SCE-17 Vol. 05 Rebuttal Testimony€¦ · Historical and Forecast of Capital Expenditures SCE Recorded 2014 - 2019 and SCE’s Rebuttal Position (Nominal $000) 3 B. F L O C E 4 Facility

Application No.: A.19-08-013 Exhibit No.: SCE-17, Vol. 05 Witnesses: T. Guntrip

D. Neal

(U 338-E)

2021 General Rate Case Rebuttal Testimony

Enterprise Operations

Before the

Public Utilities Commission of the State of California

Rosemead, California June 12, 2020

SCE-17, Vol. 05: Enterprise Operations

Table Of Contents

Section Page Witness

-i-

I. INTRODUCTION .............................................................................................1 D. Neal

A. Summary of Rebuttal Position 1 T. Gruntrip D. Neal

B. Facility and Land Operations Capital Expenditures ..............................3 D. Neal

1. Infrastructure Upgrades .............................................................4

a) Blythe Service Center ....................................................5

(1) SCE’s Application .............................................5

(2) TURN .................................................................6

b) Santa Barbara Service Center ........................................7

(1) SCE’s Application .............................................7

(2) TURN .................................................................8

(3) Conclusion .......................................................11

c) T&D Training Center ...................................................11

(1) SCE’s Application ...........................................11

(2) TURN ...............................................................12

(3) Conclusion .......................................................15

d) Vehicle Maintenance Facilities ....................................15


(2) TURN ...............................................................16

(3) Conclusion .......................................................18

2. Substation Reliability Upgrades ..............................................18

a) Devers Maintenance and Test Building .......................19


(2) TURN ...............................................................20

SCE-17, Vol. 05: Enterprise Operations

Table Of Contents

Section Page Witness

-ii-

(3) Conclusion .......................................................22

b) Rector Maintenance and Test Building ........................22


(2) TURN ...............................................................22

(3) Conclusion .......................................................24

Appendix A SCE 17, Vol. 5 Workpaper Index

-1-

I. 1

INTRODUCTION 2

In this volume, Southern California Edison (SCE) addresses certain recommendations made by 3

The Utility Reform Network (TURN) to SCE’s forecasts for Enterprise Operations related forecasts of 4

capital expenditures for 2019 through 2023. This volume also covers SCE’s Test Year 2021 forecast of 5

operations and maintenance (O&M) expenses for the Facility and Land Operations Business Planning 6

Element (BPE) and 2019 through 2023 capital expenditures forecast for the Facility and Land 7

Operations and Transportation Services BPEs (collectively, Enterprise Operations). The forecasts for 8

these activities support the acquisition, operation and maintenance of SCE facilities, land and land 9

rights, and vehicles and equipment necessary to maintain safe and reliable company-wide operations and 10

service to our customers. 11

Except for TURN, no other party (including the Cal Advocates) submitted testimony opposing 12

SCE’s O&M and capital forecasts for the Facility and Land Operations and Transportation Services 13

BPEs.1 TURN recommends adjustments and disallowances to certain Facility and Land Operations 14

capital forecasts as discussed below.2 15

A. Summary of Rebuttal Position 16

The forecasts for Enterprise Operations O&M expense, and capital expenditures, made by SCE, 17

Cal Advocates, and TURN are shown in the following tables. Table I-1 provides a summary of the 2021 18

O&M expense forecast for SCE, Cal Advocates, and TURN. As noted earlier, there are no variances 19

reflected below as neither Cal Advocates nor TURN opposed Enterprise Operations’ O&M forecast for 20

Test Year 2021. 21

1 Exhibit PAO-12 (Enterprise Support II), pp. 7 - 9. 2 TURN submitted no testimony concerning the Transportation Services BPE capital forecast.

2

Table I-1 Enterprise Operations 2021 O&M Forecast

Summary of SCE, Cal Advocates, and TURN Position (2018 Constant $000)

Table I-2 provides a summary of Enterprise Operations 2019 through 2023 capital forecast by 1

SCE, Cal Advocates, and TURN, along with the variance from SCE’s forecast where applicable. 2

Table I-2 Enterprise Operations

Capital Expenditures 2019-2023 Forecast Summary of SCE, Cal Advocates3, and TURN Position

(Nominal $000)

Table I-3 provides the recorded amounts for 2014 through 2019 and the forecast for 2020 3

through 2023 for SCE, Cal Advocates and TURN. The forecast for 2020 through 2023 includes updates 4

from the errata submitted on June 12, 2020 (SCE-06, Volume 05E). For Exhibit SCE-06, Volume 05, 5

Enterprise Operations capital expenditures forecast, TURN proposed changes to SCE’s forecasts for 6

certain Facility and Land Operations BPE projects. SCE will address the issues raised by TURN 7

recommendations related to SCE’s 2019 through 2023 capital forecast in the corresponding chapters 8

3 Cal Advocates’ higher 2019 - 2023 capital forecast appears to have arisen from the use of figures from SCE’s

original submission in August 2019 rather than the updated figures reflected in the subsequently submitted errata (SCE-06, Vol. 05E).

SCECal

Advocates TURNCal

Advocates TURN1 Facility and Land Operations 59,277 59,277 59,277 - - 59,277 2 Transportation Services - - - - - - 3 Total 59,277 59,277 59,277 - - 59,277

Line No.

Business Planning Elements

2021 Forecast Variance from SCE

SCE Rebuttal Position

SCECal

Advocates TURNCal

Advocates TURN1 Facility and Land Operations 644,232 648,894 544,117 4,662 (100,113) 639,504 2 Transportation Services 24,081 24,081 24,081 - - 24,332 3 Total 668,313 672,975 568,198 4,662 (100,113) 663,836

SCE Rebuttal Position

Line No.

Business Planning Element2019 - 2023 Forecast Variance from SCE

3

below.4 TURN submitted no testimony contesting Transportation Services BPE capital forecast. Cal 1

Advocates reviewed the proposals for Enterprise Operations and does not oppose SCE’s requests.5 2

Table I-3 Enterprise Operations

Historical and Forecast of Capital Expenditures SCE Recorded 2014 - 2019 and SCE’s Rebuttal Position

(Nominal $000)

B. Facility and Land Operations Capital Expenditures 3

Facility and Land Operations capital expenditures are necessary to provide a safe and productive 4

environment for SCE’s workforce and visitors to SCE facilities. 5

Facility and Land Operations capital forecasts includes five major programs: 1) Infrastructure 6

Upgrades, 2) Facility Repurpose Programs, 3) Substation Reliability Upgrades, 4) Facility Management 7

