Testimony Supporting Southern California Edison's ...€¦ · 20 entitled Testimony Supporting Southern California Edison’s Application A.20-04-010 as 21 identified in the Table

Application No.: A.20-04-010 Exhibit No.: SCE-01 Witnesses: K. Billapati

C. Cameron J. Nichols

(U 338-E)

Testimony Supporting Southern California Edison's Application A.20-04-010

Before the

Public Utilities Commission of the State of California

Rosemead, California July 16, 2020

SCE 01: Testimony Supporting Southern California Edison's Application A.20-04-010

Table Of Contents

Section Page Witness

-i-

I. INTRODUCTION .............................................................................................1 J. Nichols

A. Purpose ...................................................................................................1

B. Background ............................................................................................1

II. SCE’S RESPONSE TO CATALINA ENVIRONMENTAL ISSUES ..............................................................................................................4

A. SCE’s Need To Perform The Work Is Time-Sensitive And Ongoing..................................................................................................4

B. Activities Performed During The System-Wide Assessment ................5

C. Timely Response To Environmental Issues Should Not Be Disincentivized Due To Uncertainty Of Cost Recovery ........................6 C. Cameron

III. STANDARD PRACTICE U-27-W ...................................................................8

A. SCE’s Request Satisfies The Requirements Of Standard Practice U-27-W ....................................................................................8

1. The Need To Incur The Costs Is Not Under SCE’s Control .......................................................................................8 J. Nichols

a) Compliance With TSCA ................................................8

b) SCE Must Act Expeditiously Consistent With EPA Policy ............................................................9

2. The Costs Could Not Have Been Reasonably Foreseen In SCE’s Last General Rate Case ...............................9 C. Cameron

3. The Costs Will Occur Before SCE’s Next General Rate Case .................................................................................10

4. The Costs Are Of A Substantial Nature And Justify The Approval Of The Memorandum Account .........................10

5. The Proposed Memorandum Account Benefits Customers ................................................................................11 K. Billapati

IV. EFFECTIVE DATE .........................................................................................12 C. Cameron

SCE 01: Testimony Supporting Southern California Edison's Application A.20-04-010

Table Of Contents (Continued)

Section Page Witness

-ii-

A. SCE’s Requested Effective Date Is Reasonable ..................................12

1. SCE’s Original Requested Effective Date Is Consistent With Commission Policy .......................................12

2. SCE Followed Guidance From Water Division In Filing The Application .............................................................13

V. CONCLUSION ................................................................................................15

Appendix A Witness Qualifications

1

I. 1

INTRODUCTION 2

A. Purpose 3

In this proceeding, Southern California Edison (SCE) is requesting authority from the California 4

Public Utilities Commission (Commission) to establish a memorandum account to record and track costs 5

associated with SCE’s completion of a system-wide assessment of the Santa Catalina Island (Catalina) 6

water infrastructure. This testimony provides information on the following issues set forth in the 7

Scoping Memo for this proceeding: 8

1. Should the Commission authorize SCE to establish the memorandum account? 9

a. Does SCE meet the requirements for establishing a memorandum account in 10

Standard Practice U-27-W? 11

2. If the Commission authorizes the memorandum account, should it set January 28, 2020 as 12

the effective date? 13

The testimony establishes that SCE’s request for the memorandum account is reasonable and in 14

accordance with the Commission’s rules and precedent for establishing a memorandum account. 15

Section I.B provides pertinent background information regarding SCE’s Catalina water 16

infrastructure that will be included in the assessment. Section II discusses SCE’s response to Catalina 17

environmental issues to date and describes the scope of planned assessment activities. Section III 18

explains how the requested memorandum account meets the requirements of Standard Practice U-27-W 19

and the reasons supporting January 28, 2020 as the effective date for the memorandum account. 20

