Application No.: A.19-08-013 Exhibit No.: SCE-13, Vol. 01, Part 1 Witnesses: R. Tucker

(U 338-E)

2021 General Rate Case Rebuttal Testimony

Distribution Infrastructure Replacement

Before the

Public Utilities Commission of the State of California

Rosemead, California June 12, 2020

SCE-13, Vol. 01, Part 1: Distribution Infrastructure Replacement

Table Of Contents

Section Page Witness

-i-

I.  INTRODUCTION .............................................................................................1 R. Tucker 

A.  Summary of Rebuttal Position ...............................................................2 

1.  Capital Expenditure Summary ...................................................3 

II.  BUSINESS PLANNING ELEMENT/GRC ACTIVITY ..................................5 

A.  Capital Expenditures ..............................................................................5 

1.  SCE’s Application .....................................................................5 

B.  Non-Financial Proposals and Clarifications ..........................................5 

1.  The Commission Should Reject CUE’s Recommendation that SCE Develop a Ten-Year Distribution IR Plan ...................................................................5 

a)  CUE’s Position ..............................................................5 

b)  SCE’s Rebuttal to CUE’s Position .................................6 

(1)  Steady State Replacement Rates ........................6 

(2)  A Ten-Year Infrastructure Replacement Plan ...............................................7 

(3)  Resource Constraints .........................................9 

2.  CUE’s Statements Regarding Certain Wildfires Are Not Supported by the Existing Record ......................................9 

III.  CONCLUSION ................................................................................................11 

Appendix A SCE-13 Vol. 01, Part 1 Data Request Responses 

1

I. 1

INTRODUCTION 2

In this volume, Southern California Edison (SCE) provides additional support for its capital 3

expenditures forecast for Distribution Infrastructure Replacement (IR) activities managed primarily by 4

the Transmission and Distribution (T&D) organization. If approved, this funding request will allow SCE 5

to complete necessary replacements of distribution infrastructure so that SCE will be able to continue 6

providing safe, reliable, affordable and clean power to customers. 7

There are ten different activities that make up the Distribution IR program. Five of the activities 8

– Worst Circuit Rehabilitation (WCR), Cable-In-Conduit (CIC) Replacement, Underground (UG) 9

Switch Replacement, Underground (UG) Structure Replacement, and Cable Life Extension (CLE) – 10

focus on underground infrastructure. One activity – the Overhead Conductor Program (OCP) – focuses 11

on overhead infrastructure. The remaining four activities – the Capacitor Bank Replacement, 12

Distribution Automatic Recloser, 4kV Cutover and Substation Elimination, and PCB-contaminated 13

Transformer Removal Programs – focus on infrastructure that exists in both overhead and underground 14

configurations.1 15

This rebuttal testimony addresses recommendations raised by the Coalition of California Utility 16

Employees (CUE). CUE did not oppose SCE’s GRC request for Distribution IR but did provide 17

recommendations related to long-term Distribution IR planning. Cal Advocates did not oppose SCE’s 18

GRC request for Distribution IR and The Utility Reform Network (TURN) did not comment on SCE’s 19

GRC request for Distribution IR. SCE’s GRC request for Distribution IR in years 2019-2023 is $858 20

million, and SCE’s unconstrained need for 2019-2023 is $2,282 million.2 SCE notes that the reductions 21

between the unconstrained need and the GRC request should be considered temporary in nature. These 22

near-term deferments in Distribution IR activities do not mean that the fundamental issues associated 23

with SCE’s aging infrastructure have changed. These deferments may cause an increase in the average 24

age of SCE’s distribution infrastructure and in-service failure rates. Going forward, as wildfire 25

prevention-related work stabilizes and more resources become available, SCE expects to increase 26

1 Exhibit SCE-02 Vol. 1., Part 1, p. 16, line 1-15.

2 The term unconstrained need refers to the estimated amount that SCE would have otherwise requested in this GRC, if not for wildfire risk mitigation efforts. See Exhibit SCE-02 Vol.1, Part 1, p. 14, Table II-3.