Capital Programs, 5) Land Operations. 8

While Cal Advocates does not oppose SCE’s Facility and Land Operations capital expenditures 9

forecast, TURN recommends reductions to and disallowances of certain projects encompassed by two of 10

the five Facility and Land Operation capital programs.6 SCE’s rebuttal position and TURN’s 11

recommendations are summarized below in Table I-4. 12

4 Exhibit to TURN-10, p. 7. 5 Exhibit PAO-12 (Enterprise Support II), pp. 7 - 9. 6 Exhibit TURN-10, p. 8.

2014 2015 2016 2017 20182019

Recorded2020

Forecast2021

Forecast2022

Forecast2023

ForecastTotal

2019-20231 Facility and Land Operations 228,974 161,752 105,301 104,348 116,120 105,217 102,876 140,441 142,467 148,503 639,504 2 Transportation Services 745 781 1,441 5,855 6,042 5,664 5,529 3,418 6,086 3,635 24,332 3 Total 229,720 162,533 106,742 110,203 122,161 110,881 108,405 143,859 148,553 152,138 663,836

SCE Recorded SCE Rebuttal Position

Lin

e #

Business Planning Element

4

Table I-4 Facility and Land Operations

2019 Recorded/2020-2023 Forecast Summary of SCE and TURN Position

(2018 Nominal $000)

1. Infrastructure Upgrades 1

Infrastructure Upgrades address specific deficiencies in facility conditions and systems 2

which need to be resolved in order to meet current operational requirements. SCE forecasts total 3

expenditures for Infrastructure Upgrades of $201.944 million from 2019 through 2023.7 TURN 4

recommends a reduction of $82.874 million8 in connection with four Infrastructure Upgrade projects: (1) 5

Blythe Service Center; (2) Santa Barbara Service Center; (3) T&D Training Center and (4) Vehicle 6

Maintenance Facilities. SCE’s rebuttal position in Table I-5 below is updated to reflect 2019 recorded 7

capital expenditures, across the disputed Infrastructure Upgrade programs. 8

7 Exhibit SCE-06, Vol. 05, p. 34, Table II-8 (Infrastructure Upgrades total ($244.096 million) less prior

recorded expenditures ($42.152 million) equals $201.944 million). 8 While TURN’s testimony (TURN-10, p. 8) indicates the difference between SCE’s position and TURN’s

position on Infrastructure Upgrades is $85.108 million, Table I-5 below shows a slight difference due to this table utilizing SCE’s 2019 recorded amounts rather than 2019 forecast amounts.

Line No.

Facility and Land Operations2019

Recorded2020

Forecast2021

Forecast2022

Forecast2023

ForecastTotal

2019-20232019

Forecast 2020 2021 2022 2023Total

2019-2023

Variance From SCE2019-2023

1 Infrastructure Upgrades 26,299 16,342 56,389 53,269 46,005 198,304 26,848 9,904 25,447 35,100 19,536 116,834 (81,470) 2 Facility Repurpose Projects 8,150 23,059 23,334 30,177 40,467 125,187 8,452 23,059 23,334 30,177 40,467 125,489 302 3 Substation Reliability Upgrades 5,704 5,077 - - - 10,781 - - - - - - (10,781) 4 Facility Management Capital Programs 59,046 50,387 56,887 57,841 58,814 282,975 54,307 50,387 56,887 57,841 58,814 278,236 (4,739) 5 Projects Less Than $3M 4,881 6,394 2,177 - 2,000 15,452 5,738 6,394 2,177 - 2,000 16,309 857 6 Land Operations 1,136 1,617 1,653 1,180 1,218 6,804 1,582 1,617 1,653 1,180 1,218 7,250 446

Total 105,217 102,876 140,441 142,467 148,503 639,504 96,926 91,360 109,499 124,298 122,034 544,117 (95,385)

TURN PositionSCE Rebuttal Position

5

Table I-5 Infrastructure Upgrades


(Nominal $000)

a) Blythe Service Center 1

(1) SCE’s Application 2

This project addresses the aging infrastructure and compliance 3

requirements (e.g., hazardous materials storage canopy, run-off, and water management) of the Blythe 4

Service Center. These compliance requirements and current building operational constraints, such as 5

deficient site ingress and egress capabilities, are addressed by expanding and reconstructing the existing 6

service center at its current location.9 7

Table I-6 below shows SCE’s and TURN’s forecasts for the Blythe 8

Service Center project. SCE’s rebuttal position incorporates 2019 recorded expenditures in the place of 9

2019 forecast. 10

9 Exhibit SCE-06, Vol. 05, p. 34.

Line No.

Infrastructure Upgrades2019

Recorded2020

Forecast2021

Forecast2022

Forecast2023

Forecast

Total2019-2023 2019 2020 2021 2022 2023

Total2019-2023


1 Blythe Service Center 11,159 - - - - 11,159 11,159 - - - - 11,159 - 2 Santa Barbara Service Center - - - 1,068 14,055 15,123 - - - - - - (15,123) 3 T&D Training Center 856 6,438 30,942 6,869 - 45,105 - - - - - - (45,105) 4 Vehicle Maintenance - - - 10,232 12,414 22,646 - - - - - - (22,646) Total 12,015 6,438 30,942 18,169 26,469 94,033 11,159 - - - - 11,159 (82,874)

SCE Rebuttal Position TURN Position

6

Table I-6 Blythe Service Center Capital Expenditures


(Nominal $000)

(2) TURN 1

(a) TURN’s Position 2

TURN recommends $11.159 million in 2019 for the Blythe 3

Service Center project. TURN’s recommendation is $2.054 million lower than SCE’s forecast. TURN’s 4

recommendation is based on the following argument:10 5

The new Blythe Service Center buildings were fully used and 6

useful as of December 13, 2019, so project costs included in 7

rates should be limited to SCE’s actual spend as of December 8

13, 2019. 9

(b) SCE’s Rebuttal to TURN’s Position 10

TURN’s recommendation to reduce funding for the Blythe Service 11

Center project should be rejected. Although the Blythe Service Center was fully in use and useful at the 12

end of 2019 based upon work completed through 2019, additional funding is needed to cover final 13

construction invoices that did not issue until 2020. 14

In its direct testimony, SCE forecast $13.213 million to complete 15

the project.11 Although SCE recorded $11.159 million in expenditures and the project progressed such 16

that the upgraded buildings were in service by the end of 2019, there were delays in receiving the final 17

invoices for this project. The final construction invoices, along with the City’s invoices for offsite 18

improvements and invoice retentions under the construction contracts still need to be paid in 2020 once 19

10 Exhibit TURN-10, p. 9, lines 9 - 13. 11 Exhibit SCE-06, Vol. 05, p. 36, lines 9 - 12.

Line No. Blythe Service Center 2019 2020 2021 2022 2023 TOTAL

1 SCE Application 13,213 - - - - 13,213 2 TURN Recommendation 11,159 - - - - 11,159 3 Variance (2,054) - - - - (2,054) 4 SCE Rebuttal Position 11,159 - - - - 11,159

7

final punch list items are complete. SCE forecasts the total of such final payments in 2020 will be 1