B. Background 21

SCE’s Catalina water operation is a Class C utility serving approximately 2,000 customer 22

accounts across the island. SCE acquired the Catalina water utility in 1962 and is the sole domestic 23

water purveyor on the island, providing potable water service to approximately 4,100 residents and one 24

million annual visitors. Most components of the Catalina water system were installed several decades 25

ago in the late 1960s. 26

2

In 1967, SCE installed the million-gallon tank (MGT) and the Two Harbors Pipeline, which 1

supplies drinking water from groundwater wells near the Middle Ranch Reservoir over nine miles to the 2

western part of the island via the MGT. The Two Harbors Pipeline is constructed of steel with an 3

interior coal tar enamel lining and an external coal tar wrap. The same coal tar lining was also used on 4

the interior of the MGT. In addition, SCE has identified other components of the Catalina water system 5

that contain coal tar in the interior lining and/or exterior wrap. At the time of installation, these coal tar 6

materials were commonly used in water systems to prevent corrosion of steel and iron. When used as an 7

external coating, the coal tar was often reinforced with fibrous wraps, often consisting of asbestos felt 8

material. 9

Although the use of coal tar was common industry practice and deemed safe at the time 10

Catalina’s water infrastructure was installed, these materials are now known to possibly contain non-11

liquid polychlorinated biphenyls (PCBs) in concentrations that have since become regulated by the U.S. 12

Environmental Protection Agency (EPA) under the Toxic Substances Control Act (TSCA).1 TSCA was 13

passed in 1976 to, among other things, regulate the manufacture, distribution, use, storage, and disposal 14

of PCBs. Under TSCA, certain materials containing PCBs that were once approved for use have since 15

become prohibited. Once such materials are removed from use, TSCA and EPA’s regulations 16

implementing TSCA establish requirements and restrictions related to the storage and disposal of PCB 17

wastes. 18

SCE’s water infrastructure includes approximately 47 miles of distribution pipeline, discrete 19

segments of which were taken out of service over the years as part of routine repairs and maintenance. 20

In some cases, the decommissioned pipe included coal tar materials in the interior lining and/or exterior 21

wrap. At times, when the individual segments of decommissioned pipe were taken out of service, they 22

were left in-place (either above-ground or below-ground) at various locations across Catalina, including 23

near the Two Harbors Pipeline. In December 2019, SCE identified a potential TSCA violation due to the 24

possible presence of PCBs in coal tar materials on segments of decommissioned pipe. Subsequent 25

1 50 parts per million is the threshold concentration for PCB regulation under TSCA.

3

sampling confirmed the presence of PCBs above 50 parts per million (ppm) in certain segments of 1

above-ground decommissioned pipe. SCE then initiated efforts to fully identify, assess, and properly 2

dispose of all decommissioned pipe segments and to remediate any potential soil contamination in 3

compliance with all state and federal environmental regulations. 4

Due to the rugged, mountainous terrain on Catalina, SCE has not been able to confirm the full 5

extent of below-ground decommissioned pipe on the island. As part of SCE’s corrective actions to 6

achieve compliance, a comprehensive assessment of the water infrastructure on Catalina must be 7

completed. One objective of the system-wide assessment is to identify all decommissioned pipe 8

containing PCBs on the island.2 The information obtained from the assessment is necessary to determine 9

what additional corrective actions are required for SCE to achieve full compliance with TSCA PCB 10

regulations. 11

2 The system-wide assessment also includes in-service pipeline, as discussed in Section II.B.

4

II. 1

SCE’S RESPONSE TO CATALINA ENVIRONMENTAL ISSUES 2

A. SCE’s Need To Perform The Work Is Time-Sensitive And Ongoing 3

Much of the Catalina water system infrastructure was installed prior to the enactment of TSCA 4

utilizing materials that were authorized at the time, including coal tar materials containing PCBs at 5

concentrations greater than 50 ppm. Once it is removed from service, that material is then considered 6

PCB waste and governed by TSCA’s implementing regulations at 40 C.F.R. Part 761, Subpart D, which 7

impose restrictions on time, location, and conditions for storage and disposal. Therefore, on December 8

13, 2019, SCE submitted to the EPA a voluntary disclosure regarding potential violations of TSCA PCB 9

regulations related to the decommissioned pipe. 10

SCE submitted its voluntary disclosure pursuant to the EPA’s policy on “Incentives for Self-11

Policing: Discovery, Disclosure, Correction and Prevention of Violations” (commonly referred to as the 12

“Audit Policy”). Under the Audit Policy, violations must be corrected within 60 calendar days from the 13

date of discovery, or as expeditiously as possible. In this case, the discovery date was December 12, 14

2019, which required SCE to achieve compliance by February 11, 2020. Accordingly, SCE immediately 15

took steps to begin identification, sampling, and disposal of decommissioned pipe on Catalina. 16

SCE made significant progress on its corrective actions within the 60-day compliance period. 17

