Docket Exhibit Number Commissioner ALJ Witness

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A.19-08-013 PAO-03 _______ Shiroma Wildgrube/Seybert Lasko

PUBLIC ADVOCATES OFFICE CALIFORNIA PUBLIC UTILITIES COMMISSION

Report on the Results of Operations for

Southern California Edison Company General Rate Case

Test Year 2021

Transmission & Distribution Capital Expenditures Part 1

San Francisco, California April 10, 2020

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TABLE OF CONTENTS

I. INTRODUCTION ............................................................................................... 1

II. SUMMARY OF RECOMMENDATIONS .......................................................... 3

III. GENERAL DISCUSSION ................................................................................... 4

A. Background ....................................................................................................... 4

B. Capital Expenditures versus Capital Additions ................................................ 6

IV. DISCUSSION / ANALYSIS OF DISTRIBUTION INFRASTRUCTURE REPLACEMENT (SCE-02, VOL. 1, PART 1)................... 7

V. DISCUSSION / ANALYSIS OF METER ACTIVITIES (SCE-02, VOL. 1, PART 3) .................................................................................................... 8

A. Overview of SCE’s Request ............................................................................. 8

B. Meter Engineering Routine Work .................................................................... 8

VI. DISCUSSION / ANALYSIS OF TRANSMISSION GRID (SCE-02, VOL. 2) ............................................................................................................... 10

A. Overview of SCE’s Request ........................................................................... 10

B. Transmission Capital Maintenance: Aerial Inspection Maintenance ............ 11

VII. DISCUSSION / ANALYSIS OF SUBSTATIONS (SCE-02, VOL. 3) ............... 13

VIII. WITNESS QUALIFICATIONS – Y. LASKO ................................................... 14

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TRANSMISSION & DISTRIBUTION 1 CAPITAL EXPENDITURES PART 1 2

I. INTRODUCTION 3

This exhibit presents the analyses and recommendations of the Public 4

Advocates Office (Cal Advocates) regarding Southern California Edison Company’s 5

(SCE or Edison) forecasts of certain Transmission and Distribution (T&D) capital 6

expenditures for 2019, 2020 and Test Year (TY) 2021. 7

The chart below shows how SCE has subdivided T&D capital expenditures 8

into numerous parts. The chart also shows the cumulative amounts that SCE has 9

proposed spending for each part over the five-year period 2019 through 2023, as well 10

as the percentage of the total expenditures each part constitutes. 11

Figure 3-11 12 SCE’s T&D Capital Expenditure Request 13 CPUC Jurisdictional, 2019 – 2023 Forecast 14

(in Millions of Direct Nominal Dollars) 15

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1 Ex. SCE-2, Vol. 1, Pt. 1, p. 2.

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This exhibit examines SCE’s Exhibit SCE-02, Vol. 1, Parts 1 and 3, Vol. 2 and 1

Vol. 3, for which SCE has proposed expending $2.169 billion over the five-year 2

period, and are made up of the following categories: 3

• Distribution Infrastructure Replacement – capital expenditures 4

associated with transformers, switches, capacitors, automatic 5

reclosers, underground structures, cables and conductors. SCE is 6

requesting $858 million2 for distribution grid capital expenditures 7

over the 2019-2023 period. 8

• Meter Activities – capital expenditures used for safety and reliability 9

of the meter system. SCE is requesting $162 million3 for meter 10

activities capital expenditures over the 2019-2023 period. 11

• Transmission Grid – capital expenditures used to construct, operate, 12

inspect, and maintain the transmission grid and telecom network. 13

SCE is requesting $1,147 million4 for transmission grid capital 14

expenditures over the 2019-2023 period. 15

• Substations – capital expenditures used to support monitoring, 16

operating and protecting SCE's substation infrastructure. SCE is 17

requesting $2.022 billion for substation infrastructure capital 18

expenditures over the 2019-2023 period. 19

SCE’s proposals regarding its T&D capital expenditures associated with other 20

areas are addressed in Exhibits PAO-04 and PAO-05. 21

2 Ex. SCE-2, Vol. 1, Pt. 1, p. 3, Figure I-2. 3 Ex. SCE-2, Vol. 1, Pt. 3, p. 3, Figure I-2. 4 Ex. SCE-2, Vol. 2, p. 3, Figure I-2.