$1.500 million. These timing issues resulting in certain costs forecast during 2019 to not be recorded 2

until 2020 do not serve as a reasonable basis for disallowing SCE’s recovery of the full cost of the 3

project. This holds particularly true where SCE forecasts completion of the project for $554,000 under 4

its previous forecast and where at least some of the deferred payments are the result of holdbacks to 5

further satisfactory contractor performance. 6

(c) Conclusion 7

TURN’s proposed disallowance of $2.054 million for this project 8

should be rejected. SCE does not contend that the Commission should authorize more for the project 9

than what will actually be recorded as TURN seems to suggest.12 While the Blythe Service Center 10

project was completed in 2019, closeout activities and final invoicing of $1.500 million will occur in 11

2020 and are valid expenditures. All of that considered, to be consistent with historical practice in the 12

GRC, SCE is not proposing to update its 2020 forecast at this time to reflect the delay of incurring these 13

costs, but instead will true-up to the final cost of the project in its next GRC. 14

b) Santa Barbara Service Center 15


SCE seeks to relocate the Santa Barbara Service Center to an area closer 17

to the majority of the Santa Barbara customer base and workforce in an effort to improve System 18

Average Interruption Duration Index (SAIDI) scores and the delivery of electricity to the customers 19

served.13 In the 2018 GRC decision, the Commission agreed that SCE’s relocation of the service center 20

was reasonable.14 Table I-7 below summarizes the forecasts of SCE and TURN. 21

12 Exhibit TURN-10, p. 9, line 11. 13 Exhibit SCE-06, Vol. 05, p. 37, lines 7 - 14. 14 Exhibit TURN-10, p. 10, Footnote 17.

8

Table I-7 Santa Barbara Service Center Capital Expenditures


(Nominal $000)

(2) TURN 1


TURN recommends disallowing SCE’s 2022 and 2023 forecast for 3

the relocation of the Santa Barbara Service Center. TURN’s recommendation is based on the following 4

arguments:15 5

TURN asserts the expenditures for land purchase and 6

environmental studies forecast through 2023 are not 7

recoverable since the service center will not be completed 8

during this period and, therefore, cannot be considered used 9

and useful. 10

There is not sufficient reason to believe that the land purchase 11

and environmental studies will be completed as scheduled 12

based on SCE’s “history of not spending authorized amounts.” 13


TURN’s recommendation to disallow funding for the land 15

purchase and environmental studies supporting relocation of the Santa Barbara Service Center should be 16

rejected. 17

15 Exhibit TURN-10, pp. 10 - 12.

Line No.

Santa Barbara Service Center 2019 2020 2021 2022 2023 TOTAL

1 SCE Application - - - 1,068 14,055 15,123 2 TURN Recommendation - - - - - - 3 Variance - - - (1,068) (14,055) (15,123) 4 SCE Rebuttal Position - - - 1,068 14,055 15,123

9

(i) Federal and Commission Guidance Support the 1

Recovery of Land Acquisition and Related Costs in 2

Advance of Construction. 3

The Federal Energy Regulatory Commission (FERC) 4

Uniform System of Accounts, Section 7, Land and Land Rights, provides that land acquisition costs and 5

related costs be included in rates.16 More specifically, Plant Held For Future Use (PHFFU), FERC 6

Account 105, provides that land purchased in anticipation of future requirements be included in rates, 7

including when made in advance of the construction of utility assets thereupon.17 In the 2018 GRC 8

decision, the Commission authorized the relocation of the Santa Barbara Service Center which included 9

the purchase of land on which the relocated service center would be built.18 SCE’s forecast of land 10

purchase and environmental studies through 2023 conforms with Commission guidelines for inclusion in 11

Rate Base as PHFFU.19 As such, TURN’s contention that SCE’s request should be disallowed on the 12

grounds that the construction of the Santa Barbara Service Center will not occur until later years should 13

be rejected. 14

(ii) SCE has made and continues to make reasonable and 15

diligent efforts to locate a suitable parcel for the 16

relocation of the Santa Barbara Service Center. 17

As it does in this GRC, TURN also recommended complete 18

disallowance of funding for the relocation of the Santa Barbara Service Center in the 2018 GRC. 19

Notwithstanding the uncertainty over whether the Commission would adopt SCE’s forecast for the 20

project in the face of TURN’s objections, SCE moved forward with the Santa Barbara Service Center 21

relocation by conducting searches for a suitable parcel to meet the project’s needs even before the 22

issuance of the 2018 GRC Decision in May 2019. SCE faced significant challenges in locating a suitable 23

parcel notwithstanding its efforts. The target land area of South Santa Barbara and Carpinteria is a 24

narrow stretch of land, limited by the ocean on one side, mountains on the other, and much of the region 25

is not zoned for industrial use. SCE has conducted reviews of multiple parcels, including several parcels 26

16 See Appendix, pp. A-1-A-15, Code of Federal Regulations, Title 18, Chapter 1, Subchapter C, Part 101,

Electric Plant Instructions, Chapter 7. 17 See Appendix, pp. A-16-A-20, Excerpt from D.87-12-066, Section J (Plants Held for Future Use). 18 Exhibit TURN-10, p. 10, Footnote 17. 19 Exhibit SCE-07, Vol. 02A, pp. 6 - 7.

10

that appeared to be feasible but which were ultimately deemed unworkable due to zoning or physical site 1

constraints.20 SCE’s efforts to identify a suitable parcel remain ongoing and consistent with the forecast 2

and schedule as presented in direct testimony.21 3

While funds for the Santa Barbara Service Center 4

relocation were authorized in the 2018 GRC Decision issued in May 2019,22 SCE prioritized and 5

recorded expenditures for other Facility and Land Operations BPE projects that emerged in 2018 to 6

address safety and compliance issues, including the GO1 Workplace Upgrades (performed concurrent 7

with seismic mitigation work), the GO1 Electrical Upgrades, and a higher volume of capital 8

maintenance work.23 While TURN’s testimony appears to contest SCE’s ability to reallocate authorized 9

funds for other emergent needs,24 SCE, in its management discretion, must retain the ability to 10

accomplish other prudent and beneficial work that subsequently emerged as necessary and was not 11

otherwise forecast.25 12

Additionally, TURN did not object to the projects that were 13

undertaken (two of which are discussed in detail in SCE’s direct testimony) as SCE’s efforts to locate a 14

suitable parcel delayed commencement of the Santa Barbara Service Center relocation.26 Beyond noting 15

the difficulty SCE has experienced in locating a suitable parcel (which is not in dispute), TURN’s 16

current testimony does not offer a basis for challenging the justification for the project or reasonableness 17

of the forecast. 18

20 Exhibit SCE-06, Vol. 05, pp. 36 - 37. 21 Exhibit SCE-06, Vol. 05, pp. 37 - 38. 22 Exhibit TURN-10, p. 10, Footnote 17. 23 Exhibit SCE-06, Vol. 05, p. 14, lines 3 - 23. 24 See, in contrast, Appendix, p. A-22, Amended Scoping Memo and Ruling of Assigned Commission and

Assigned Administrative Law Judges dated April 10, 2020, p. 5 (“TURN argues that SCE already has the authority to shift resources and spend money differently than forecast in its rate case…”) (citing to TURN March 20, 2020 PHC Statement, p. 2).