This included initial field surveys, visual inspections and sampling of decommissioned pipe segments, 18

and the removal of above-ground decommissioned pipe. While SCE worked diligently and expeditiously 19

to achieve compliance, it was unable to complete all necessary corrective actions by February 11, 2020. 20

Therefore, SCE requested a 30-day extension of its compliance deadline via the EPA’s eDisclosure 21

system. On March 2, 2020, for the reasons documented in a February 28, 2020 letter, SCE then 22

requested that the EPA grant an additional extension of nine months (until December 11, 2020) to allow 23

for the implementation of further corrective actions.3 24

3 See WPS-SCE-01, pp. 31-37 for SCE’s February 28, 2020 letter justifying the March 2, 2020 extension

request.

5

In its February 28 letter, SCE described specific corrective actions, including the system-wide 1

assessment to identify and characterize pipe, it would complete by year-end 2020. Therefore, SCE must 2

continue to work towards achieving full compliance in a timely manner. 3

B. Activities Performed During The System-Wide Assessment 4

As discussed above, SCE initiated a system-wide assessment as part of its efforts to achieve 5

compliance with TSCA PCB regulations. The assessment is necessary to identify remaining 6

decommissioned pipe (including partially and fully buried segments) and in-service pipeline containing 7

PCBs on the island. To perform the assessment, SCE is relying on a combination of operational 8

knowledge, desktop review of readily available as-built maps, reports and documents, and confirmatory 9

field surveys. 10

In February and March 2020, SCE performed a desktop review of available documentation and 11

then field-verified decommissioned pipe locations, sizes, and materials utilizing iPads and GPS 12

hardware. The data collected, which included maps and photo documentation, was compiled in a 13

spreadsheet and Geographic Information System (GIS) layer and was subsequently reviewed to identify 14

potential sampling locations. 15

In June 2020, SCE performed sampling of the identified segments in order to determine the 16

presence and concentration of PCBs in the below-ground decommissioned pipe. Samples of the interior 17

lining and exterior wrap were collected at over 40 locations where the pipe was readily accessible 18

without the need for potholing. The sample results at these locations indicated approximately five miles 19

of below-ground decommissioned pipe is TSCA-regulated waste (i.e., PCBs were present above 50 20

ppm). Based on these findings, SCE is still evaluating whether further pipe sampling is warranted. In 21

addition, SCE will need to perform soil sampling for those locations where PCBs were detected in the 22

decommissioned pipe to determine if PCBs have migrated from the pipe into adjacent soils. Obtaining 23

additional samples of the pipe lining and wrap may require potholing activities (i.e., using hand tools to 24

dig an approximate excavation three feet wide by three feet long) to expose the buried pipe. The soil 25

disturbance associated with the potholing and soil sampling may require Los Angeles Department of 26

Regional Planning (LADRP) permitting, which could involve a lengthier process for pipe located in 27

6

sensitive ecological areas. These characterization efforts will continue through the balance of 2020. 1

Once the system-wide assessment is complete, SCE will initiate further discussions with the EPA and 2

other stakeholders regarding disposition of the below-ground decommissioned pipe. SCE anticipates 3

these discussions would address whether abandonment in place is appropriate for any of the pipe 4

segments. 5

In addition to the decommissioned pipe, the system-wide assessment will also identify and 6

characterize in-service distribution pipeline. Similar to the efforts described above for decommissioned 7

pipe, SCE performed a desktop review of available documentation followed by field verification. The 8

activities to locate the pipe and collect samples are similar to those described above with certain notable 9

differences. To confirm the presence or absence of PCBs on in-service pipeline interior linings, samples 10

had to be collected while the line was still operational. To accomplish this, a tapping machine was used 11

to collect a coupon from the pipeline. The coupon could then be analyzed to determine if either the 12

interior lining or exterior wrap contained PCBs. Sampling of the in-service pipeline is still in progress 13

and may require LADRP permitting for any potholing activities. Once analytical results are available for 14

the in-service pipeline materials, SCE will determine the need to perform soil sampling for those 15

locations where PCBs were detected. These efforts will continue through the balance of 2020 as SCE 16

conducts the assessment and characterization activities across the system. 17

C. Timely Response To Environmental Issues Should Not Be Disincentivized Due To 18

Uncertainty Of Cost Recovery 19

Memorandum accounts provide utilities a mechanism to track and record costs for unforeseen 20

events for potential future recovery. Absent a memorandum account, utilities would be precluded from 21

recovering unanticipated, though reasonably incurred costs due to the retroactive ratemaking 22

prohibition. An example of this concept is the Catastrophic Event Memorandum Account (CEMA). The 23

original resolution authorizing utilities to establish CEMAs was issued following the Loma Prieta 24

earthquake when utilities incurred considerable costs to immediately make repairs and restore service to 25

customers following the disaster. The Commission wanted to provide utilities the “maximum incentive 26