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II. SUMMARY OF RECOMMENDATIONS 1

The following summarizes the Public Advocates Office’s recommendations: 2

• The Public Advocates Office recommends the Commission approve $15 3 million for Transmission Aerial Inspection Maintenance for 2021 instead of 4 $27.315 million as requested by SCE. Should SCE find aerial inspection 5 maintenance costs to be above $15 million, Edison can request the 6 Commission to approve a memorandum account for aerial inspection 7 maintenance. 8

• The Public Advocates Office recommends the Commission adopt recorded 9 2016 Meter Engineering Routine Work capital expenditures of $13.5 10 million for 2019-2021 period on a yearly basis instead of $15.8 million as 11 requested by SCE. 12

Table 3-1 compares the Public Advocates Office’s and SCE’s 2019-2021 13

forecasts of T&D capital expenditures associated with Distribution Infrastructure 14

Replacement, Meter Activities, Transmission Grid and Substations. 15

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Table 3-1 1 T&D Capital Expenditures for 2019-2021 2

(In Thousands of Nominal Dollars) 3

Description Public Advocates Office Recommended

SCE Proposed5

2019 2020 2021 2019 2020 2021 Distribution Infrastructure Replacement

$304,910 $151,973 $120,630 $304,910 $151,973 $120,630

Meter Activities $25,877 $42,842 $29,548 $28,177 $45,142 $31,848 Transmission

Capital Maintenance $35,526 $36,507 $52,299

$35,526 $36,507 $64,614

Transmission Tower Corrosion

$8,001 $12,040 $30,039 $8,001 $12,040 $30,039

Telecommunication Capital Maintenance

$3,207 $3,239 $3,286 $3,207 $3,239 $3,286

Transmission Claims $3,344 $3,437 $3,511 $3,344 $3,437 $3,511 Transmission

Capital Line Rating Remediation

$129,385 $94,913 $133,414 $129,385 $94,913 $133,414

Transmission Emergency Equipment

$154 $158 $162 $154 $158 $162

Transmission Tools and Work Equipment

$1,306 $1,364 $1,393 $1,306 $1,364 $1,393

Substation $300,122 $316,033 $443,443 $300,122 $316,033 $443,443 Total $811,832 $662,506 $817,725 $814,132 $664,806 $832,340

III. GENERAL DISCUSSION 4

A. Background 5 This exhibit only discusses capital expenditures and does not specifically 6

address SCE’s capital additions. The distinction between the two is important. 7

Capital expenditures, as the term implies, reflect the capital dollars that SCE spends in 8

a given year. No consideration is given as to whether or not those expenditures result 9

in projects that are actually completed (and considered to be “used and useful”) 10

during the year. In contrast, capital additions reflect the dollar amount of projects that 11

are completed during a given year, regardless of when the expenditures actually took 12

5 Ex. SCE-02, Vol. 1, Pt. 1, SCE-02, Vol. 1, Pt. 3, SCE-02, Vol. 2, and SCE-02, Vol. 3.

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place. SCE has elected to present its testimony and workpapers using the 1

“expenditure” format. SCE’s Results of Operations (RO) computer model takes these 2

expenditures and converts them to capital additions using project completion dates 3

that are loaded into the model. To be consistent, Public Advocates Office has also 4

presented its discussions and recommendations using capital expenditures. Capital 5

expenditures that occur after the 2021 Test Year are not discussed in this exhibit. The 6

Public Advocates Office’s post-test year ratemaking proposals for 2022 and 2023 are 7

set forth in Exhibit PAO-17. 8

Capital expenditures, once they become plant additions, are cumulative in 9

nature. Expenditures made during one year are added to expenditures that were made 10

in previous years. Therefore, the Public Advocates Office must analyze all of the 11

proposed capital expenditures occurring from the end of the last recorded year (SCE 12

included 2018 recorded data in its exhibits and workpapers) through the end of the 13

Test Year (2021). 14

In order to eliminate estimating uncertainty, the Public Advocates Office 15

obtains additional years of recorded plant data whenever possible. In this GRC, the 16

Public Advocates Office was able to obtain recorded expenditures for 2019. 17

In its exhibits and workpapers, SCE has presented its capital expenditures in 18

direct nominal dollars. “Direct” dollars refers to the fact that SCE’s capital 19

expenditure estimates do not include various loadings, such as the capitalized portions 20

of Pensions and Benefits, Payroll Taxes, Injuries and Damages, Administrative and 21