25 My testimony addresses why TURN’s proposal is incorrect based on the specific merits and circumstances of the Santa Barbara Service Center project and forecast. In SCE’s Results of Operations rebuttal testimony, SCE Rate Case Director Douglas Snow explains on an overall ratemaking basis the invalidity of the TURN proposal and other, similar proposals found elsewhere in GRC Parties’ testimony that would impose shareholder funding for projects that benefit customers. See Exhibit SCE-18, Vol. 1, Chap. II.

26 Exhibit SCE-06, Vol. 05, pp. 45-50, 64-73, 92 and 95.

11

(3) Conclusion 1

FERC and CPUC guidance provide for rate recovery of land acquisition 2

and related costs. SCE has made and continues to make reasonable efforts to locate a suitable parcel for 3

the relocation of the Santa Barbara Service Center. Therefore, SCE respectfully requests that the 4

Commission reject TURN’s recommendation and adopt SCE’s forecast of $15.123 million in 2022 and 5

2023. 6

c) T&D Training Center 7


The T&D Training Center project will consolidate the existing training 9

schools at Alhambra, Chino and Westminster to a single location on an SCE-owned site in Rancho 10

Vista, which will maximize trainer efficiency, upgrade training facilities and create an environment that 11

more closely replicates actual field conditions. The project will support enhancements to training that 12

will improve reliability of the system and the safety of the workforce.27 The T&D Training Center was 13

approved in the 2018 GRC decision and since then SCE has reduced the forecast for this project 14

significantly. SCE now forecasts a total expenditure of $46.561 million for the T&D Training Center.28 15

Table I-8 below includes SCE’s rebuttal position incorporating 2019 recorded expenditures in place of 16

the 2019 forecast. 17

27 Exhibit SCE-06, Vol. 05, p. 39, lines 17 - 21. 28 Exhibit SCE-06, Vol. 05, p. 41, lines 17 - 22.

12

Table I-8 T&D Training Center Capital Expenditures


(Nominal $000)

(2) TURN 1


As noted in Table I-8 above, TURN recommends no funding for 3

the T&D Training Center project. TURN’s recommendation is based on the following arguments:29 4

Since SCE only spent a portion of the Commission’s 5

authorized funding from the 2018 GRC Decision for this 6

project, SCE has not provided sufficient reason to believe that 7

requested funds will be spent on the authorized project. 8

TURN asserts that SCE’s documentation did not support the 9

level of cost represented by the forecast for the T&D Training 10

Center project. 11


TURN’s recommendation to disallow all funding for the T&D 13

Training Center should be rejected. 14

(i) SCE activities on this project and recorded spend 15

document SCE’s commitment to completing this 16

project. 17

As discussed in direct testimony, SCE initiated assessments 18

of appropriate sites for the T&D Training Center requested in the 2018 GRC starting in 2017 and prior 19

29 Exhibit TURN-10, pp. 13 - 14.

Line No. T&D Training Center 2019 2020 2021 2022 2023 TOTAL

1 SCE Application 1,036 6,438 30,942 6,869 - 45,285 2 TURN Recommendation - - - - - - 3 Variance (1,036) (6,438) (30,942) (6,869) - (45,285) 4 SCE Rebuttal Position 856 6,438 30,942 6,869 - 45,105

13

to the issuance of the 2018 GRC Decision. SCE subsequently determined that utilizing the Rancho Vista 1

site for the T&D Training Center was feasible.30 SCE also reduced the scope of the project as it was 2

originally contemplated in the 2018 GRC request, by eliminating the need to purchase land and related 3

significant site preparation activities. In particular, SCE’s 2018 GRC forecast for this project included 4

land purchase costs of $22.950 million and site preparation costs of $20.324 million.31 In this GRC, 5

SCE’s forecast for the T&D Training Center is $46.561 million ($45.476 million under the 2018 GRC 6

forecast of $92.037 million).32 7

TURN’s contention that SCE has provided insufficient 8

reason to believe the T&D Training Center project will move forward runs contrary to SCE’s efforts to 9

move forward with the project continuously from 2015 through the present.33 The planning and 10

engineering activities for this project are ongoing as of the date of this submission and in line with 11

SCE’s 2021 GRC forecast.34 12

While the T&D Training Center program did not proceed 13

as forecasted in the 2018 GRC for the reasons discussed above and in direct testimony, SCE prioritized 14

and recorded expenditures for other Facility and Land Operations BPE capital work, including the GO1 15

Workplace Upgrades and GO1 Electrical Upgrades projects and additional capital maintenance work in 16

2018.35 As noted earlier, TURN’s argument for blanket disallowance runs contrary to SCE’s discretion 17

to reallocate authorized funds where circumstances changed to delay the commencement of the T&D 18

Training Center project and SCE prudently applied funds to perform other emerging and beneficial 19

projects, including GO1 upgrade projects and additional capital maintenance work.36 20

While the overall schedule of the project may have shifted, 21

SCE was ultimately able to find a lower cost solution for a consolidated training center and continues to 22

move this project forward. Notwithstanding its doubts above SCE’s plan to complete the T&D Training 23

Center, TURN does not question or otherwise challenge SCE’s justification for and the benefits that 24

30 Exhibit SCE-06, Vol. 05, p. 38, lines 5 - 15. 31 See Appendix to this Rebuttal Volume, p. A-24, 2018 GRC, Exhibit SCE-07, Vol. 03, Book C, p. 332. 32 Exhibit SCE-06, Vol. 05, p. 38, Table II-11. 33 Exhibit TURN-10, p. 12, Footnote 27. 34 Exhibit SCE-06, Vol. 05, p. 41, line 20. 35 Exhibit SCE-06, Vol. 05, p. 14, lines 3 - 23. 36 See Exhibit SCE-18, Vol. 1, Chapter II.