7

to restore service immediately and completely after declared disasters.”4 While not related to a declared 1

disaster as with CEMA, responding to environmental issues in a timely manner is in the public interest 2

and utilities should be provided a similar incentive to address such issues. In the current circumstances, 3

SCE is incentivized to act in a timely manner consistent with the EPA’s Audit Policy as discussed in 4

Section II.A. SCE should not be disincentivized to respond to the present issue in a timely manner due to 5

uncertainty of cost recovery. Additionally, with memorandum accounts there is no presumption of 6

recovery and any costs recorded in the account are subject to a reasonableness review and approval by 7

the Commission. 8

4 Resolution E-3238 at p.2.

8

III. 1

STANDARD PRACTICE U-27-W 2

A. SCE’s Request Satisfies The Requirements Of Standard Practice U-27-W 3

The criteria for establishing a memorandum account is provided in Standard Practice U-27-W 4

Processing Rate Offsets and Establishing and Amortizing Memorandum Accounts. Standard Practice U-5

27-W requires that in order to qualify for memorandum account treatment, costs must be due to events 6

of an exceptional nature that: 7

1. Are not under the utility’s control, 8

2. Could not have been reasonably foreseen in the utility’s last general rate case, 9

3. And that will occur before the utility’s next scheduled general rate case, 10

4. Are of a substantial nature such that the amount of money involved is worth the effort of 11

processing a memorandum account, and 12

5. Have ratepayer benefits. 13

SCE’s request to establish the memorandum account satisfies the five-prong criteria outlined in 14

Standard Practice U-27-W, as discussed in the following sections. 15

1. The Need To Incur The Costs Is Not Under SCE’s Control 16

a) Compliance With TSCA 17

As discussed above, TSCA and the EPA’s implementing regulations establish 18

requirements and restrictions related to the storage and disposal of PCB wastes. Once PCB waste is 19

generated, it must be handled in a manner that complies with EPA regulations. Under EPA regulations, 20

PCB waste generally must be disposed of within one year of the date it became waste.5 The regulations 21

specify that a PCB item becomes waste “on the date of removal from service.”6 Because SCE identified 22

a potential TSCA violation related to the decommissioned pipe segments, SCE must now complete the 23

5 40 CFR § 761.65.

6 Id.

9

system-wide assessment in order to disposition the waste in compliance with applicable laws and 1

regulations. 2

b) SCE Must Act Expeditiously Consistent With EPA Policy 3

The EPA’s Audit Policy encourages regulated entities to voluntarily discover, 4

promptly disclose, and expeditiously correct violations of Federal environmental requirements. Entities 5

that make disclosures and expeditiously begin to take corrective action under the terms of the Audit 6

Policy benefit from reductions in the amount of potential civil penalties. Accordingly, on December 13, 7

2019, SCE submitted to the EPA a disclosure related to the potential violation of TSCA regulations 8

resulting from its handling of decommissioned pipe containing PCB materials. 9

The EPA expects a regulated entity to “do its utmost to achieve or return to 10

compliance as expeditiously as possible.”7 Consistent with this directive, following submittal of its 11

disclosure, SCE immediately began takings steps to identify and properly dispose of the 12

decommissioned pipe on Catalina. Although it was initially required to achieve full compliance by 13

February 11, 2020, SCE requested from the EPA an extension until December 11, 2020 to perform 14

additional corrective actions.8 15

2. The Costs Could Not Have Been Reasonably Foreseen In SCE’s Last General Rate 16

Case 17

SCE filed its last Catalina Water general rate case (GRC) application in November, 2010, 18

with a proposed 2011 test year (2011 Water GRC).9 This filing was made nearly a decade before SCE 19

identified the present issue regarding the potential violation of TSCA regulations resulting from its 20

handling of PCB-containing decommissioned pipe on Catalina. It is common for utilities to include a 21

five-year forecast of expenditures when filing a general rate case application. The 2011 Water GRC did 22

not include a five-year forecast or an attrition mechanism, only a test year 2011 forecast. Even if SCE 23

had included a five-year forecast of expenditures, SCE could not have reasonably foreseen the 24

7 65 FR 19618, 19622 (April 11, 2000).