2

Distribution IR activities to compensate for the longer-term effects of these near-term deferments.3 In 1

Policy Exhibit SCE-01, Vol.1, SCE explains there are not enough available resources to implement the 2

scope of both the grid hardening and Distribution IR at the levels that SCE would otherwise propose.4 3

SCE’s capital request of $638.521 million in capital expenditure forecasts for 2019-2021 4

requested in SCE-02 Vol.1 Part 1 Distribution IR activities included the presentation of ample evidence 5

demonstrating the reasonableness of SCE’s request and was unopposed by intervenors. Therefore, 6

SCE’s request for Distribution IR should be adopted. Although testimony submitted by Robert Earle on 7

behalf of The Coalition of California Utility Employees (CUE) supports SCE’s Application “and 8

understands that there may be limitations in what SCE can accomplish,”5 it proposes the Commission 9

require SCE to develop long-term Distribution IR plans beyond this GRC.6 10

A. Summary Of Rebuttal Position 11

The forecasts for SCE-02 Vol.1 Part 1 Distribution IR capital expenditures, made by SCE, Cal 12

Advocates, and TURN are shown in the following tables. Table I-1 provides a summary of Distribution 13

IR 2019 to 2021 capital expenditure forecast by SCE, Cal Advocates, TURN and CUE. 14

Table I-1 Distribution Infrastructure Replacement Capital Expenditures 2019-2021 Forecast

Summary of SCE, Cal Advocates, TURN and CUE’s Position (Nominal $000)

Table I-2 provides the recorded amounts for 2014-2019 and the forecast amounts for 2020-2021 15

for Distribution IR for SCE. 16

3 Exhibit SCE-02 Vol. 1 Pt. 1, p. 14, lines 11-17.

4 Exhibit SCE-01 Vol. 1 p. 9, lines 6-12.

5 Exhibit CUE-01, p. 4, lines, 10-11.

6 Exhibit CUE-01, p. 4.

SCECal

Advocates TURN CUECal

Advocates TURN CUEDistribution Infrastructure Replacement 577,513 577,513 N/A N/A - - - 638,521 Total 577,513 577,513 N/A N/A - - - 638,521

SCE Rebuttal Position

Variance from SCE2019 - 2021 Forecast

Business Planning Element

3

Table I-2 Distribution Infrastructure Replacement

2014-2019 Recorded/2020-2021 Forecast7,8 Summary of SCE’s Position

(2018 Constant $000)

1. Capital Expenditure Summary 1

Table I-3 provides the recorded 2019 and the forecast for 2020-2021 for SCE and Cal 2

Advocates. As discussed in SCE-12 Volume 1, SCE proposes the Commission authorize SCE’s revised 3

capital forecast for 2019, which incorporates 2019 recorded expenditures. As such, the tables displaying 4

SCE’s rebuttal position includes recorded 2019 costs and not SCE’s original 2019 forecast. For the 5

Distribution IR Capital Expenditures forecast, no intervenors proposed changes to SCE’s forecasts. SCE 6

will address the issues raised by CUE regarding their recommendation for a long-term Distribution IR 7

Plan. 8

7 With respect to our 2019 recorded expenditures, the overspend to forecast for Distribution IR was mainly due

to the completion of more work than forecast. The 4kV Cutovers activity completed 191 units over forecast. The Underground Structure Replacements completed 119 over forecast for Replacements and Shoring Vaults and CPRR completed 240 units over forecast. The Overhead Conductor Program shifted work causing an increase in 2019 spend associated with work in progress.

8 As we approach the end of the 2018-2020 GRC cycle, SCE will continue to manage Overhead Conductor Program deployment levels relative to forecast in consideration of resource constraints, risk analysis, authorized levels, and other factors. It is likely that SCE will spend some amount below the original 2020 forecast, however the exact amount is not yet known at this time.

