissioning Trusts 9

The purpose of calculating the Trust Net Liquidation Value is to simulate the 10 conversion of all investments into cash. Thus, the Trust Net Liquidation Value 11 assumes the tax realization of gains and losses for all existing investments. As 12 such, the Trust Net Liquidation Value shall be equal to (1) the fair market value of 13 the existing investments, (2a) minus the product of the composite income tax rate 14 multiplied by the excess of the fair market value of existing investments over the 15 cost basis of existing investments, or (2b) plus the product of the composite 16 income tax rate multiplied by the excess of the cost basis of existing investments 17 over the fair market value of existing investments. 18

Where not otherwise reflected in the Trust For Tax Implications Not Reflected in 19 the Trust Net Liquidation Value 20

Net Liquidation Value, for any tax year where a decommissioning trust has 21 reported a net capital gain, the taxes paid on those gains shall be deducted from 22 the Trust Net Liquidation Value. 23

Where not otherwise reflected in the Trust Net Liquidation Value, for any tax year 24 where a decommissioning trust has reported a net capital loss that can be carried 25 back to prior tax years and utilized in those carry back years, the tax reduction (or 26 refund) associated with that loss shall be added to the Trust Fund Net Liquidation 27 Value. 28

16 D.10-07-047: Appendix B, p. 7 § 6.3 (“Decommingling”): “In the next NDCTP, the Utilities will report the pro rata

share of funds accumulated for NRC License Termination (radiological decommissioning to meet the NRC standard for license termination). At the time of filing their next NDCTP applications, the Utilities will also provide copies of their most recent funding assurance letters (pursuant to 10 C.F.R 50.75) sent to the NRC.”

17 Id. 18 D.10-07-047: Appendix B, p. 7 § 3.6.

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For any tax year where a decommissioning Trust has reported a net capital loss that results in a 1

net capital loss carry forward, the tax reduction (or refund) associated with that net capital loss 2

carry forward shall be determined under applicable tax rates and ninety percent (90%) of such 3

tax reduction (or refund) shall be added to the Trust Net Liquidation Value. The net capital loss 4

carry forward used for these purposes shall be adjusted to reflect any increases or decreases to 5

the net capital loss carry forward reported in any subsequent tax return filed by or for the 6

decommissioning trust.19 7

Q9: Do you have any suggestions for changes to the administrative provisions of the Master 8

Trust Agreements? 9

A9: Yes. In compliance with Decision (D.) 95-07-055, dated July 24, 1995, SCE must submit 10

investment management agreements to the Commission for approval. This process is time 11

consuming and inefficient. SCE therefore requests that the approval of investment management 12

agreements, that must be in compliance with Commission decisions, be delegated to the 13

Committee. 14

V. 15

Trust Fund Committees 16

Q10: Does the utility notify the Commission when it becomes aware of an upcoming vacancy on 17

the Committee? 18

A10: SCE fulfills its obligations consistent with the requirements outlined in the Trust Agreements. 19

Namely, SCE notifies the Commission of an upcoming vacancy on the Committee in the form of 20

a request to extend the term or replace the Committee member. 21

Q11: How does the utility search for and select nominees for the Committee? 22

A11: The Committee Chairman and SCE Investment Staff review available resources for qualified and 23

available professionals. Nominees that are approved by SCE’s Board of Directors, are provided 24

to the Commission for review and approval. 25

19 Trust Agreements, Appendices F-G.

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Q12: Is representation of the diverse population of California-based investment professionals a 1

factor in your methods and/or decision? Explain why or why not. 2

A12: Yes. Nominees selected for the Committee are not necessarily “investment professionals,” as 3

this is not a specific requirement for being on the Committee. All current members have 4

significant financial and investment experience. Investment experience is helpful as the 5

Committee makes decisions on investment related issues. It would not be helpful to have 6

Investment Managers on the Committee as this could create conflict of interest issues. For 7

example, in the past, one of our investment managers expressed concern about reporting detailed 8

information on their investment strategies if a Committee member was an employee of a 9

competing firm. 10

Of the three external members of the Committee, one is an African-American female, and one a 11

male Latino. Of the two internal members, one is a male Latino. 12

Q13: How many members have been reappointed since the Committee was created, and how 13

many more than once? 14

A13: Seventeen members have been appointed to the Committee over the years; nine have been 15

reappointed after their initial term, and three have been reappointed more than once. The 16

Committee members reappointed more than once are: Al Fohrer (5 appointments), Dan Garcia, 17

Latino male (4 appointments) and Aulana Peters, African-American female (3 appointments). 18

Q14: Excluding the assigned Commissioner, identify all non-Committee members who attended 19

Committee meetings between January 1, 2009 and June 30, 2010, and explain the role of 20

the non-members who attended the meetings. 21

A14: Four Committee meetings were held between January 1, 2009 and June 30, 2010. Non-22

Committee attendees are identified under each meeting. 23 24

a) April 7, 2009 25 26

Staff 27 Director of Investments, David E. Ertel 28 Senior Attorney, Michael A. Henry 29