General Expenses, etc. These various loadings are estimated separately and are 22

allocated to the various capital projects by the RO computer model. “Nominal” 23

dollars refers to the fact that SCE’s forecasts are presented with estimates keyed to the 24

year in which they occurred. For example, a 2020 capital expenditure will use 2020 25

dollars for its forecast, rather than presenting the estimate in constant dollars from a 26

prior year. Because the exhibits, workpapers, and the RO computer model are all set 27

up to use direct nominal dollars, the Public Advocates Office is presenting its analyses 28

and estimates in the same manner. 29

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Many of the capital projects analyzed in this exhibit are, in part or in whole, 1

allocated to the Federal Energy Regulatory Commission (FERC) jurisdiction. In 2

much of its testimony and workpapers, SCE discusses the total capital expenditures 3

for its projects – both CPUC and FERC jurisdiction. The RO computer model splits 4

off the FERC allocations, and the revenue requirement is derived using the CPUC 5

jurisdiction. The Public Advocates Office found this to be confusing at times; a large 6

capital expenditure may have no impact in this case if it is eventually allocated to 7

FERC. The Public Advocates Office requested that SCE remove all of the FERC 8

allocated expenditures from its forecast; both Figure 3-1 and Table 3-1 show only 9

CPUC jurisdiction expenditures. Continuing with that format, in this exhibit, all of 10

the analyses, recommendations, and adjustments are presented only in CPUC 11

jurisdiction dollars. 12

B. Capital Expenditures versus Capital Additions 13 This exhibit (as well as SCE’s exhibits) does not specifically address capital 14

additions. SCE’s capital exhibits and supporting workpapers (as well as its RO 15

computer model) are organized around capital expenditures. SCE’s capital witnesses 16

provide testimony regarding the magnitude of the direct capital dollars that are 17

estimated to be spent each year, not how much is actually being booked to plant. SCE 18

relies on its RO computer model to manipulate these direct capital expenditures and 19

calculate the corresponding capital additions. The Public Advocates Office has 20

studied SCE’s RO model, and finds that it properly calculates plant additions. 21

Therefore, the Public Advocates Office’s analyses and recommended direct capital 22

adjustments are also stated in terms of capital expenditures. 23

When analyzing data in this format, the impact of recommended adjustments to 24

capital expenditures may not show up in the year in which they are made. For 25

example, suppose a capital project is scheduled to begin construction in 2021, but is 26

not scheduled to be completed until 2023. If the Public Advocates Office was to 27

recommend an adjustment to the 2021 expenditures, there will not be a revenue 28

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requirement impact until 2023, when the project is completed, is booked to plant-in-1

service, and begins earning a return. 2

IV. DISCUSSION / ANALYSIS OF DISTRIBUTION 3 INFRASTRUCTURE REPLACEMENT (SCE-02, Vol. 1, Part 1) 4 SCE's distribution grid includes infrastructure such as transformers, switches, 5

capacitors, automatic reclosers, underground structures, cables, and conductors. 6

SCE's inspection and maintenance of the distribution grid allows components to 7

remain in service for decades, but in the long run, every component in the distribution 8

grid will wear out and need to be replaced.6 9

SCE forecasts $858 million in capital expenditures for 2019-2023 for 10

Distribution Grid Capital Expenditures.7 Table 3-2 summarizes Edison's forecast for 11

the 2019-2021 period and presents the actual 2018 recorded costs for comparison 12

purposes. 13

Table 3-2 14 Distribution Infrastructure Replacement Capital Activities 15

Recorded 2018 / Forecast 2019-2021 16 (in Thousands of Nominal Dollars) 17

Description 2018 actual recorded

2019 2020 2021

4 kV Cutovers $116,586 $48,326 $29,981 $9,982 4 kV Substation Eliminations $5,521 $6,054 $5,643 $3,288 Automatic Reclosers Replacement Program $1,248 $2,435 $2,448 $2,610 Cable Life Extension Program $31,258 $20,574 $0 $0 Cable-in-Conduit Replacement Program $50,723 $17,074 $13,866 $5,989 Capacitor Bank Replacement Program $19,386 $10,318 $5,302 $2,716 Overhead Conductor Program $181,503 $100,063 $34,992 $70,939 PCB Transformer Removal $2,533 $1,813 $1,883 $1,943 Underground Structure Replacements $56,730 $27,573 $21,771 $13,562 Underground Switch Replacements $9,714 $3,389 $3,520 $2,642 Worst Circuit Rehabilitation $118,299 $67,291 $32,566 $6,960 Totals $593,503 $304,910 $151,973 $120,630