8 See WPS-SCE-01, pp. 31-37 for SCE’s February 28, 2020 letter describing the additional corrective actions.

9 A.10-11-009 was filed on November 15, 2010.

10

immediate issue as it was not identified until December 2019. Therefore, it is evident that the costs for 1

the system-wide assessment could not have been reasonably foreseen in the 2011 Water GRC. 2

3. The Costs Will Occur Before SCE’s Next General Rate Case 3

As a Class C water utility, SCE is not subject to a rate case plan or a predetermined GRC 4

filing schedule. SCE is currently planning to file its next Catalina Water GRC in 2020, with the timing 5

of that application still being evaluated. SCE’s prior GRC took nearly four years to resolve.10 Given the 6

time-sensitive and ongoing nature of the work being performed for the system-wide assessment as 7

discussed in Section II.A, SCE will incur costs before its next GRC application is filed and a decision 8

authorizing the work is issued. Indeed, SCE has already started incurring costs to perform the system-9

wide assessment. SCE will continue to incur costs prior to the next Catalina Water GRC application to 10

complete the system-wide assessment and to satisfy the EPA compliance deadline of December 11, 11

2020. 12

Furthermore, costs incurred in 2020 (in advance of the GRC) are necessary to inform 13

remediation requirements and their associated costs. 14

4. The Costs Are Of A Substantial Nature And Justify The Approval Of The 15

Memorandum Account 16

The current authorized revenue requirement for the Catalina Water Utility is $4.130 17

million.11 SCE currently estimates the cost to perform the system-wide assessment at $0.9 million, or 18

approximately 22 percent of the current authorized revenue requirement, as shown in Table III-1 below. 19

10 D.14-10-048 was issued on October 20, 2014.

11 D.14-10-048, Appendix A.

11

Table III-1 Catalina System-Wide Assessment Project Costs

(2020 $, in millions)

The system-wide assessment costs include both decommissioned pipe and in-service 1

pipeline. The activities to identify and characterize decommissioned pipe and in-service pipeline are 2

similar in nature and economy of scale is realized by performing the assessment activities concurrently. 3

While a relatively small amount compared to expenses routinely incurred for SCE’s electric utility, the 4

estimated costs to perform the system-wide assessment are significant when viewed in the context of 5

SCE’s Catalina water utility. It is plainly evident that costs amounting to nearly one-fourth the 6

authorized revenue requirement constitute costs that are substantial in nature and justify the approval of 7

SCE’s memorandum account request. 8

5. The Proposed Memorandum Account Benefits Customers 9

Conducting the system-wide assessment allows SCE to properly catalogue the Catalina 10

water system infrastructure by identifying in-service distribution pipeline and decommissioned pipe 11

locations (mapped with latitude/longitude GIS layers), lengths, diameters, and composition (including 12

any hazardous materials). This information will enable SCE to accurately and efficiently characterize 13

waste, thereby potentially avoiding the higher removal and disposal costs that would be incurred by 14

merely assuming all pipe contains hazardous materials. 15

In addition, the desktop review and field verification of existing drawings will improve 16

SCE’s water facilities documentation and mapping data. GIS layering benefits the entire water system as 17

the data is combined with other terrestrial layering including environmentally sensitive areas, location 18

boundaries, and property ownership to improve recordkeeping. The updated map data and improved 19

facilities documentation will support asset management programs and improved efficiency of utility 20

operations requiring pipeline location and identification (such as repair and maintenance activities). 21

Item No. Description Estimated Cost1. Engineering $0.602. Environmental $0.203. Contingency $0.104. Total $0.90

12

IV. 1

EFFECTIVE DATE 2

A. SCE’s Requested Effective Date Is Reasonable 3

1. SCE’s Original Requested Effective Date Is Consistent With Commission Policy 4

General Order 96-B, Water Industry Rule 7.2(2) states: “Upon request and justification 5

by the Utility, Staff may allow a Tier 2 advice letter to be made effective, subject to refund, in less than 6

30 days.” SCE submitted Advice Letter (Advice) 116-W on January 28, 2020, requesting that the advice 7

letter be effective upon submittal, subject to a 30-day review by Water Division pursuant to Water 8