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Manager of Investments, Gregory A. Henry 1 Senior Investment Analyst, Marvin K. Tong 2 3 b) July 1, 2009 4 5 Staff 6 Director of Investments, David E. Ertel 7 Senior Attorney, Kathleen Brennan de Jesus 8 Manager of Investments, Gregory A. Henry 9 Senior Investment Analyst, Marvin K. Tong 10 11 Guests (Investment Manager Representatives, to provide a market update and portfolio review) 12 Bob Fields (PIMCO) 13 Brent Holden (PIMCO) 14 Kwame Anochie (PIMCO) 15 16 c) December 18, 2009 17

18 Staff 19 Director of Investments, David E. Ertel 20 Manager of Regulatory Finance, Paul T. Hunt 21 Senior Attorney, Michael A. Henry 22 Manager of Investments, Gregory A. Henry 23 Senior Investment Analyst, Marvin K. Tong 24 25 Guests (Investment Manager Representatives, to provide a market update and portfolio review) 26 Billy Williams (STW) 27 Rick Rezek (STW) 28

29 d) June 1, 2010 30

31 Staff 32 Director of Investments, David E. Ertel 33 Senior Attorney, Michael A. Henry 34 Manager of Investments, Gregory A. Henry 35 Project Manager, Robert D. Bledsoe 36 Investment Analyst, Andrew Hsiai 37 38 Guests (Investment Manager Representatives, to provide a market update and portfolio review) 39 Scott Migliori (RCM) 40 Melody McDonald (RCM)| 41

42

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VI. 1

Investments 2

Q15: Identify for each currently active Manager, the value of the assets managed, the period of 3

engagement, the fees earned in 2009, investments strategies for the funds, whether 2009 4

benchmarks were met, and any concerns or difficulties with the Manager or the 5

management of the funds. 6

A15: A review of all managers is included in the 2009 annual report to the Commission attached as 7

Appendix A. There are currently no significant concerns or difficulties with any of the 8

managers. The Committee has entered into agreements with the following current investment 9

managers to manage the Trusts’ current assets. Inception dates are noted. 10

11 Qualified Trust: 12

13 1. AllianceBernstein, June 30, 1997 14 2. BlackRock Financial Management (BlackRock), July 31, 1997 15 3. Pacific Investment Management Company (PIMCO), November 30, 2001 16 4. PanAgora Asset Management, October 31, 1995 17 5. STW, March 31, 1988 18 6. State Street Global Advisors (SSgA), January 31, 2004 19 20 21 22 Non-Qualified Trust: 23 24 7. Pacific Investment Management Company (PIMCO), September 30, 2002 25 8. RCM Capital Management (RCM), June 30, 1989 26 9. State Street Global Advisors (SSgA), January 31, 2004 27 28

29 30 31 32 33 34 35

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Performance is net of taxes and net of fees, and assets are market values. 1 Assets Assets Return vs.

as of 30-Jun-10 as of 12/31/09 Investment Benchmark($ Millions) ($ Millions) ($) (BP) Strategy @ 12/31/09

Qualified Trust1 AllianceBernstein 353.6$ 335.9$ 416,603$ 12 Fixed Income - Active + 10.02 BlackRock Financial Management (BlackRock) 232.4$ 219.3$ 235,482$ 11 Fixed Income - Active + 2.33 Pacific Investment Management Company (PIMCO) 297.5$ 284.4$ 543,621$ 19 Fixed Income - Active + 10.44 PanAgora Asset Management 519.0$ 580.7$ 326,062$ 6 Non-U.S. Equity - Passive – 1.35 STW 501.1$ 466.6$ 619,454$ 13 Fixed Income - Active + 16.96 State Street Global Advisors (SSgA) 1,057.0$ 1,127.7$ 224,283$ 2 U.S. Equity - Passive – 1.4

TOTAL Qualified Trust 2,960.6$ 3,014.5$ 2,365,505$ 8

Non-Qualified Trust7 Pacific Investment Management Company (PIMCO) 55.6$ 54.5$ 116,742$ 21 Fixed Income - Active + 0.98 RCM Capital Management (RCM) 32.8$ 36.7$ 62,242$ 17 U.S. Equity - Active + 3.79 State Street Global Advisors (SSgA) 33.6$ 36.2$ 10,444$ 3 U.S. Equity - Passive – 0.2

TOTAL Non-Qualified Trust 122.0$ 127.3$ 189,428$ 15

Total FeesPaid in 2009

2

The annual investment management fee for both Trusts is approximately 11 basis points. SCE 3

believes that this level of fees is attractive relative to other types of institutional funds. 4

Q16: Are there any Manager agreements that have not been approved by Commission 5

Resolution or Decision? If so, what process did you use to acquire Commission approval? 6

A16: An Investment Management Agreement for Rhumbline Advisers (African-American owned US 7

equity manager) was submitted to the Commission on September 2, 2010 and approval is 8

pending. 9

Q17: Should the Commission adopt any guidelines for reducing equity assets upon the 10

commencement of decommissioning? Explain why or why not, and if guidelines should be 11

adopted, what should they be? 12

A17: No. These decisions should be retained by the Committee. The Committee should retain the 13

ability to make adjustment to the asset allocation as this increases flexibility. This added 14

flexibility is very useful, especially in times of crisis. Secondly, prior to decommissioning an 15

asset allocation study should be initiated and the allocations should then be guided by the results 16

of the study. 17

Q18: How is the Committee informed about the decommissioning schedule of expenses which 18

will be subject to interim disbursement during the next one to two years? How does the 19

schedule impact investment decisions? 20

A18: Prior to decommissioning SONGS 1, an asset allocation study was conducted and the results of 21

the study showed that it would be beneficial for customers to maintain the existing asset 22