Source: Ex. SCE-02, Vol. 1, Pt. 1, p. 5, Table II-1. 18

6 Ex. SCE-02, Vol. 1, Pt. 1, p. 4, lines 3-6. 7 Ex. SCE-02, Vol. 1, Pt. 1, p. 3, Figure I-2.

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The Public Advocates Office reviewed SCE's testimony, workpapers and data 1

request responses and does not oppose SCE's capital request for Distribution 2

Infrastructure Replacement. 3

V. DISCUSSION / ANALYSIS OF METER ACTIVITIES (SCE-02, Vol. 4 1, Part 3) 5

SCE's meter activities capital expenditures are "required for the safety and 6

reliability of the meter system, guards against the issues caused by technology 7

obsolescence, allows customers to receive timely billing, makes sure that all 8

customers pay their fair share for the electricity they use, and protects against the 9

safety issues caused by energy theft."8 10

A. Overview of SCE’s Request 11 SCE forecasts $162.167 million in capital expenditures for 2019-2023 for 12

Meter Activities. This includes $157.717 million for Meter Engineering and $4.450 13

million for Meter System Maintenance Design.9 Table 3-3 summarizes Edison's 14

forecast for the 2019-2021 period. 15

Table 3-310 16 Meter Activities Capital Cost 17

(in Thousands of Nominal Dollars) 18 Description 2019 2020 2021

Meter Engineering $27,327 $44,242 $30,948 Meter System Maintenance Design $850 $900 $900 Total $28,177 $45,142 $31,848

Source: Ex. SCE-02, Vol. 1, Pt. 3, p. 22, Figure II-10 and p. 27, Figure II-11. 19

B. Meter Engineering Routine Work 20 SCE's routine meter replacement forecast is based on the three-year average 21

from 2016-2018 and is a part of Meter Engineering activities. Edison states that 22

8 Ex. SCE-02, Vol. 1, Pt. 3, p. 4, lines 8-11. 9 Ex. SCE-2, Vol. 1, Pt. 3, p. 21, lines 11-13. 10 Ex. SCE-2, Vol. 1, Pt. 3, p. 22 Figure II-10 and p. 27 Figure II-11.

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"2014 and 2015 are not appropriate for inclusion in developing our forecast because 1

these years reflect costs SCE incurred when using many meters that were repaired by 2

the vendor under warranty. Now that most meters are no longer under warranty, costs 3

for these years are not representative of future needs."11 SCE spent $13.5 million in 4

2016, $21 million in 2017, and $13.1 million in 2018 for a three-year average of 5

$15.8 million.12 When queried to provide a detailed description behind the cost 6

drivers in 2017 in comparison to 2016 and 2018, SCE replied: 7

The increased 2017 spend was primarily due to SCE having purchased 8 additional inventory ahead of schedule due to a manufacturer that was 9 moving a major portion of its meter production to a new location and 10 that was experiencing challenges to provide SCE with meters. 11 However, while increased inventory purchases in 2017 reduced some of 12 the demand for meter purchases in 2018, SCE still recorded $13.1M in 13 2018 due to SCE's aging meter population falling out of warranty which 14 merited purchasing more meters.13 15 The Public Advocates Office finds that the supply chain disruption experienced 16

by SCE in 2017 to be an extraordinary event that is not related to ordinary company 17

activities. Furthermore, large purchases in 2017 reduced the needed demand in 2018 18

and therefore those numbers are not appropriate for inclusion in the forecast. The 19

Public Advocates Office recommends the Commission adopt recorded 2016 meter 20

engineering routine work capital expenditures of $13.5 million for 2019-2021 period 21

on a yearly basis. 22

11 Ex. SCE-2, Vol. 1, Pt. 3, p. 25, lines 18-21. 12 Ex. SCE-2, Vol. 1, Pt. 3, p. 25, footnote 16. 13 SCE response to data request PubAdv-SCE-083-YNL, Q.4.