2014 2015 2016 2017 20182019

Recorded2020

Forecast2021

ForecastTotal

2019-20211 4kV Cutovers 53,403$ 79,916$ 107,452$ 107,349$ 116,586$ 58,414$ 29,981$ 9,982$ 98,377$ 2 4kV Substation Elimination 1,731$ 1,756$ 2,643$ 3,893$ 5,521$ 5,857$ 5,643$ 3,288$ 14,788$ 3 Automatic Reclosers Replacement Program 1,523$ 2,488$ 2,136$ 2,393$ 1,248$ 1,488$ 2,448$ 2,610$ 6,546$ 4 Cable Life Extension (CLE) Program 13,244$ 11,665$ 22,858$ 32,033$ 31,258$ 11,235$ -$ -$ 11,235$ 5 Cable-in Conduit (CIC) Replacement Program 23,042$ 54,084$ 33,468$ 42,363$ 50,723$ 19,973$ 13,866$ 5,989$ 39,828$ 6 Capacitor Bank Replacement Program 7,814$ 8,684$ 7,765$ 6,920$ 19,386$ 9,736$ 5,302$ 2,716$ 17,754$ 7 Overhead Conductor Program (OCP) -$ 60,654$ 97,330$ 138,714$ 181,503$ 125,029$ 34,992$ 70,939$ 230,960$ 8 PCB Transformer Removal 1,368$ 1,325$ 1,579$ 1,479$ 2,533$ 2,114$ 1,883$ 1,943$ 5,940$ 9 Underground Structure Replacements 130,644$ 101,861$ 76,014$ 52,231$ 56,730$ 48,247$ 21,771$ 13,562$ 83,580$ 10 Underground Switch Replacements 19,580$ 25,890$ 17,566$ 19,129$ 9,714$ 8,594$ 3,520$ 2,642$ 14,756$ 11 Worst Circuit Rehabilitation (WCR) 153,013$ 117,673$ 143,162$ 135,286$ 118,299$ 75,231$ 32,566$ 6,960$ 114,757$

Total 405,362$ 465,996$ 511,973$ 541,790$ 593,501$ 365,918$ 151,972$ 120,631$ 638,521$

Lin

e #

Distribution Infrastructure ReplacementSCE Recorded SCE Rebuttal Position

4

Table I-3 Distribution Infrastructure Replacement Capital Expenditures

2019 Recorded/2020-2021 Forecast Summary of SCE and Cal Advocates’ Position

2019 Recorded

2020 Forecast

2021 Forecast

Total2019-2021

2019 Forecast 2020 2021

Total2019-2021

Variance From SCE2019-2021

1 4kV Cutovers 58,414$ 29,981$ 9,982$ 98,377$ 48,326$ 29,981$ 9,982$ 88,289$ (10,088)$

2 4kV Substation Elimination 5,857$ 5,643$ 3,288$ 14,788$ 6,054$ 5,643$ 3,288$ 14,985$ 197$

3 Automatic Reclosers Replacement Program 1,488$ 2,448$ 2,610$ 6,546$ 2,435$ 2,448$ 2,610$ 7,493$ 947$

4 Cable Life Extension (CLE) Program 11,235$ -$ -$ 11,235$ 20,574$ -$ -$ 20,574$ 9,339$

5 Cable-in Conduit (CIC) Replacement Program 19,973$ 13,866$ 5,989$ 39,828$ 17,074$ 13,866$ 5,989$ 36,929$ (2,899)$

6 Capacitor Bank Replacement Program 9,736$ 5,302$ 2,716$ 17,754$ 10,318$ 5,302$ 2,716$ 18,336$ 582$

7 Overhead Conductor Program (OCP) 125,029$ 34,992$ 70,939$ 230,960$ 100,063$ 34,992$ 70,939$ 205,994$ (24,966)$

8 PCB Transformer Removal 2,114$ 1,883$ 1,943$ 5,940$ 1,813$ 1,883$ 1,943$ 5,639$ (301)$

9 Underground Structure Replacements 48,247$ 21,771$ 13,562$ 83,580$ 27,573$ 21,771$ 13,562$ 62,906$ (20,674)$

10 Underground Switch Replacements 8,594$ 3,520$ 2,642$ 14,756$ 3,389$ 3,520$ 2,642$ 9,551$ (5,205)$

11 Worst Circuit Rehabilitation (WCR) 75,231$ 32,566$ 6,960$ 114,757$ 67,291$ 32,566$ 6,960$ 106,817$ (7,940)$ Total 365,918$ 151,972$ 120,631$ 638,521$ 304,910$ 151,972$ 120,631$ 577,513$ (61,008)$

SCE Rebuttal Position Cal Advocates

Distribution Infrastructure ReplacementLine No.