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allocation. In the early years of SONGS 1 decommissioning, the Committee was periodically 1

informed of the amounts of assets remaining for SONGS 1, the costs incurred to date, and the 2

remaining costs associated with decommissioning the unit. This was done because the 3

expenditures were significant in the early years. Costs are also detailed in the triennial NDCTP 4

and reviewed with the Committee. Now that Phase I of SONGS 1 decommissioning is 5

completed, the amounts being withdrawn for SONGS 1 are small, thus frequently notifying the 6

Committee of withdrawals is unnecessary. In the future, when SONGS 2 and 3, and Palo Verde 7

1, 2 and 3 are closer to being decommissioned, an asset allocation study will be conducted. It 8

will then become necessary to adjust the investment strategy and present a detailed year by year 9

cash flow analysis to the Committee. This cash flow forecast will have to be updated 10

periodically and reviewed with the Committee on an ongoing basis. 11

Q19: If a utility decides to accelerate a planned decommissioning process, resulting in the need 12

for interim disbursements sooner than originally planned, what effect will it have on the 13

Committee’s investment strategy? 14

A19: SCE would be unlikely to accelerate a planned decommissioning process. If it did, however, an 15

asset allocation study would be conducted that takes into account current circumstances, 16

including the value of assets, and the new schedule. This would likely result in a plan to 17

reallocate funds to fixed income securities, rather than more volatile equity securities in order to 18

reduce any risk exposure and ensure that the funds are sufficient to meet required payments. 19

Q20: Describe the considerations or circumstances that would prompt the Committee to 20

consider removing some or all of the Trust Fund assets from a Manager (e.g., 21

underperformance compared to benchmarks for a specified period of time). 22

A20: The Committee will remove some or all of the Trust Fund assets from a manager due to, among 23

other things, manager under-performance versus benchmark for the specified period, manager 24

under-performance versus peer universe, performance outside of a tracking range, and/or 25

organizational stability, the lack of which may give rise to unfavorable changes in investment 26

strategies. If a portfolio manager consistently underperforms, they would be terminated. For 27

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example, in 2009 the Committee terminated an equity manager due to performance and 1

organizational issues. 2

Q21: In 2009, the California Attorney General sued State Street corp. alleging it had defrauded 3

large pension funds operated by CalPERS and STRS, by overcharging them on certain 4

trades. If any State Street Corp. affiliate (e.g., State Street Global Advisors) has managed 5

any Trust funds, has the Committee undertaken a review of the charges submitted by that 6

affiliate? 7

A21: State Street Global Advisors (SSgA) manages assets in both the Qualified and Nonqualified 8

Trusts. They are passive mangers receiving asset management fees according to a fee schedule 9

approved by the Commission. SSgA invoices are reviewed by SCE investment staff prior to 10

being paid. (See response to question 15 for the assets managed by SSgA and the fees paid to 11

SSgA in 2009.) They have performed according to expectations. The Committee has not 12

undertaken a review of the charges because the issue is with the parent corporation, State Street. 13

SCE understands that the issue involves currency trading in their role as Trustee for other plans, 14

not portfolio management. In its role for the Trusts as investment manager, State Street Global 15

Advisors is only receiving management fees for U.S. passive investment management. There is 16

no room for manipulation of fees in this domestic assignment. 17

Q22: List any of the managed funds in which Trust Fund assets are invested that are currently 18

the subject of investor litigation or governmental investigation or action. 19

A22: SCE is unaware of any managed funds in which Trust Fund assets are invested that are currently 20

the subject of investor litigation or governmental investigation or action. 21

Q23: Has the Committee made any payments to placement agents or other intermediates for 22

helping fund managers reach agreements with the Committee? 23

A23: No. 24

Appendix A

The two most recent Nuclear Regulatory Commission filings made to report the status of the

Trust Funds (per 10 CFR 50.75(f)(1))

* Appendix A also includes the “Report of the Southern California Company Nuclear Facilities Decommissioning Master Trust Committee to the California Public Utilities Commission on the 2009 Performance of the Trustee and Investment Managers For the Qualified and Non-Qualified Trusts.” This document was not requested by the Commission

Appendix B

Graphs illustrating the actual performance of the individual investment funds as compared to

the designated benchmark from 2000-2010, including the percentage of Trust Fund

assets in each fund

Appendix C

Graph illustrating estimated Trust Fund growth as set forth in the utility NDCTP

applications filed since 1999, as compared to actual growth for each Trust Fund

* Liquidation values reported do not reflect the methodology for crediting back tax refunds approved In the Phase 1 settlement agreement. This adjustment will be made when SCE files its next NDCTP filing.

