BEFORE THE PUBLIC UTILITIES COMMISSION OF THE
STATE OF CALIFORNIA
Order Instituting Rulemaking on the Commission’s Proposed Policies Governing Restructuring California’s Electric Services Industry and Reforming Regulation.
________________________________________
Order Instituting Investigation on the Commission’s Proposed Policies Governing Restructuring California’s Electric Services Industry and Reforming Regulation.	)))))))))	Rulemaking 94-04-031
(Filed April 20, 1994)

Investigation 94-04-032
(Filed April 20, 1994)	
RESPONSE BY SOUTHERN CALIFORNIA EDISON COMPANY (U 338‑e) TO ADMINISTRATIVE LAW JUDGE’S RULING OF NOVEMBER 28, 2000
MEGAN SCOTT-KAKURES
JENNIFER M. TSAO

Attorneys for
SOUTHERN CALIFORNIA EDISON COMPANY
2244 Walnut Grove Avenue
Post Office Box 800
Rosemead, California  91770
Telephone:	(626) 302-6819
Facsimile:	(626) 302-2050
E-mail:	jennifer.tsao@sce.com
Dated:  December 11, 2000

BEFORE THE PUBLIC UTILITIES COMMISSION OF THE
STATE OF CALIFORNIA
Order Instituting Rulemaking on the Commission’s Proposed Policies Governing Restructuring California’s Electric Services Industry and Reforming Regulation.
________________________________________
Order Instituting Investigation on the Commission’s Proposed Policies Governing Restructuring California’s Electric Services Industry and Reforming Regulation.	)))))))))	Rulemaking 94-04-031
(Filed April 20, 1994)

Investigation 94-04-032
(Filed April 20, 1994)	
RESPONSE BY SOUTHERN CALIFORNIA EDISON COMPANY (U 338-e) TO ADMINISTRATIVE LAW JUDGE’S RULING OF NOVEMBER 28, 2000
I.	
INTRODUCTION
Southern California Edison Company (“SCE”) respectfully submits this Response to Administrative Law Judge’s Ruling, dated November 28, 2000 (the “ALJ Ruling”).  In the ALJ Ruling, the assigned ALJ requests additional comments from the parties on a number of issues.  SCE’s responses are stated below.
II.	
DISCUSSION
1.  Will the language change as proposed in the October 12, 2000 draft decision impact Pacific Gas and Electric Company’s (PG&E) bond financing agreements?  Will SCE’s proposed language change, as set forth at page 9 of its November 1, 2000 comments, impact the bond financing agreements of SDG&E and PG&E?
SCE will defer to PG&E and SDG&E to address issues relating to their own bond financing agreements.

2.  Should the draft decision be changed to allow only SDG&E to adopt a one-tiered payment system, while requiring SCE and PG&E to follow the two-tiered system as set forth in section P.(1)(b) of Appendix A of D.97-10-087, as modified by Ordering Paragraph 2 of D.98-02-030?
SCE only objects to the imposition of SDG&E’s proposed changes upon SCE.  SCE has no position on whether SDG&E should be allowed to have a different procedure for processing partial payments for its own direct access accounts.

3.  How will SCE’s proposed language change affect electric customers, the ESPs, and the UDCs?
SCE’s proposed language change was not aimed at substantially changing SDG&E’s proposed one-tiered system.  As the ALJ Ruling correctly points out, SCE opposes the one-tiered system as applied to SCE.  If, despite SCE’s objection, the one-tiered system is required for all UDCs, SCE has suggested language to clarify that there are other billed charges (including governmental taxes) that are included on a pro rata basis.  Further, Transfer Trust Amount (TTA) charges need to be recognized as a disconnectible charge.  Finally, SCE asks that it be entitled to send back (i.e. charge off) disputed ESP charges to the ESP so that the customer and the ESP can resolve any disputed charges between themselves.  This proposal would prevent SCE from having to manually track disputed ESP charges to prevent disconnection in error and avoid costly reprogramming for system enhancements.  The proposal would also allow the customer and the ESP to resolve issues without involvement of a third party as long as the customer notifies SCE to charge off the ESP charges.  SCE does not believe that any of its proposed language will adversely affect electric customers, ESPs or the UDCs.  