Industry Rule 7.2(2). Additionally, Public Utilities Code Section 1731(a) states that “The [C]ommission 9

shall set an effective date when issuing an order or decision. The [C]ommission may set the effective 10

date of an order or decision before the date of issuance of the order or decision.” There are several 11

examples of the Commission citing this provision when setting an effective date pre-dating its final 12

decision.12 The Commission’s approval of an effective date before the final decision is particularly 13

warranted when a utility must incur costs to meet regulatory requirements prior to the Commission’s 14

final decision on cost recovery of those costs. In Decision (D.) 19-09-026, for example, the Commission 15

authorized SCE, Pacific Gas & Electric Company, San Diego Gas & Electric Company, and Southern 16

California Gas Company to establish memorandum accounts to track and record costs associated with 17

complying consumer privacy protections under the newly enacted California Consumer Privacy Act of 18

2018, with an effective date prior to the Commission’s final decision approving the memorandum 19

account.13 The same type of situation exists here, as SCE must perform the system-wide assessment and 20

incur costs prior to a final decision in this pending Application, so that SCE can timely proceed with any 21

required environmental remediation activities and comply with regulatory requirements. 22

12 D.19-09-026, p. 10; D.18-11-051, p. 8; D.18-06-029, pp. 11-15; D.19-01-019, pp. 6-8, 10.

13 See, e.g. D.19-09-026, p. 10 (authorizing SCE, Pacific Gas & Electric Company, San Diego Gas & Electric Company, and Southern California Gas Company to establish memorandum accounts to track and record costs associated with complying consumer privacy protections under the newly enacted California Consumer Privacy Act of 2018, with an effective date prior to the Commission’s final decision on cost recovery).

13

2. SCE Followed Guidance From Water Division In Filing The Application 1

SCE should not lose the benefit of its original advice letter submittal and requested 2

effective date of January 28, 2020. As described in Advice 116-W (submitted on January 28, 2020), 3

SCE originally requested a memorandum account to track and record costs to identify, assess, remove 4

and dispose of above- and below-ground decommissioned pipe on Catalina.14

Advice 116-W requested a 5

Catalina Water Utility Hazardous Substances Memorandum Account to track and record costs to fully 6

identify, assess, remove, and dispose of decommissioned pipe containing PCBs and to remediate any 7

associated soil contamination. Including removal and disposal costs in the original request significantly 8

increased the estimated costs to be recorded in the proposed memorandum account. As stated in Section 9

III.A.5, performing the current system-wide assessment may allow SCE to characterize certain 10

decommissioned pipe segments as non-hazardous, potentially decreasing the estimated project costs. An 11

updated estimate of decommissioned pipe removal and disposal costs will be prepared following 12

completion of the system-wide assessment and characterization work. 13

On February 26, 2020, Water Division issued a Suspension Notice for Advice 116-W. In 14

the email from Water Division accompanying the Suspension Notice, Water Division recommended that 15

“the project and memorandum account request be reviewed through a formal application.”15 Water 16

Division further recommended that the proposed environmental remediation project (including removal 17

and disposal) and memorandum account request be included in SCE’s upcoming general rate case filing. 18

While Water Division’s recommendation pointed to a general rate case based on SCE’s plan to file in 19

2020, the principal thrust of its guidance was for SCE to request the memorandum account through a 20

formal application, GRC or other mechanism. In response to the feedback received from Water 21

Division, SCE narrowed the scope of the memorandum account request only to include system-wide 22

assessment related activities required to be performed in 2020 to meet the EPA compliance deadline and 23

resubmitted the request via the present application. These system-wide assessment activities are a subset 24

14 See WPS-SCE-01, pp. 1-18 for Advice Letter 116-W.

15 See WPS-SCE-01, p. 19 for Water Division Email Suspending Advice 116-W.

14

of the scope for which a memorandum account was originally sought in Advice 116-W. SCE plans to 1

file a general rate case in 2020; however, the time-sensitive nature of the system-wide assessment work 2

indicated a separate application be filed requesting authority to establish the memorandum account. 3

Because SCE has followed the guidance provided by Water Division and reasonably narrowed its 4

requests, SCE should not lose the benefit of the effective date of January 28, 2020, as requested in 5

Advice 116-W. 6

15

V. 1

CONCLUSION 2

For the reasons explained above, the Commission should approve SCE’s request to establish the 3