Appendix D

List of current Committee members, their professional affiliations,

and the duration of their terms, including prior appointments

Appendix E

Southern California Edison Company Qualifications and

Prepared Testimony of Gregory Henry

SOUTHERN CALIFORNIA EDISON COMPANY 1 QUALIFICATIONS AND PREPARED TESTIMONY 2

OF GREGORY HENRY 3

Q. Please state your name and business address for the record. 4

A. My name is Gregory Henry, and my business address is 2244 Walnut Grove Avenue, 5

Rosemead, California 91770. 6

Q. Briefly describe your present responsibilities at the Southern California Edison Company. 7

A. I am a Manager of Investments in the Investments Division, Treasurer’s Department. I am 8

responsible for performing investment analysis for several billion dollars in Trust assets for 9

Edison’s retirement plan, nuclear decommissioning Trusts, PBOP Trusts and 401k plan. In 10

particular, I am responsible for managing the Division’s investment manager research and 11

analysis function, one of the key value-added areas for these Trusts. 12

Q. Briefly describe your educational and professional background. 13

A. I received a Bachelor degree in Economics and Accounting from the University of the West 14

Indies in 1987; a Master of Business Administration (Finance) from California State University, 15

San Bernardino in 1997 and I am a CFA charter holder. 16

I joined the Southern California Edison Company as a Financial Analyst in the Planning and 17

Analysis group of the Treasurer’s Department in 1998 and transferred to the Investments 18

Division in 2000. 19

Q. What is the purpose of your testimony in this proceeding? 20

A. The purpose of my testimony in this proceeding is to sponsor Exhibit No. SCE-14. 21

Q. Was this material prepared by you or under your supervision? 22

A. Yes, it was. 23

Q. Insofar as this material is factual in nature, do you believe it to be correct? 24

A. Yes, I do. 25

Q. Insofar as this material is in the nature of opinion or judgment, does it represent your best 26

judgment? 27

A. Yes, it does. 1

Q. Does this conclude your qualifications and prepared testimony? 2

A. Yes, it does3

Appendix F

Southern California Edison Company Nuclear Facilities Qualified CPUC Decommissioning

Master Trust Agreement, as amended and restated November 1, 2002

Appendix G

Southern California Edison Company Nuclear Facilities Non-Qualified

CPUC Decommissioning Master Trust Agreement, as amended and restated

November 1, 2002

PROCEEDING: A0904009 - EDISON AND SDG&E - F FILER: SAN DIEGO GAS & ELECTRIC COMPANY LIST NAME: LIST LAST CHANGED: SEPTEMBER 21, 2010

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GLORIA M. ING ALVIN S. PAK SENIOR ATTORNEY ATTORNEY AT LAW SOUTHERN CALIFORNIA EDISON COMPANY SEMPRA ENERGY 2244 WALNUT GROVE AVE 101 ASH STREET, HQ12C ROSEMEAD, CA 91770 SAN DIEGO, CA 92101-3017 FOR: SOUTHERN CALIFORNIA EDISON COMPANY FOR: SAN DIEGO GAS & ELECTRIC COMPANY DONALD H. KORN RASHID A. RASHID DHK ASSOCIATES CALIF PUBLIC UTILITIES COMMISSION 355 N SAN ANTONIO ROAD LEGAL DIVISION LOS ALTOS, CA 94022 ROOM 4107 FOR: DHK ASSOCIATES 505 VAN NESS AVENUE SAN FRANCISCO, CA 94102-3214 FOR: DIVISION OF RATEPAYER ADVOCATES MATTHEW FREEDMAN CRAIG M. BUCHSBAUM THE UTILITY REFORM NETWORK LAW DEPARTMENT 115 SANSOME STREET, SUITE 900 PACIFIC GAS AND ELECTRIC COMPANY SAN FRANCISCO, CA 94104 PO BOX 7442 / 77 BEALE STREET FOR: THE UTILITY REFORM NETWORK SAN FRANCISCO, CA 94105 FOR: PACIFIC GAS AND ELECTRIC COMPANY ANN L. TROWBRIDGE SCOTT L. FIELDER DAY CARTER & MURPHY LLP ATTORNEY AT LAW 3620 AMERICAN RIVER DRIVE, SUITE 205 FIELDER, FIELDER & FIELDER SACRAMENTO, CA 95864 419 SPRING STREET, SUITE A FOR: MERCED IRRIGATION DISTRICT NEVADA CITY, CA 95959 FOR: FIELDER, FIELDER & FIELDER