5

II. 1

BUSINESS PLANNING ELEMENT/GRC ACTIVITY 2

A. Capital Expenditures 3

1. SCE’s Application 4

SCE’s distribution grid includes infrastructure assets such as transformers, switches, 5

capacitors, automatic reclosers, underground structures, cables, and conductors. SCE’s inspection and 6

maintenance of distribution grid allows components to remain in service for decades, but in the long run, 7

every component in the distribution grid will wear out and need to be replaced. The ongoing systematic 8

replacement of infrastructure is a necessary aspect of maintaining a reliable electric distribution system.9 9

Due to wildfire risk mitigation and grid hardening efforts, which utilize the same resources required for 10

Distribution IR activities, SCE’s application requested $638.521 million10 for 2019-2021 that is required 11

to meet the need for ongoing replacement of distribution assets. 12

B. Non-Financial Proposals and Clarifications 13

1. The Commission Should Reject CUE’s Recommendation That SCE Develop A 14

Ten-Year Distribution IR Plan 15

a) CUE’s Position 16

While “CUE is broadly supportive of SCE’s Application,”11 CUE expresses 17

concerns that limiting funding and deferring Distribution IR affects reliability and burdens future 18

ratepayers.12 CUE recommends the Commission require SCE to develop an IR Plan that includes three 19

elements: “1) how SCE will achieve steady-state replacement of aging infrastructure; 2) a ten-year 20

forward infrastructure replacement plan; and 3) a discussion of potential resource constraints, including 21

personnel constraints, and how SCE will address them.”13 22

9 SCE-02 Vol. 01 Pt.01, p. 4, lines 3-7.

10 This includes 2019 recorded costs.

11 Exhibit CUE-01, p. 4, line 10.

12 Exhibit CUE-01, pp. 2-3.

13 Exhibit CUE-01, p. 5, lines 18-21.

6

b) SCE’s Rebuttal To CUE’s Position 1

While SCE agrees with CUE’s sentiment regarding the need for continued 2

investment in IR, SCE disagrees with the need for CUE’s proposed IR Plan and its three elements. SCE 3

requests the Commission reject CUE’s proposal. SCE addresses the three elements of CUE’s 4

recommendation in the order they were presented in CUE’s testimony. 5

(1) Steady State Replacement Rates 6

SCE agrees with CUE that the ongoing need for replacement of aging 7

assets is part of asset ownership and operation. While the concept of long-term steady state replacement 8

rates is very useful as an illustration of this ongoing need, a steady-state replacement rate is not an 9

appropriate target for IR planning purposes for two reasons. 10

First, there is underlying difficulty (indeed, practical impossibility) in 11

determining when steady-state rates can be achieved. SCE explained in a data request response to CUE 12

and testimony provided in Exhibit SCE-02 Volume 1, “[the] precise calculation of when the steady state 13

replacement rate will be achieved is complicated.”14 Complicating factors include non-fixed 14

populations, non-like-for-like replacements, and environmental factors.15 Such factors constantly disrupt 15

SCE’s system trajectory towards steady-state in ways that are extremely difficult to forecast, making it 16

practically impossible to determine when steady-state can be achieved. Thus, imposing this new 17

requirement would not provide meaningful insight to customers, SCE, the Commission, or intervenors. 18

Second, use of steady-state replacement rates as an IR target would not 19

appropriately consider failure-related risks. Even at steady-state, in-service failures contribute to total 20

replacement rates. For in-service failures, risk is a function of both failure frequency (i.e., failure rate) 21

and failure impact (i.e., consequence),16 but any plan to achieve steady-state replacement rates would 22

focus only on the former and fail to consider the latter. This can have significant risk implications; 23

hypothetically, a system with high-impact in-service failures at a steady-state failure rate could present 24

14 Data Response to CUE-SCE-001, Question 2.b, see also Appendix A pp. A2 – A3; Exhibit SCE-02 Volume

1, Part 1, p. 6, lines 11-12.

15 Data Response to CUE-SCE-001 Question 2.b., see also Appendix A, pp. A2 – A3.

16 Exhibit SCE-02 Volume 1, Part 1, p. 7, lines 2-4.

7

greater risk than a system with low-impact in-service failures and an increasing failure rate.17 As SCE 1

has incorporated risk analysis into its Distribution IR planning processes,18 the addition of any new 2

requirement to set steady-state failure rate targets would be a step backward – not forward – in the 3

integration of risk analysis and Distribution IR planning. 4

(2) A Ten-Year Infrastructure Replacement Plan 5

A requirement to develop a 10-year Distribution IR plan such as CUE 6

proposes would be an unnecessary additional exercise for two reasons: (1) SCE’s current IR planning 7

process is sufficient for purposes of prioritizing both near-term and longer-term IR activities; (2) any 8

new requirement to develop a longer 10-year IR plan would be inconsistent with and disruptive to 9

existing GRC and SCE’s Risk Assessment Mitigation Phase Report (RAMP) processes. SCE explains 10

these reasons in further detail below. 11

First, SCE’s existing IR planning process uses strategies and 12

methodologies that meet both short-term and long-term IR planning needs. Essentially, SCE generates a 13

five-year IR plan but also refreshes this plan on an annual, rolling basis. Thus, SCE’s near-term (i.e., 1-5 14

years) IR plans are always informed by recently available data and most up-to-date risk models. 15