14

would be gained from the T&D Training Center project. As such, TURN’s conjecture regarding SCE’s 1

commitment to the project are incorrect. 2

(ii) The T&D Training Center Forecast is properly 3

supported by cost estimates prepared by a third-party 4

specialist. 5

In support of its contention that SCE has failed to produce 6

sufficient documentation concerning the T&D Training Center forecast, TURN cites SCE’s response to 7

a TURN data request (specifically, TURN-SCE-030, Question 14) and claims SCE should have 8

produced “bids, contracts and invoices” as part of its response.37 However, this TURN Data Request 9

only requested “support” for the amounts shown on a specific workpaper, a professional planning 10

estimate of the T&D Center Project costs from an independent third party estimating firm.38 SCE 11

properly responded to this data request by discussing the third party estimating company, Cumming 12

Construction Management Inc. (CCMI), its cost estimating methodology and related estimating work, 13

and providing a more detailed breakdown of CCMI’s planning estimate. The detailed breakdown of the 14

planning estimate workpaper included line by line division activity, quantity, unit of measure, unit cost 15

and activity cost total.39 Additionally, SCE’s direct testimony already included details concerning 16

CCMI’s cost estimating methodology and sources of information used to generate planning estimates for 17

SCE’s construction projects including: 18

Proprietary CCMI data; 19

Industry standard data from the American Institute of 20

Architects (AIA), American Society of Mechanical 21

Engineers (ASME), Institute of Electrical and 22

Electronic Engineers (IEEE), American Society of 23

Professional Estimators, Construction Management 24

37 Exhibit TURN-10, pp. 13 - 14. 38 Exhibit TURN-10, p. 13, Footnote 31. 39 See Appendix to this Rebuttal Volume, pp. A-27-A-30 (SCE’s Response to TURN-SCE-030, Question 14

with attachment). Although TURN includes the body of the response as part of the attachments to TURN-10, TURN did not include the detailed cost estimate breakdown that was included with the response. See TURN-10, Attachments, pp. 6 - 7.

15

Association of America (CMAA), and RS Means and 1

Leland Saylor Associates; 2

Third party construction data and experience, historical 3

data (which includes experiential and parametric data 4

for unique use properties, systems, materials or 5

equipment). 6

Current local market rates; and, 7

Data provided by SCE.40 8

As such, TURN’s citation to SCE’s data request response 9

does not reflect a failure by SCE’s to support the T&D Training Center forecast. Given the actual 10

construction of the T&D Training Center had not commenced, there were no bids, contracts or invoices 11

that could be provided at that time and SCE’s properly provided the supporting information and 12

documentation about CCMI’s planning estimate as TURN requested. 13

(3) Conclusion 14

SCE remains on track to complete the T&D Training Center based on the 15

updated scope and forecast presented in this GRC which was properly supported by a detailed cost 16

estimate from a third-party construction cost estimating firm. While TURN takes issue with SCE’s 17

failure to move forward with the project as originally anticipated, TURN does not question the merits of 18

the project itself. Accordingly, SCE respectfully requests the Commission reject TURN’s 19

recommendation and adopt SCE’s forecast of $45.105 million for the T&D Training Center project. 20

d) Vehicle Maintenance Facilities 21


SCE’s Vehicle Maintenance Facilities program seeks to address the aged 23

condition of existing facilities and operational needs, including electrification of SCE’s fleet. The lack of 24

capacity and accommodations to service current and future vehicles, makes the facilities deficient in 25

their fitness for purpose. SCE’s forecasts include constructing and providing maintenance equipment 26

and electric vehicle charging at one vehicle service bay at the Orange Coast and Montebello Service 27

Centers, and two vehicle service bays (one with equipment) at the Ventura Service Center.41 28

40 Exbibit SCE-06, Vol. 05, p. 25, line 14 - p. 26, line 7. 41 Exhibit SCE-06, Vol. 05, pp. 43 - 44.

16

Table I-9 Vehicle Maintenance Facilities Capital Expenditures


(Nominal $000)

(2) TURN 1


As noted in Table I-9 above, TURN recommends no funding for 3

the Vehicle Maintenance Facilities project. TURN’s recommendation is based on the following 4

arguments:42 5

SCE has not spent the funds the Commission authorized for 6

this project in the 2018 GRC Decision. 7

TURN asserts that SCE’s Planning Estimate does not 8

adequately support the level of cost for this project. 9


(i) SCE activities on this project support SCE’s 11

commitment to completing this project. 12

As discussed in direct testimony, these projects were 13

delayed from their initial start date in 2018 following benchmarking analyses with other utilities which 14

resulted in programming and business changes to each facility. The start date was further pushed back to 15

2022 to address electrification of the fleet to be housed there. By taking these steps, SCE sought a 16

suitable long-term solution rather than performing multiple interim improvements. 17

Although funds were authorized for these projects in the 18

2018 GRC Decision,43 SCE prioritized and recorded expenditures for other Facility and Land Operations 19

42 Exhibit TURN-10, p. 15. 43 See, D.19-05-020, May 24, 2019, p. 227.

Line No. Vehicle Maintenance 2019 2020 2021 2022 2023 TOTAL

1 SCE Application - - - 10,232 12,414 22,646 2 TURN Recommendation - - - - - - 3 Variance - - - (10,232) (12,414) (22,646) 4 SCE Rebuttal Position - - - 10,232 12,414 22,646

17

BPE capital projects, including the GO1 Workplace Upgrades and GO1 Electrical Upgrades projects and 1

additional capital maintenance work during 2018 as SCE awaited the 2018 GRC Decision.44 As 2

discussed earlier, SCE must retain discretion to reallocate authorized funds for other emergent needs and 3

undertake projects that are prudent and beneficial to customers.45 Additionally, TURN does not appear 4

to take issue with the reasonableness of the projects themselves, recognizing that these vehicles 5

maintenance facilities are heavily used, over 30 years old, and have not undergone major renovation 6

since original construction.46 7

While the overall schedule of the project may have shifted 8

due to the events indicated above, SCE continues to move this project forward and respectfully requests 9

that the Commission authorize funding for the Vehicle Maintenance Facility program as described in 10

SCE’s testimony. 11

(ii) SCE provided support for how the Planning Estimates 12

referred to by TURN (included in workpapers) were 13

produced by an independent third party. 14

As with TURN’s challenge to the T&D Training Center, 15

TURN’s contention that SCE failed to adequately support its forecast for the vehicle maintenance 16

facility incorrectly relied on SCE’s response to a TURN data request that was confined to seeking 17

support for the planning estimate that SCE submitted from a third party cost estimating firm (CCMI). 18

SCE’s response properly disclosed CCMI’s estimating methodology (including all the factors CCMI 19

considered in developing the estimate such as, scope of work, drawings, level of design, phasing of 20

project, hours of operation, open shop or union, contractor bond requirements, etc.) and provided a more 21

detailed breakdown of CCMI’s planning estimate (including line by line division activity, quantity, unit 22

of measure, unit cost and activity cost total.)47 SCE’s direct testimony discussed CCMI’s role in 23

44 Exhibit SCE-06, Vol. 05, p. 14, lines 3 - 23. 45 See Exhibit SCE-18, Vol. 1, Chapter II. 46 Exhibit SCE-06, Vol. 05, pp. 43 - 44. 47 See Appendix to this Rebuttal Volume, pp. A-31- A-34 (SCE’s Response to TURN-SCE-030, Question 18.).

Although TURN includes the body of the response as part of the attachments to TURN-10, TURN did not include the detailed cost estimate breakdown that was included with the response. See TURN-10, Attachments, pp. 9 - 10.