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CASSANDRA SWEET RAMIREZ ASSET MANAGAMENT DOW JONES NEWSWIRES EMAIL ONLY EMAIL ONLY EMAIL ONLY, CA 00000 EMAIL ONLY, CA 00000 MRW & ASSOCIATES, LLC CLIFFORD SWINT EMAIL ONLY SENIOR VICE PRESIDENT EMAIL ONLY, CA 00000 BLAYLOCK ROBERT VAN, LLC EMAIL ONLY EMAIL ONLY, NY 00000-0000 RONALD M. QUIGLEY LOUIS A. SARNO ALADDIN CAPITAL LLC RAMIREZ ASSET MANAGEMENT SIX LANDMARK SQUARE 61 BROADWAY, 29TH FL. STAMFORD, CT 06901 NEW YORK, NY 10006 NIALL J. KENNY RAY O'CONNOR VP 61 BROADWAY RAMIREZ ASSET MANAGEMENT NEW YORK, NY 10006 61 BROADWAY 29TH FL. NEW YORK, NY 10006 SAMUEL A. RAMIREZ JR. GREG PARSONS PRESIDENT & CEO PRESIDENT RAMIREZ ASSET MANAGEMENT UCM PARTNERS 61 BROADWAY, 29TH FLOOR 52 BVANDERBILT AVNUE, SUITE 401 NEW YORK, NY 10006 NEW YORK, NY 10017 THOMAS B. MANDEL DAIL ST CLAIRE SENIOR MANAGING DIRECTOR WILLIAMS CAPITAL MANAGEMENT, LLC UCM PARTNERS 570 SEVENTH AVENUE, SUITE 504 52 VANDERBILT AVENUE, SUITE 401 NEW YORK, NY 10018 NEW YORK, NY 10017 DAIL ST. CLAIRE CLIFFORD C. SWINT WILLIAMS CAPITAL MANAGEMENT TRUST BLAYLOCK & COMPANY 570 SEVENTH AVENUE, STE. 504 600 LEXINGTON AVE., STE 300 NEW YORK, NY 10018 NEW YORK, NY 10022-7637 JUAN D. ESPINOSA BETTE SMITH-MILNE CABRERA CAPITAL MARKETS, LLC FIRST-CHOICE DISTRIBUTORS 122 EAST 42ND STREET, 15TH FLOOR 11835 W. OLYMPIC BOULEVARD, SUITE 425E NEW YORK, NY 10168 LOS ANGELES, CA 90064 JERRY J. RUIZ JANICE BRYANT HOWROYD ADORNO YOSS ALVARADO & SMITH ACT 1 GROUP 633 W. FIFTH STREET, SUITE 1100 1999 W. 190TH STREET LOS ANGELES, CA 90071 TORRANCE, CA 90504 KEN LANDAU GORDON M. DE LANG ACT 1 GROUP SOUTHERN CALIFORNIA COMMERCIAL BANKING 1999 W. 190TH STREET 135 NORTH LOS ROBLES AVE, SUITE 100 TORRANCE, CA 90504 PASADENA, CA 91101 ANGELICA MORALES PAUL T. HUNT ATTORNEY SOUTHERN CALIFORNIA EDISON COMPANY SOUTHERN CALIFORNIA EDISON COMPANY PO BOX 800 2244 WALNUT GROVE AVENUE 2244 WLANUT GROVE AVENUE ROSEMEAD, CA 91770 ROSEMEAD, CA 91770

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RAQUEL IPPOLITI JAMES F. WALSH SOUTHERN CALIFORNIA EDISON COMPANY ATTORNEY AT LAW CASE ADMINISTRATION - LAW DEPARTMENT SAN DIEGO GAS & ELECTRIC COMPANY 2244 WALNUT GROVE AVE. PO BOX 1831, 101 ASH STREET ROSEMEAD, CA 91770 SAN DIEGO, CA 92101-3017 WENDY KEILANI LINDA WRAZEN SAN DIEGO GAS & ELECTRIC REGULATORY CASE ADMINISTRATOR 8330 CENTURY PARK COURT, CP32D SAN DIEGO GAS & ELECTRIC COMPANY SAN DIEGO, CA 92123 8330 CENTURY PARK COURT, CP32D SAN DIEGO, CA 92123-1530 CENTRAL FILES HAL CARDEN SDG&E AND SOCALGAS PACIFIC GAS AND ELECTRIC COMPANY 8330 CENTURY PARK COURT, CP31-E PO BOX 56 SAN DIEGO, CA 92123-1550 AVILA BEACH, CA 93424 BRUCE FOSTER EDMUND VIRAY SOUTHERN CALIFORNIA EDISON COMPANY WULFF HANSEN & CO. 601 VAN NESS AVENUE, STE. 2040 351 CALIFORNIA STREET, STE., 1000 SAN FRANCISCO, CA 94102 SAN FRANCISCO, CA 94104 LEONARD BERRY NINA SUETAKE BACKSTROM MCCARLEY BERRY & CO., LLC THE UTILITY REFORM NETWORK 115 SANSOME STREET, MEZZANINE A 115 SANSOME STREET, SUITE 900 SAN FRANCISCO, CA 94104 SAN FRANCISCO, CA 94104 ANTHEA LEE BONNIE TAM PACIFIC GAS AND ELECTRIC COMPANY PACIFIC GAS AND ELECTRIC COMPANY 77 BEALE STREET, MC B9A, ROOM 904 77 BEALE STREET, MC B10A, PO BOX 770000 SAN FRANCISCO, CA 94105 SAN FRANCISCO, CA 94105 CHRISTOPHER J. WARNER HAUSMANN BANET PACIFIC GAS AND ELECTRIC COMPANY 595 MARKET STREET, SUITE 2170 77 BEALE STREET SAN FRANCISCO, CA 94105 SAN FRANCISCO, CA 94105 JOHNITA MIZELLE THURMAN B. WHITE, JR. PROGRESS INVESTMENT MANAGEMENT CO. LLC PROGRESS INVESTMENT MANAGEMENT CO, LLC 33 NEW MONTGOMERY ST. 19TH FLOOR 33 NEW MONTGOMERY STREET, 19TH FLOOR SAN FRANCISCO, CA 94105 SAN FRANCISCO, CA 94105 ANTOINETTE CHANDLER HILARY CORRIGAN MORGAN STANLEY CALIFORNIA ENERGY MARKETS 101 CALIFORNIA STREET, 7TH FLOOR 425 DIVISADERO ST. SUITE 303 SAN FRANCISCO, CA 94111 SAN FRANCISCO, CA 94117-2242 CASE ADMINISTRATION LINDSEY HOW-DOWLING PACIFIC GAS & ELECTRIC COMPANY LAW OFFICES OF LINDSEY HOW-DOWLING 77 BEALE STREET, MC B9A 6331 FAIRMOUNT AVE., NO. 283 SAN FRANCISCO, CA 94177 EL CERRITO, CA 94530 FOR: PACIFIC GAS & ELECTRIC COMPANY DONALD E. RAGSDALE JAMES ADAMS 1290 PARKMOOR AVE NO. 51 9394 MIRA DEL RIO DRIVE SAN JOSE, CA 95126 SACRAMENTO, CA 95827 RALPH R. NEVIS DAY CARTER & MURPHY LLP 3620 AMERICAN RIVER DR., SUITE 205 SACRAMENTO, CA 95864