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Table 3-4: The Public Advocates Office’s Recommended and SCE's proposed Meter 1 Engineering Capital Expenditures 2

(in Thousands of Nominal Dollars) 3

Description SCE Proposed Forecast14 Public Advocates Office Proposed

Work Activity 2019 2020 2021 2019 2020 2021 Routine Work $15,800 $15,800 $15,800 $13,500 $13,500 $13,500

Non-Routine Work $11,527 $28,442 $15,148 $11,527 $28,442 $15,148 Total Meter Eng. $27,327 $44,242 $30,948 $25,027 $41,942 $28,648

VI. DISCUSSION / ANALYSIS OF TRANSMISSION GRID (SCE-02, Vol. 2) 4

SCE's Business Planning Group (BPG) "includes the activities SCE performs 5

to inspect and maintain its transmission and telecommunication network. The 6

Transmission Grid BPG is comprised of two Business Planning Elements (BPEs): (1) 7

Transmission Inspections & Maintenance and (2) Capital Related Expense & 8

Other."15 9

A. Overview of SCE’s Request 10 SCE forecasts $1,147 million16 (in nominal dollars) in capital expenditures for 11

transmission grid capital expenditures for the 2019-2023 time period to construct, 12

operate, inspect, and maintain the transmission grid and telecommunication network. 13

Table 3-5 summarizes Edison's forecast for the 2019-2021 period. 14 Table 3-5 15

Transmission Grid Capital Expenditures 16 Forecast 2019-2021 (in Thousands of Nominal Dollars) 17 Description 2019 2020 2021

Transmission Capital Maintenance $35,526 $36,507 $64,614 Transmission Tower Corrosion $8,001 $12,040 $30,039 Telecommunication Capital Maintenance $3,207 $3,239 $3,286 Transmission Claims $3,344 $3,437 $3,511 Transmission Capital Line Rating Remediation $129,385 $94,913 $133,414 Transmission Emergency Equipment $154 $158 $162 Transmission Tools and Work Equipment $1,306 $1,364 $1,393

Source: Ex. SCE-02, Vol. 2, pp. 28, 31, 33, 35, 38, 43-44. 18

14 Ex. SCE-02, Vol. 1, Pt. 3, p. 25, Table II-4. 15 Ex. SCE-02, Vol. 2, p. 1, lines 6-9. 16 Ex. SCE-02, Vol. 2, p. 3, Figure I-2.

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B. Transmission Capital Maintenance: Aerial Inspection Maintenance 1 The Transmission Capital Maintenance is divided into four sub-activities. 2

Table 3-6 summarizes Edison's forecasts for the 2019-2021 period for these sub-3

activities. 4

Table 3-6 5 Transmission Capital Maintenance Sub-Activities 6

Forecast 2019-2021 (in Thousands of Nominal Dollars) 7 Sub Activity 2019 2020 2021

Ongoing Maintenance $31,549 $32,421 $33,125 Aerial Inspection Maintenance $0 $0 $27,315 Breakdown $2,920 $3,000 $3,065 Encroachments $1,057 $1,085 $1,109 Total $35,526 $36,506 $64,614

SCE is planning to add a new transmission aerial inspection program 8

that will drive incremental transmission capital maintenance expenditures 9

above historical levels in 2021. SCE’s testimony states: 10

When inspecting approximately 32,175 non-HFRA assets, SCE expects 11 to find maintenance items on 25% of these assets, leading to 8,044 12 notifications per year. SCE anticipates that 15% (or 1,207) of these 13 notifications will be for pole replacements. To avoid duplication and 14 account for notifications that may be identified to be replaced by SCE's 15 pole program, 30% of these expected notifications are removed. As a 16 result, SCE adjusts its forecast to 845 notifications.17 17

In response to a data request from the Public Advocates Office, SCE 18

states: 19

SCE's new aerial inspection program is part of its broader Enhanced 20 Overhead Inspection (EOI) initiative. SCE's EOI initiative was set forth 21 in SCE's 2019 Wildfire Mitigation Plan (WMP), which was approved 22 by the Commission in D.19-05-038. At the time of the filing of SCE's 23 2019 WMP, SCE had not yet begun aerial component of EOI. 24 However, SCE informed the Commission of this modification to the 25 EOI initiative in both AL 4031-E (currently suspended pending further 26 Commission Staff review) and AL-4120-E (preliminarily rejected 27