4.  Will SDG&E’s proposal, as set forth in the draft decision, or SCE’s proposed language change, lead to more customer disconnections if a customer fails to notify the UDC that only a partial payment is being made because of a billing dispute with the ESP?  That is, will the resulting pro rata allocation leave insufficient funds to cover the UDC charges for which delinquency may result in disconnection?
Yes.  SCE estimates that if SDG&E’s proposal is adopted for SCE, this may lead to more customer disconnections of approximately 3,600 per year.  In addition, there may be impacts to SCE cash flows of approximately $3.2 million and an additional write-off of $90,000 annually.

5.  What steps, if any, should be taken to minimize customer disconnections resulting from a scenario where a partial payment is made, but the customer fails to notify the UDC that the customer disputes the ESP charges?
If SCE is required to adopt the one-tiered system and if, under such system, a customer fails to notify SCE that it disputes the ESP charges, then SCE’s customer service system would automatically show the customer’s account as subject to disconnection.  This is consistent with our current process for notifying bundled customers of delinquency and potential disconnection.  To alter SCE’s current system process would require substantial system changes or manual processes.  SCE opposes any steps to minimize customer disconnections resulting from the one-tiered system that would require costly system enhancements or administrative expenses by SCE.  

6.  Should the Rule 22 working group be given an opportunity to discuss the changes proposed in SDG&E’s petition and in SCE’s comments to the draft decision before the Commission acts on SDG&E’s petition?
Yes.  If the Commission is inclined to require all three UDCs to follow the same procedures for processing partial payments, then SCE believes that the issues should be discussed in the Rule 22 working group, or other forum, before the Commission acts on SDG&E’s petition.
Respectfully submitted,

MEGAN SCOTT-KAKURES
JENNIFER M. TSAO

By:	Jennifer M. Tsao	
Attorneys for
SOUTHERN CALIFORNIA EDISON COMPANY
2244 Walnut Grove Avenue
Post Office Box 800
Rosemead, California  91770
Telephone:	(626) 302-6819
Facsimile:	(626) 302-2050
E-mail:	jennifer.tsao@sce.com
December 11, 2000

CERTIFICATE OF SERVICE
I hereby certify that, pursuant to the Commission’s Rules of Practice and Procedure, I have this day served a true copy of RESPONSE OF SOUTHERN CALIFORNIA EDISON COMPANY (U 338-E) TO ADMINISTRATIVE LAW JUDGE’S RULING OF NOVEMBER 28, 2000 on all parties identified on the attached service list.  Service was effected by means indicated below:
	Placing the copies in properly addressed sealed envelopes and depositing such envelopes in the United States mail with first‑class postage prepaid (Via First Class Mail);
	Placing the copies in sealed envelopes and causing such envelopes to be delivered by hand to the offices of each addressee (Via Courier);
	Transmitting the copies via facsimile, modem, or other electronic means (Via Electronic Means).
Executed this 11th day of  December, 2000, at Rosemead, California.
______________________________________________
Anthony V. Archer
Project Analyst
SOUTHERN CALIFORNIA EDISON COMPANY

2244 Walnut Grove Avenue
Post Office Box 800
Rosemead, California  91770

December 11, 2000
Docket Clerk
California Public Utilities Commission
505 Van Ness Avenue
San Francisco, California  94102
Re:  R.94-04-031/I.94-04-032
Dear Docket Clerk:
Enclosed for filing with the Commission are the original and five copies of the RESPONSE OF SOUTHERN CALIFORNIA EDISON COMPANY (U 338-E) TO ADMINISTRATIVE LAW JUDGE’S RULING OF NOVEMBER 28, 2000 in the above-referenced proceeding.
We request that a copy of this document be file-stamped and returned for our records.  A self-addressed, stamped envelope is enclosed for your convenience.
Your courtesy in this matter is appreciated.
Very truly yours,
Jennifer M. Tsao
JMT:scp:LW003686074
Enclosures
cc:	All Parties of Record in R.94-04-031/I.94-04-032
			ALJ Angela K. Minkin (via Overnight Mail)
			ALJ John S. Wong (via Overnight Mail)