BERNARD AYANRUOH CLAYTON K. TANG CALIF PUBLIC UTILITIES COMMISSION CALIF PUBLIC UTILITIES COMMISSION ENERGY COST OF SERVICE & NATURAL GAS BRA ENERGY COST OF SERVICE & NATURAL GAS BRA ROOM 4205 ROOM 4205 505 VAN NESS AVENUE 505 VAN NESS AVENUE SAN FRANCISCO, CA 94102-3214 SAN FRANCISCO, CA 94102-3214 DONALD J. LAFRENZ ERIC GREENE CALIF PUBLIC UTILITIES COMMISSION CALIF PUBLIC UTILITIES COMMISSION ENERGY DIVISION ENERGY DIVISION AREA 4-A AREA 4-A 505 VAN NESS AVENUE 505 VAN NESS AVENUE SAN FRANCISCO, CA 94102-3214 SAN FRANCISCO, CA 94102-3214 MELANIE DARLING PAUL M. CHAN CALIF PUBLIC UTILITIES COMMISSION CALIF PUBLIC UTILITIES COMMISSION DIVISION OF ADMINISTRATIVE LAW JUDGES ENERGY COST OF SERVICE & NATURAL GAS BRA ROOM 5041 ROOM 4205 505 VAN NESS AVENUE 505 VAN NESS AVENUE SAN FRANCISCO, CA 94102-3214 SAN FRANCISCO, CA 94102-3214 PAUL S. PHILLIPS ROBERT M. POCTA CALIF PUBLIC UTILITIES COMMISSION CALIF PUBLIC UTILITIES COMMISSION EXECUTIVE DIVISION ENERGY COST OF SERVICE & NATURAL GAS BRA ROOM 5212 ROOM 4205 505 VAN NESS AVENUE 505 VAN NESS AVENUE SAN FRANCISCO, CA 94102-3214 SAN FRANCISCO, CA 94102-3214 THOMAS M. RENAGHAN CALIF PUBLIC UTILITIES COMMISSION ENERGY COST OF SERVICE & NATURAL GAS BRA ROOM 4205 505 VAN NESS AVENUE SAN FRANCISCO, CA 94102-3214

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PROCEEDING: A0904007 - PG&E - FOR ITS 2009 FILER: PACIFIC GAS AND ELECTRIC COMPANY LIST NAME: LIST LAST CHANGED: SEPTEMBER 21, 2010

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GLORIA M. ING ALVIN S. PAK SENIOR ATTORNEY ATTORNEY AT LAW SOUTHERN CALIFORNIA EDISON COMPANY SEMPRA ENERGY 2244 WALNUT GROVE AVE 101 ASH STREET, HQ12C ROSEMEAD, CA 91770 SAN DIEGO, CA 92101-3017 FOR: SOUTHERN CALIFORNIA EDISON COMPANY FOR: SAN DIEGO GAS & ELECTRIC COMPANY DONALD H. KORN RASHID A. RASHID DHK ASSOCIATES CALIF PUBLIC UTILITIES COMMISSION 355 N SAN ANTONIO ROAD LEGAL DIVISION LOS ALTOS, CA 94022 ROOM 4107 FOR: DHK ASSOCIATES 505 VAN NESS AVENUE SAN FRANCISCO, CA 94102-3214 FOR: DIVISION OF RATEPAYER ADVOCATES MATTHEW FREEDMAN CRAIG M. BUCHSBAUM THE UTILITY REFORM NETWORK LAW DEPARTMENT 115 SANSOME STREET, SUITE 900 PACIFIC GAS AND ELECTRIC COMPANY SAN FRANCISCO, CA 94104 PO BOX 7442 / 77 BEALE STREET FOR: THE UTILITY REFORM NETWORK SAN FRANCISCO, CA 94105 FOR: PACIFIC GAS AND ELECTRIC COMPANY ANN L. TROWBRIDGE SCOTT L. FIELDER DAY CARTER & MURPHY LLP ATTORNEY AT LAW 3620 AMERICAN RIVER DRIVE, SUITE 205 FIELDER, FIELDER & FIELDER SACRAMENTO, CA 95864 419 SPRING STREET, SUITE A FOR: MERCED IRRIGATION DISTRICT NEVADA CITY, CA 95959 FOR: FIELDER, FIELDER & FIELDER