Similarly, longer-term (i.e., six-years and beyond) IR needs are systematically addressed as those years 16

begin rolling into the five-year planning window. Expanding the required Distribution IR planning 17

window to 10 years, as CUE recommends, would not eliminate the annual need for a plan refresh using 18

up-to-date risk models and data. Therefore, such a requirement would create additional work for SCE, 19

the Commission, and intervenors without yielding additional benefit. For Distribution IR, short-term and 20

long-term IR planning needs are best met by continuing to use a five-year planning window and an 21

annual, rolling planning process, not by expanding the planning window to 10 years. 22

17 Consider the analogy of light bulb replacements in a hypothetical factory, which SCE has used in previous

rate cases, to illustrate the concept of steady-state replacement rates. In such a factory, we would expect to see replacements of the light bulb population eventually level off at a steady-state replacement rate. However, some of these light bulbs would be in high-risk locations (e.g., areas where failure can threaten employee safety) and others would be in low-risk locations (e.g. areas with high levels of ambient light). In terms of risk mitigation, it would be prudent to focus pre-emptive replacement efforts on high-risk locations, even if this results in an increasing replacement rate among the overall asset population.

18 Exhibit SCE-01 Vol. 2, pp. 26-27, lines 16-26.

8

Second, SCE’s current annual, rolling five-year Distribution IR planning 1

process meets GRC and RAMP requirements, and any new requirements to develop a 10-year 2

Distribution IR plan would be beyond the scope of GRC and therefore disruptive to RAMP. The scope 3

of 2021 GRC, like numerous GRCs in years past, covers a five-year planning horizon,19 and plans 4

related to years six and beyond are out of scope. RAMP scope is similarly limited to a five-year horizon, 5

because RAMP analyses are intended to inform GRC decisions. If a new 10-year planning requirement 6

was set for Distribution IR activities in GRC, this requirement would need to be incorporated into 7

underlying RAMP analysis supporting and informing that GRC forecast. The resulting non-uniformity 8

in RAMP risk analyses (i.e. different activities with different planning horizons) would be highly 9

disruptive and counterproductive to the overall intent of RAMP. 10

SCE will submit its next RAMP report in May 2022, which will likely 11

review mitigation programs through the end of SCE’s next GRC period, which will extend from 2025-12

2028.20 Under CUE’s recommendation, there would be substantial duplication between SCE’s RAMP 13

report, SCE’s GRC, and CUE’s proposed IR long-term plan, which would only serve to increase the 14

regulatory burden on SCE, parties, and the Commission. The Commission and all other parties have had 15

sufficient data and information in past GRCs to duly opine and adopt forecasts for SCE’s Distribution IR 16

programs, and this GRC is no exception. At a time when SCE is looking for ways to streamline work 17

and reporting requirements, adopting CUE’s proposal would require additional work that is unnecessary. 18

In summary, it is difficult to determine what significant benefits a ten-year 19

plan would provide over a rolling five-year plan that is updated annually, and CUE offers no reasonable 20

explanation in support of its ten-year plan proposal. Providing a ten-year plan as part of the GRC is both 21

beyond the scope of the GRC and not necessary, and therefore CUE’s proposed requirement should be 22

rejected. 23

19 Decision 20-01-002 and the April 17, 2020 Amended Scoping Memo and Ruling introduces a third Post-Test

Year, i.e. shifting the GRC from a 3-year cycle to a 4-year cycle. The issues discussed in this Amended Scoping Memo illustrate the complexities associated with expansion or modification of established GRC processes. While this extra year will result in the need for a six-year Distribution IR plan, this does not fundamentally change SCE’s arguments about the disruption that would be caused by a new requirement to develop a ten-year plan.