18

preparing the planning estimates for the Facility and Land Operations BPE capital projects and the 1

sources of information relied upon by CCMI in preparing those estimates.48 2

As such, TURN’s citation to SCE’s data request response 3

does not reflect a failure by SCE’s to support the project forecasts. Given the actual construction work 4

had not commenced, there were no bids, contracts or invoices to be provided at that time and SCE 5

properly provided supporting information about CCMI’s planning estimate as specifically requested by 6

TURN. Moreover, although SCE has made changes in scope for the reason outlined earlier and in its 7

direct testimony, SCE’s forecast remains consistent with the forecast presented in the 2021 GRC. As 8

such, TURN’s argument concerning SCE’s failure to provide sufficient support for its forecast should be 9

rejected. 10

(3) Conclusion 11

Based upon the foregoing, SCE respectfully requests that the Commission 12

reject TURN’s proposed disallowance and adopt SCE’s forecast of $22.646 million for the Vehicle 13

Maintenance Facilities projects. 14

2. Substation Reliability Upgrades 15

SCE’s Substation Maintenance and Test Building program seeks to replace temporary 16

and outdated substation facilities. SCE forecasts expenditures for the updates to the Devers and Rector 17

Maintenance and Test Buildings totaling $15.005 million from 2019 to 2020.49 TURN recommends 18

complete disallowance of SCE’s forecast for this program.50 SCE’s rebuttal position in Table I-10 below 19

is updated to reflect 2019 recorded capital expenditures across each project. 20

48 Exhibit SCE-06, Vol. 05, p. 25, line 14 - p. 26, line 7. 49 Exhibit SCE-06, Vol. 05, p. 78. 50 Exhibit TURN-10, p. 16.

19

Table I-10 Substation Reliability Upgrades


(Nominal $000)

a) Devers Maintenance and Test Building 1


The upgrade project for Devers Maintenance and Test Building is 3

necessary to address age, condition, and operational inefficiency (including lack of sufficient space for 4

storage and operations). The expansion of the facility will improve productivity by creating additional 5

space for equipment and collaborative workspaces. SCE’s forecast for the upgrade of the Devers 6

Maintenance and Test Building is $5.005 million.51 Table I-11 below, includes SCE’s rebuttal position 7

incorporating 2019 recorded expenditures in place of the 2019 forecast. 8

51 Exhibit SCE-06, Vol. 05, p. 79, lines 4 - 17.

Line No.

Substation Reliability Upgrades

2019 Recorded

2020 Forecast

2021 Forecast

2022 Forecast

2023 Forecast

Total2019-2023 2019 2020 2021 2022 2023

Total2019-2023


1Devers Maintenance & Test Building 1,178 1,557 - - - 2,735 - - - - - - (2,735)

2Rector Maintenance & Test Building 4,526 3,520 - - - 8,046 - - - - - - (8,046)

Total 5,704 5,077 - - - 10,781 - - - - - - (10,781)

SCE Rebuttal Position TURN Position

20

Table I-11 Devers Maintenance and Test Building Capital Expenditures


(Nominal $000)

(2) TURN 1


TURN recommends no funding for the Devers Maintenance and 3

Test Building project. TURN’s recommendation is based on the following arguments52: 4

SCE failed to complete the project during the preceding GRC 5

cycle and did not spend all the funds authorized for the project 6

in the 2018 GRC Decision. 7

TURN asserts that SCE’s Planning Estimate is not adequate 8

support for this project. 9



documents SCE’s commitment to completing this 12

project. 13

SCE has recorded costs on this project continuously from 14

2016 through the present.53 Although the start date of this project was delayed for reasons detailed in 15

SCE’s direct testimony (including modification of scope and local public use permitting requirements), 16

the project entered the planning stage in 2018 and is presently in the midst of construction.54 The 17

concrete slabs have been poured, structural steel has been erected and stud walls are being installed. The 18

52 Exhibit TURN-10, p. 17. 53 Exhibit TURN-10, p. 16, Footnote 36. 54 Exhibit SCE-06, Vol. 05, p. 79. lines 5 - 12.

Line No.

Devers Maintenance & Test Building 2019 2020 2021 2022 2023 TOTAL

1 SCE Application 3,086 1,557 - - - 4,643 2 TURN Recommendation - - - - - - 3 Variance (3,086) (1,557) - - - (4,643) 4 SCE Rebuttal Position 1,178 1,557 - - - 2,735

21

project is on track to be completed before the end of 2020. By the end of 2019, SCE incurred 1

expenditures representing 31% of the authorized funds for this project in the 2018 GRC Decision. 2

Given the significant progress on this project, TURN’s 3

contention that the delayed completion warrants a complete disallowance should be rejected. 4

Additionally, TURN does not appear to take issue with the reasonableness of or need for this project.55 5

While the overall schedule of the project may have shifted due to the events discussed in the testimony, 6

the project is slated for completion in 2020 and in line with the current forecast.56 7


referred to by TURN (included in the workpapers) were 9

produced by independent third party. 10

As with other projects, TURN asserts that SCE has not 11

submitted sufficient information concerning its forecast, relying on SCE’s response to a data requesting 12

that solely requested support for a workpaper containing the planning estimate. SCE’s response provided 13

CCMI’s estimating methodology (including all the factors CCMI considered in developing the estimate 14

such as, scope of work, drawings, level of design, phasing of project, hours of operation, open shop or 15

union, contractor bond requirements, etc.) and provided a more detailed breakdown of CCMI’s planning 16

estimate (including line by line division activity, quantity, unit of measure, unit cost and activity cost 17

total).57 18

TURN’s citation to SCE’s data request response does not 19

reflect a failure by SCE’s to support the project’s forecast. By requesting “support” for the planning 20

estimate workpaper itself, SCE reasonably understood the data request to seek information relating basis 21

for the estimate which did not rely on actual bids, contracts or invoices. TURN’s reliance on SCE’s 22

response is unavailing and does not serve as a basis to contest the forecast. As such, TURN’s argument 23

concerning SCE’s failure to provide sufficient support for its forecast should be rejected. 24

55 As discussed earlier, TURN’s argument for blanket disallowance due to SCE’s reallocation of authorized

funds to complete other prudent and beneficial projects after construction work was delayed on this project should be rejected. See also Exhibit SCE-18, Vol. 1, Chapter II.

56 Exhibit SCE-06, Vol. 05, p. 80, lines 15 - 19. 57 See Appendix to this Rebuttal Volume, pp. A-35-A-38 (SCE’s Response to TURN-SCE-030, Question 48.).

Although TURN includes the body of the response as part of the attachments to TURN-10, TURN did not include the detailed cost estimate breakdown that was included with the response. See TURN-10, Attachments, pp. 11 - 12.