17 Ex. SCE-02, Vol. 2, p. 29, lines 14-18.

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without prejudice on unrelated grounds in the February 5, 2020 1 Proposed Decision [in R.18-10-007]. On February 26, 2020, SCE 2 submitted Comments on the PD advocating for approval of AL 4120-E, 3 and fully expects Commission approval of the two outstanding advice 4 letters.18 5

Because transmission aerial inspections are a brand-new program at SCE, 6

forecasts were developed using consultant and subject matter expert judgment. Aerial 7

inspections are quite different from traditional inspections, so no comparable 8

historical SCE data was available to use as a basis for SCE’s forecast. Likewise, the 9

find rate for pole replacements using aerial inspection was based on the judgment of 10

subject matter experts. Furthermore, the potential duplication of pole replacement 11

notifications was based on the judgment of subject matter experts.19 12

It is not clear whether the two advice letters will be approved and when. 13

Furthermore, due to lack of historical data the forecasts were largely made based on 14

subject matter expert judgment and are therefore subjective. Accordingly, the Public 15

Advocates Office recommends the Commission approve $15 million for Transmission 16

Aerial Inspection Maintenance for 2021 instead of $27.315 million as requested by 17

SCE. Should SCE find Aerial Inspection Maintenance costs to be above $15 million, 18

Edison can request the Commission to approve a memorandum account to track costs 19

for Aerial Inspection Maintenance. 20

18 SCE response to data request PubAdv-SCE-107-YNL, Q.1.a. 19 SCE response to data request PubAdv-SCE-107-YNL, Q.1.b-d.

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VII. DISCUSSION / ANALYSIS OF SUBSTATIONS (SCE-02, Vol. 3) 1

Edison is requesting “$1,970 million in nominal capital expenditures for 2019-2

2023 to support monitoring and operating SCE’s power systems, maintain substation 3

equipment and infrastructure, and perform other related activities.”20 Table 3-7 below 4

summarizes SCE’s request broken down by Business Planning Elements (BPE). 5

Table 3-7 6 Capital Activities by BPE 7

(in Thousands of Nominal Dollars) 8 Description 2019 2020 2021

Capital Related Expense & Other $32,281 $23,713 $31,804 Grid Monitoring & Operability $45,925 $46,141 $72,622 Infrastructure Replacement $166,044 $188,760 $280,057 Inspections & Maintenance $55,871 $57,419 $58,960 Totals $300,122 $316,033 $443,443

Source: Ex. SCE-02, Vol. 3, p. 4, Table I-2. 9

The Public Advocates Office reviewed SCE's testimony, workpapers and data 10

request responses and does not oppose SCE's request. 11

20 Ex. SCE-02, Vol. 3, p. 1, lines 18-20.

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VIII. WITNESS QUALIFICATIONS – Y. LASKO 1

My name is Yakov Lasko. My business address is 505 Van Ness Avenue, San 2

Francisco, California. I am employed by the Public Advocates Office as a Public 3

Utilities Regulatory Analyst IV in the Energy Cost of Service and Natural Gas 4

Branch. 5

I received a Bachelor of Arts Degree in Political Economy of Industrial 6

Societies from the University of California at Berkeley, and a Master’s Degree in 7

Corporate Finance from SDA Bocconi in Milan, Italy. 8

Since joining the Public Advocates Office in 2012, I worked in the Electric 9

Planning & Policy Branch from 2012-2016 and testified before the Commission on 10

Pacific Gas and Electric Company’s (PG&E) Energy Resource Recover Account 11

(ERRA) Compliance and the San Onofre Nuclear Generating Station Investigation 12

proceedings. I was the Public Advocates Office Project Coordinator for the PG&E 13

2014 and 2015 ERRA compliance proceedings, Application (A.) 15-02-023 and A.16-14

02-019, respectively. I prepared and submitted testimony in the joint SCE and San 15

Diego Gas & Electric Company (SDG&E) and the PG&E nuclear decommissioning 16

cost triennial proceedings, A.16-03-004 and A.16-03-006, respectively; SCE’s 2018 17

GRC proceeding, A.16-09-001; SDG&E Customer Information System Replacement 18

Program proceeding, A.17-04-027; Sempra 2019 GRC proceeding, A.17-10-007/008, 19

and PG&E 2020 GRC, A.18-12-009. The most recent cases I worked on were the 20

PacifiCorp and Liberty CalPeco cost of capital proceedings, A.18-04-002 and A.18-21

12-001, respectively. 22

This completes my prepared testimony. 23