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CASSANDRA SWEET RAMIREZ ASSET MANAGAMENT DOW JONES NEWSWIRES EMAIL ONLY EMAIL ONLY EMAIL ONLY, CA 00000 EMAIL ONLY, CA 00000 MRW & ASSOCIATES, LLC CLIFFORD SWINT EMAIL ONLY SENIOR VICE PRESIDENT EMAIL ONLY, CA 00000 BLAYLOCK ROBERT VAN, LLC EMAIL ONLY EMAIL ONLY, NY 00000-0000 RONALD M. QUIGLEY LOUIS A. SARNO ALADDIN CAPITAL LLC RAMIREZ ASSET MANAGEMENT SIX LANDMARK SQUARE 61 BROADWAY, 29TH FL. STAMFORD, CT 06901 NEW YORK, NY 10006 NIALL J. KENNY RAY O'CONNOR VP 61 BROADWAY RAMIREZ ASSET MANAGEMENT NEW YORK, NY 10006 61 BROADWAY 29TH FL. NEW YORK, NY 10006 SAMUEL A. RAMIREZ JR. GREG PARSONS PRESIDENT & CEO PRESIDENT RAMIREZ ASSET MANAGEMENT UCM PARTNERS 61 BROADWAY, 29TH FLOOR 52 BVANDERBILT AVNUE, SUITE 401 NEW YORK, NY 10006 NEW YORK, NY 10017 THOMAS B. MANDEL DAIL ST CLAIRE SENIOR MANAGING DIRECTOR WILLIAMS CAPITAL MANAGEMENT, LLC UCM PARTNERS 570 SEVENTH AVENUE, SUITE 504 52 VANDERBILT AVENUE, SUITE 401 NEW YORK, NY 10018 NEW YORK, NY 10017 DAIL ST. CLAIRE CLIFFORD C. SWINT WILLIAMS CAPITAL MANAGEMENT TRUST BLAYLOCK & COMPANY 570 SEVENTH AVENUE, STE. 504 600 LEXINGTON AVE., STE 300 NEW YORK, NY 10018 NEW YORK, NY 10022-7637 JUAN D. ESPINOSA BETTE SMITH-MILNE CABRERA CAPITAL MARKETS, LLC FIRST-CHOICE DISTRIBUTORS 122 EAST 42ND STREET, 15TH FLOOR 11835 W. OLYMPIC BOULEVARD, SUITE 425E NEW YORK, NY 10168 LOS ANGELES, CA 90064 JERRY J. RUIZ JANICE BRYANT HOWROYD ADORNO YOSS ALVARADO & SMITH ACT 1 GROUP 633 W. FIFTH STREET, SUITE 1100 1999 W. 190TH STREET LOS ANGELES, CA 90071 TORRANCE, CA 90504 KEN LANDAU GORDON M. DE LANG ACT 1 GROUP SOUTHERN CALIFORNIA COMMERCIAL BANKING 1999 W. 190TH STREET 135 NORTH LOS ROBLES AVE, SUITE 100 TORRANCE, CA 90504 PASADENA, CA 91101 ANGELICA MORALES PAUL T. HUNT ATTORNEY SOUTHERN CALIFORNIA EDISON COMPANY SOUTHERN CALIFORNIA EDISON COMPANY PO BOX 800 2244 WALNUT GROVE AVENUE 2244 WLANUT GROVE AVENUE ROSEMEAD, CA 91770 ROSEMEAD, CA 91770