20 Decision 20-01-002, pp. 3, 55.

9

(3) Resource Constraints 1

SCE explained in response to CUE-SCE-001 Q.1a-b that the same 2

resources supporting wildfire mitigation and grid hardening activities are responsible for implementing 3

SCE’s Distribution IR work.21 SCE did not take the resultant trade-offs without consideration. SCE 4

consciously made the decision to reduce system augmentation, IR, and load growth activities in order to 5

divert necessary resources to implement vital wildfire risk mitigation and grid hardening work. SCE also 6

considered its responsibility to maintain affordability for its customers and public safety.22 These 7

deferments should be considered temporary until wildfire prevention-related work nears stabilization 8

and more resources become available, at which point SCE expects to increase Distribution IR 9

activities.23 Given that these resource constraints are well understood and SCE intends for them to be 10

temporary in nature, imposing a new requirement to further discuss these constraints is unnecessary. 11

2. CUE’s Statements Regarding Certain Wildfires Are Not Supported By The Existing 12

Record 13

CUE’s testimony states, “[t]here have been devastating wildfires in SCE’s service 14

territory as well as elsewhere in California. Some of those fires have been linked to faulty SCE 15

equipment, such as the 2017 Thomas Fire that burned 281,893 acres in Ventura County and the 2018 16

Woolsey Fire that burned 96,949 acres in and around Malibu.”24 CUE cites the Wall Street Journal as 17

the reference.25 CUE’s statement regarding certain fires are not supported by the existing record. 18

SCE believes evidence shows there were at least two separate ignitions on December 4, 19

2017 that led to two fires that together are commonly referred to as the Thomas Fire — one in the 20

Anlauf Canyon area of Ventura County and another near Koenigstein Road in the city of Santa Paula. 21

Based on currently available information, SCE does not believe that its equipment was associated with 22

the fire ignition in the Anlauf Canyon area. As for the Koenigstein fire, it appears that SCE’s equipment 23

was associated with the Koenigstein ignition. The specific cause has not been determined nor does SCE 24

21 Response to CUE-SCE-001 Q. 1 a-b, see also Appendix A, pp. A4 – A5.

22 Id.

23 Exhibit SCE-02 Vol.1 Part 1, p. 14.

24 Exhibit CUE-01, p. 1, lines 4-7.

25 Exhibit CUE-01, p. 1, footnote 1.

10

know if faulty equipment was involved. With regards to the Woolsey Fire, final determination as to the 1

causes of the Woolsey Fire are unknown and still under investigation. Absent additional evidence, SCE 2

believes it is likely that its equipment was associated with the ignition of the Woolsey Fire. Once again, 3

the specific cause has not been determined nor does SCE know if faulty equipment was involved. 4

Moreover, inspection and testing of the physical evidence and documents in the possession of CAL 5

FIRE/VCFPD is required in order to make a final determination as to origin, cause, and progression of 6

the Woolsey Fire.26 7

26 https://newsroom.edison.com/releases/sce-responds-to-report-on-the-2017-koenigstein-fire

https://newsroom.edison.com/releases/sce-questions-investigation-report-on-anlauf-canyon-ignition-of-2017-thomas-fire.

11

III. 1

CONCLUSION 2

SCE’s forecast for capital expenditures for Distribution IR is unopposed and therefore should be 3

adopted. In addition, the Commission should reject CUE’s recommendation that SCE develop a long-4

term plan that (1) explains how SCE will achieve steady-state replacement; (2) covers a ten-year period; 5

and (3) discusses potential resource constraints. First, determining when steady-state rates can be 6

achieved for IR planning is practically impossible and would not appropriately consider failure-related 7

risks. Second, a requirement to develop a 10-year Distribution IR plan is unnecessary, as SCE’s current 8

annually updated five-year IR planning process is sufficient, and a longer 10-year IR plan would be 9

inconsistent with and disruptive to existing GRC and RAMP filings. Third, imposing a new requirement 10

to discuss potential resource constraints is unnecessary because SCE has already explained the resource 11

constraints in connection with its proposal in this GRC and that they are temporary in nature. 12

Appendix A

SCE-13 Vol. 01, Part 1 Data Request Responses

SCE-13, Vol. 01: Rebuttal Testimony on Distribution Infrastructure Replacement Appendix A Index of Data Request Responses

A1

Table of Contents PAGE(S)

CUE-SCE-001 Question 2. b A2 – A3

CUE-SCE-001 Question 1. a-b A4 – A5

Southern California EdisonA.19-08-013 – SCE 2021 General Rate Case

A2

A3

Southern California EdisonA.19-08-013 – SCE 2021 General Rate Case

A4

A5