Catalina memorandum account, with an effective date of January 28, 2020.4

Appendix A

Witness Qualifications

A-1

SOUTHERN CALIFORNIA EDISON COMPANY 1

QUALIFICATIONS AND PREPARED TESTIMONY 2

OF KISHORE BILLAPATI 3

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

A. My name is Kishore Billapati, and my business address is 1515 Walnut Grove Avenue, 5

Rosemead, California 91770. 6

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

A. Currently, I manage the Asset Management & Generation Strategy department in the Generation 8

organization. I am responsible for managing the Asset Management program in Generation. 9

Among other responsibilities, I oversee asset assessment, asset condition monitoring, asset 10

information improvement and risk assessment programs. 11

Q. Briefly describe your educational and professional background. 12

A. I have Masters’ degrees in Chemical & Biochemical Engineering and Business Administration. 13

Prior to joining Southern California Edison in 2009, I worked for four years in two different 14

Engineering firms in the environmental compliance space. In Southern California Edison, I held 15

positions of Technical Specialist, Senior Technical Specialist, Senior Project Manager, 16

Engineering Manager, Senior Manager and Principal Manager. My work has been focused on 17

environmental compliance, asset optimization, maintenance strategies, condition monitoring, 18

asset health assessment and risk assessment. 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 portions of Exhibit SCE-01, 21

entitled Testimony Supporting Southern California Edison’s Application A.20-04-010 as 22

identified in the Table of Contents thereto. 23

Q. Was this material prepared by you or under your supervision? 24

A-2

A. Yes, it was. 1

Q. Insofar as this material is factual in nature, do you believe it to be correct? 2

A. Yes, I do. 3

Q. Insofar as this material is in the nature of opinion or judgment, does it represent your best 4

judgment? 5

A. Yes, it does. 6

Q. Does this conclude your qualifications and prepared testimony? 7

A. Yes, it does. 8

A-3



OF COOPER L. CAMERON 3


A. My name is Cooper L. Cameron, and my business address is 8631 Rush Street, Rosemead, 5

California 91770. 6


A. Currently, I am an Advisor in the Regulatory Affairs organization. I am responsible for various 8

cost recovery and other regulatory proceedings for SCE’s water, gas, and electric utilities. Prior 9

to my current position, I was Supervisor of SCE’s Water and Gas department on Catalina Island, 10

overseeing the operation and maintenance of the water and gas distribution systems. 11


A. I graduated from the University of Puget Sound with a Bachelor of Arts degree in Business, 13

including coursework in economics and law. I joined SCE in 2010 as a Technical Specialist 14

supporting the water, gas, and electric utility operations on Catalina Island. My responsibilities 15

included operational and technical support, including preparation of various compliance reports. 16

In 2014, I was promoted to Supervisor of SCE’s Water and Gas department on Catalina Island. 17

My responsibilities included overseeing the daily operations and maintenance of the water and 18

gas distribution systems, as well as various related tasks including regulatory compliance, service 19

planning, and project management. I have been in my current position since April 2018. 20





A-4


A. Yes, it was. 2


A. Yes, I do. 4


judgment? 6

A. Yes, it does. 7


A. Yes, it does. 9

A-5



OF JOSHUA L. NICHOLS 3


A. My name is Joshua L. Nichols, and my business address is 2244 Walnut Grove Ave, Rosemead, 5

CA 91770. 6


A. Currently, I am a Principal Manager in the Environmental Services Department. I am 8

responsible for leading the development, implementation and monitoring of environmental 9

compliance programs related to hazardous materials, hazardous waste, air quality, site 10

assessment and remediation for the Company. 11


A. I received my Bachelor of Environmental Studies from the University of Kansas in 2003, and a 13

Masters of Environmental Management from Duke University in 2015. In 2005 joined the 14

Southern California Edison Environmental Affairs Department as a Technical Specialist focused 15

on hazardous waste management. I was promoted to Sr. Manager of the Hazardous Materials 16

Section in 2010 and to my current role as Principal Manager in 2016. 17






A. Yes, it was. 23

A-6


A. Yes, I do. 2


judgment? 4

A. Yes, it does. 5


A. Yes, it does. 7

Documents

Testimony Supporting Southern California Edison's ...€¦ · 20 entitled Testimony Supporting Southern California Edison’s Application A.20-04-010 as 21 identified in the Table