Information Only



RAQUEL IPPOLITI JAMES F. WALSH SOUTHERN CALIFORNIA EDISON COMPANY ATTORNEY AT LAW CASE ADMINISTRATION - LAW DEPARTMENT SAN DIEGO GAS & ELECTRIC COMPANY 2244 WALNUT GROVE AVE. PO BOX 1831, 101 ASH STREET ROSEMEAD, CA 91770 SAN DIEGO, CA 92101-3017 WENDY KEILANI LINDA WRAZEN SAN DIEGO GAS & ELECTRIC REGULATORY CASE ADMINISTRATOR 8330 CENTURY PARK COURT, CP32D SAN DIEGO GAS & ELECTRIC COMPANY SAN DIEGO, CA 92123 8330 CENTURY PARK COURT, CP32D SAN DIEGO, CA 92123-1530 CENTRAL FILES HAL CARDEN SDG&E AND SOCALGAS PACIFIC GAS AND ELECTRIC COMPANY 8330 CENTURY PARK COURT, CP31-E PO BOX 56 SAN DIEGO, CA 92123-1550 AVILA BEACH, CA 93424 BRUCE FOSTER EDMUND VIRAY SOUTHERN CALIFORNIA EDISON COMPANY WULFF HANSEN & CO. 601 VAN NESS AVENUE, STE. 2040 351 CALIFORNIA STREET, STE., 1000 SAN FRANCISCO, CA 94102 SAN FRANCISCO, CA 94104 LEONARD BERRY NINA SUETAKE BACKSTROM MCCARLEY BERRY & CO., LLC THE UTILITY REFORM NETWORK 115 SANSOME STREET, MEZZANINE A 115 SANSOME STREET, SUITE 900 SAN FRANCISCO, CA 94104 SAN FRANCISCO, CA 94104 ANTHEA LEE BONNIE TAM PACIFIC GAS AND ELECTRIC COMPANY PACIFIC GAS AND ELECTRIC COMPANY 77 BEALE STREET, MC B9A, ROOM 904 77 BEALE STREET, MC B10A, PO BOX 770000 SAN FRANCISCO, CA 94105 SAN FRANCISCO, CA 94105 CHRISTOPHER J. WARNER HAUSMANN BANET PACIFIC GAS AND ELECTRIC COMPANY 595 MARKET STREET, SUITE 2170 77 BEALE STREET SAN FRANCISCO, CA 94105 SAN FRANCISCO, CA 94105 JOHNITA MIZELLE THURMAN B. WHITE, JR. PROGRESS INVESTMENT MANAGEMENT CO. LLC PROGRESS INVESTMENT MANAGEMENT CO, LLC 33 NEW MONTGOMERY ST. 19TH FLOOR 33 NEW MONTGOMERY STREET, 19TH FLOOR SAN FRANCISCO, CA 94105 SAN FRANCISCO, CA 94105 ANTOINETTE CHANDLER HILARY CORRIGAN MORGAN STANLEY CALIFORNIA ENERGY MARKETS 101 CALIFORNIA STREET, 7TH FLOOR 425 DIVISADERO ST. SUITE 303 SAN FRANCISCO, CA 94111 SAN FRANCISCO, CA 94117-2242 CASE ADMINISTRATION LINDSEY HOW-DOWLING PACIFIC GAS & ELECTRIC COMPANY LAW OFFICES OF LINDSEY HOW-DOWLING 77 BEALE STREET, MC B9A 6331 FAIRMOUNT AVE., NO. 283 SAN FRANCISCO, CA 94177 EL CERRITO, CA 94530 FOR: PACIFIC GAS & ELECTRIC COMPANY DONALD E. RAGSDALE JAMES ADAMS 1290 PARKMOOR AVE NO. 51 9394 MIRA DEL RIO DRIVE SAN JOSE, CA 95126 SACRAMENTO, CA 95827 RALPH R. NEVIS DAY CARTER & MURPHY LLP 3620 AMERICAN RIVER DR., SUITE 205 SACRAMENTO, CA 95864



BERNARD AYANRUOH CLAYTON K. TANG CALIF PUBLIC UTILITIES COMMISSION CALIF PUBLIC UTILITIES COMMISSION ENERGY COST OF SERVICE & NATURAL GAS BRA ENERGY COST OF SERVICE & NATURAL GAS BRA ROOM 4205 ROOM 4205 505 VAN NESS AVENUE 505 VAN NESS AVENUE SAN FRANCISCO, CA 94102-3214 SAN FRANCISCO, CA 94102-3214 DONALD J. LAFRENZ ERIC GREENE CALIF PUBLIC UTILITIES COMMISSION CALIF PUBLIC UTILITIES COMMISSION ENERGY DIVISION ENERGY DIVISION AREA 4-A AREA 4-A 505 VAN NESS AVENUE 505 VAN NESS AVENUE SAN FRANCISCO, CA 94102-3214 SAN FRANCISCO, CA 94102-3214 MELANIE DARLING PAUL M. CHAN CALIF PUBLIC UTILITIES COMMISSION CALIF PUBLIC UTILITIES COMMISSION DIVISION OF ADMINISTRATIVE LAW JUDGES ENERGY COST OF SERVICE & NATURAL GAS BRA ROOM 5041 ROOM 4205 505 VAN NESS AVENUE 505 VAN NESS AVENUE SAN FRANCISCO, CA 94102-3214 SAN FRANCISCO, CA 94102-3214 PAUL S. PHILLIPS ROBERT M. POCTA CALIF PUBLIC UTILITIES COMMISSION CALIF PUBLIC UTILITIES COMMISSION EXECUTIVE DIVISION ENERGY COST OF SERVICE & NATURAL GAS BRA ROOM 5212 ROOM 4205 505 VAN NESS AVENUE 505 VAN NESS AVENUE SAN FRANCISCO, CA 94102-3214 SAN FRANCISCO, CA 94102-3214 THOMAS M. RENAGHAN CALIF PUBLIC UTILITIES COMMISSION ENERGY COST OF SERVICE & NATURAL GAS BRA ROOM 4205 505 VAN NESS AVENUE SAN FRANCISCO, CA 94102-3214

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