22

(3) Conclusion 1

As SCE has made significant progress on the project and construction is 2

ongoing, SCE’s commitment to the project is not subject to reasonable dispute and SCE’s detailed 3

planning estimate created by a third-party estimating firm fully supports the project’s forecast. 4

Accordingly, TURN’s proposed disallowance for the Devers Maintenance and Test Building project 5

should be rejected and SCE’s forecast of $2.735 million for the Devers Maintenance and Test Building 6

project should be adopted. 7

b) Rector Maintenance and Test Building 8


The Rector Maintenance and Test Building project addresses the age and 10

condition of the facility and workspace limitations. The crews are currently situated in temporary trailers 11

whose occupancy permits are expiring and cannot be extended. SCE’s forecast for the Rector 12

Maintenance and Test Building project is $11.035 million.58 Table I-12 below, includes SCE’s rebuttal 13

position incorporating 2019 recorded expenditures in place of the 2019 forecast. 14

Table I-12 Rector Maintenance and Test Building Capital Expenditures


(Nominal $000)

(2) TURN 15


TURN recommends no funding for the Rector Maintenance and 17

Test Building project. TURN’s recommendation is based on the following arguments:59 18

58 Exhibit SCE-06, Vol. 05, p. 81, lines 8 - 10 and p. 82, lines 1 - 5. 59 Exhibit TURN-10, pp. 18 - 19.

Line No.

Rector Maintenance & Test Building 2019 2020 2021 2022 2023 TOTAL

1 SCE Application 6,842 3,520 - - - 10,362 2 TURN Recommendation - - - - - - 3 Variance (6,842) (3,520) - - - (10,362) 4 SCE Rebuttal Position 4,526 3,520 - - - 8,046

23

SCE failed to complete the project during the preceding GRC 1

cycle and did not spent all the funds authorized for the project 2

in the 2018 GRC Decision. 3

TURN asserts that SCE’s Planning Estimate is not adequate 4

support for this project. 5



documents SCE’s commitment to completing this 8

project. 9

Although SCE has experienced delays in completing the 10

project for the reasons detailed in its direct testimony,60 SCE has continued to pursue the project 11

incurring recorded expenditures from 2016 through the present.61 By the end of 2019, SCE’s recorded 12

expenditures for the project represented 47% of the authorized amount. Currently, the project is in the 13

middle of construction and on track for completion in 2020. The exterior walls and roof are complete 14

and interior and sitework is underway. Like the Devers Maintenance and Test Building Project, TURN 15

does not appear to take issue with the reasonableness of or justification for this project. 16

Notwithstanding delayed completion and since the project 17

is currently in the middle of the construction phase and slated for completion in 2020, in line with the 18

current forecast, TURN’s contention that funding should be completely disallowed as a result of such 19

delay should be rejected.62 20


referred to by TURN (included in the workpapers) were 22

produced by independent third party. 23

As with other projects, TURN cites SCE’s response to a 24

data requesting seeking supporting information for a planning estimate workpaper to argue SCE failed to 25

sufficiently support its forecast for the Rector Maintenance and Test Building Project. As the data 26

60 Exhibit SCE-06, Vol. 05, p. 80, line 21 - p. 81 line 7. 61 Exhibit TURN-10, p. 10, Footnote 48. 62 As discussed earlier, TURN’s argument for blanket disallowance due to SCE’s reallocation of authorized

funds to complete other prudent and beneficial projects after construction work was delayed on this project should be rejected. See also, Exhibit SCE-18, Vol. 1, Chapter II.

24

request asked, SCE’s response focused on CCMI’s estimating methodology (including all the factors 1

CCMI considered in developing the estimate such as, scope of work, drawings, level of design, phasing 2

of project, hours of operation, open shop or union, contractor bond requirements, etc.) and a more 3

detailed breakdown of CCMI’s planning estimate, including line by line division activity, quantity, unit 4

of measure, unit cost and activity cost total.63 TURN’s data request sought “support” for the planning 5

estimate workpaper itself and SCE’s response reflects that the estimate was not based on bids, contracts 6

or invoices, but was rather based on CCMI’s methodology and related proprietary source materials.64 As 7

such, TURN’s reliance on SCE’s response is unavailing and its argument concerning SCE’s failure to 8

provide sufficient support for the forecast should be rejected. 9

(3) Conclusion 10

The delayed completion of the Rector Maintenance and Test Building 11

project does not warrant a complete disallowance of funding. SCE’s detailed planning estimate fully 12

supports the forecast and the project is expected to be completed by the end of 2020. Accordingly, 13

TURN’s recommended disallowance should be rejected, and SCE respectfully requests the Commission 14

adopt SCE’s forecast of $8.046 million for Rector Maintenance and Test Building project. 15

63 See Appendix to this Rebuttal Volume, pp. A-39–A-42 (SCE’s Response to TURN-SCE-030, Question 52).

Although TURN includes the body of the response as part of the attachments to TURN-10, TURN did not include the detailed cost estimate breakdown that was included with the response. See TURN-10, Attachments, pp. 14-15.

64 Exhibit SCE-06, Vol. 05, p. 25, line 14 - p. 26, line 7.

Appendix A

SCE 17, Vol. 5

Workpaper Index

SCE-17, Vol. 05: Rebuttal Testimony on Enterprise Operations

Facility and Land Operations Appendix A Workpaper Index

Workpaper PAGE(S)

Code of Federal Regulations, Title 18, Chapter 1, Subchapter C, Part 101, Electric Plant Instructions, Chapter 7 A-1-15

Decision 1988, D. 87-12-066, Section J, Plants Held for Future Use A-16-20 Amended Scoping Memo and Ruling of Assigned Commission and Assigned Administrative Law Judges dated April 10, 2020, p. 5 A-21-22

2018 GRC, Exhibit SCE-07, Vol. 03, Book C, p. 332 A-23-24

Decision 2020, D. 19-05-020, p. 227 A-25-26

TURN-SCE-030, Question 14, with attachment A-27-30




Code of Federal Regulations, Title 18, Chapter 1, Subchapter C, Part 101, Electric Plant Instructions, Chapter 7

A-1

399

Federal Energy Regulatory Commission Pt. 101

of the asset retirement costs and re-lated accumulated depreciation, and the settlement date and actual amount paid to settle the obligation. For pur-poses of analyses a utility shall main-tain supporting documentation so as to be able to furnish accurately and expe-ditiously with respect to each asset re-tirement obligation the full details of the identity and nature of the legal ob-ligation, the year incurred, the iden-

tity of the plant giving rise to the obli-

gation, the full particulars relating to

each component and supporting com-

putations related to the measurement

of the asset retirement obligation.

Electric Plant Instructions

1. Classification of electric plant at ef-fective date of system of accounts (Major utilities).

A. The electric plant accounts pro-

vided herein are the same as those con-

tained in the prior system of accounts

except for inclusion of accounts for nu-

clear production plant and some

changes in classification in the general

equipment accounts. Except for these

changes, the balances in the various

plant accounts, as determined under

the prior system of accounts, should be

carried forward. Any remaining bal-

ance of plant which has not yet been

classified, pursuant to the require-

ments of the prior system, shall be

classified in accordance with the fol-

lowing instructions. B. The cost to the utility of its un-

classified plant shall be ascertained by

analysis of the utility’s records. Ad-

justments shall not be made to record

in utility plant accounts amounts pre-

viously charged to operating expenses

or to income deductions in accordance

with the uniform system of accounts in

effect at the time or in accordance

with the discretion of management as

exercised under a uniform system of

accounts, or under accounting prac-

tices previously followed. C. The detailed electric plant ac-

counts (301 to 399, inclusive) shall be

stated on the basis of cost to the util-

ity of plant constructed by it and the

original cost, estimated if not known,

of plant acquired as an operating unit

or system. The difference between the

original cost, as above, and the cost to

the utility of electric plant after giving

effect to any accumulated provision for

depreciation or amortization shall be

recorded in account 114, Electric Plant

Acquisition Adjustments. The original

cost of electric plant shall be deter-

mined by analysis of the utility’s

records or those of the predecessor or

vendor companies with respect to elec-

tric plant previously acquired as oper-

ating units or systems and the dif-

ference between the original cost so de-

termined, less accumulated provisions

for depreciation and amortization and

the cost to the utility with necessary

adjustments for retirements from the

date of acquisition, shall be entered in

account 114, Electric Plant Acquisition

Adjustments. Any difference between

the cost of electric plant and its book

cost, when not properly includible in

other accounts, shall be recorded in ac-

count 116, Other Electric Plant Adjust-

ments.

D. Plant acquired by lease which

qualifies as capital lease property

under General Instruction 19. Criteria for Classifying Leases, shall be recorded

in Account 101.1, Property under Cap-

ital Leases, or Account 120.6, Nuclear

Fuel under Capital Leases, as appro-

priate.

2. Electric Plant To Be Recorded at Cost.

A. All amounts included in the ac-

counts for electric plant acquired as an

operating unit or system, except as

otherwise provided in the texts of the

intangible plant accounts, shall be

stated at the cost incurred by the per-

son who first devoted the property to

utility service. All other electric plant

shall be included in the accounts at the

cost incurred by the utility, except for

property acquired by lease which quali-

fies as capital lease property under

General Instruction 19. Criteria for Classifying Leases, and is recorded in

Account 101.1, Property under Capital

Leases, or Account 120.6, Nuclear Fuel

under Capital Leases. Where the term

cost is used in the detailed plant ac-

counts, it shall have the meaning stat-

ed in this paragraph.

B. When the consideration given for

property is other than cash, the value

of such consideration shall be deter-

mined on a cash basis (see, however,

definition 9). In the entry recording

VerDate Mar<15>2010 09:39 Apr 21, 2011 Jkt 223057 PO 00000 Frm 00409 Fmt 8010 Sfmt 8010 Y:\SGML\223057.XXX 223057WR

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18 CFR Ch. I (4–1–11 Edition) Pt. 101

such transition, the actual consider-

ation shall be described with sufficient

particularity to identify it. The utility

shall be prepared to furnish the Com-

mission the particulars of its deter-

mination of the cash value of the con-

sideration if other than cash.

C. When property is purchased under

a plan involving deferred payments, no

charge shall be made to the electric

plant accounts for interest, insurance,

or other expenditures occasioned solely

by such form of payment.

D. The electric plant accounts shall

not include the cost or other value of

electric plant contributed to the com-

pany. Contributions in the form of

money or its equivalent toward the

construction of electric plant shall be

credited to accounts charged with the

cost of such construction. Plant con-

structed from contributions of cash or

its equivalent shall be shown as a re-

duction to gross plant constructed

when assembling cost data in work or-

ders for posting to plant ledgers of ac-

counts. The accumulated gross costs of

plant accumulated in the work order

shall be recorded as a debit in the plant

ledger of accounts along with the re-

lated amount of contributions concur-

rently be recorded as a credit.

3. Components of construction cost. A. For Major utilities, the cost of

construction properly includible in the

electric plant accounts shall include,

where applicable, the direct and over-

head cost as listed and defined here-

under:

(1) Contract work includes amounts

paid for work performed under contract

by other companies, firms, or individ-

uals, costs incident to the award of

such contracts, and the inspection of

such work.

(2) Labor includes the pay and ex-

penses of employees of the utility en-

gaged on construction work, and re-

lated workmen’s compensation insur-

ance, payroll taxes and similar items of

expense. It does not include the pay

and expenses of employees which are

distributed to construction through

clearing accounts nor the pay and ex-

penses included in other items here-

under.

(3) Materials and supplies includes the

purchase price at the point of free de-

livery plus customs duties, excise

taxes, the cost of inspection, loading and transportation, the related stores expenses, and the cost of fabricated materials from the utility’s shop. In determining the cost of materials and supplies used for construction, proper allowance shall be made for unused materials and supplies, for materials recovered from temporary structures used in performing the work involved, and for discounts allowed and realized in the purchase of materials and sup-plies.

NOTE: The cost of individual items of

equipment of small value (for example, $500

or less) or of short life, including small port-

able tools and implements, shall not be

charged to utility plant accounts unless the

correctness of the accounting therefor is

verified by current inventories. The cost

shall be charged to the appropriate operating

expense or clearing accounts, according to

the use of such items, or, if such items are

consumed directly in construction work, the

cost shall be included as part of the cost of

the construction

(4) Transportation includes the cost of transporting employees, materials and supplies, tools, purchased equipment, and other work equipment (when not under own power) to and from points of construction. It includes amounts paid to others as well as the cost of oper-ating the utility’s own transportation equipment. (See item 5 following.)

(5) Special machine service includes the cost of labor (optional), materials and supplies, depreciation, and other ex-penses incurred in the maintenance, operation and use of special machines, such as steam shovels, pile drivers, der-ricks, ditchers, scrapers, material unloaders, and other labor saving ma-chines; also expenditures for rental, maintenance and operation of ma-chines of others. It does not include the

cost of small tools and other individual

items of small value or short life which

are included in the cost of materials

and supplies. (See item 3, above.) When

a particular construction job requires

the use for an extended period of time

of special machines, transportation or

other equipment, the net book cost

thereof, less the appraised or salvage

value at time of release from the job,

shall be included in the cost of con-

struction. (6) Shop service includes the propor-

tion of the expense of the utility’s shop


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department assignable to construction

work except that the cost of fabricated

materials from the utility’s shop shall

be included in materials and supplies. (7) Protection includes the cost of pro-

tecting the utility’s property from fire

or other casualties and the cost of pre-

venting damages to others, or to the

property of others, including payments

for discovery or extinguishment of

fires, cost of apprehending and pros-

ecuting incendiaries, witness fees in re-

lation thereto, amounts paid to mu-

nicipalities and others for fire protec-

tion, and other analogous items of ex-

penditures in connection with con-

struction work.

(8) Injuries and damages includes ex-

penditures or losses in connection with

construction work on account of inju-

ries to persons and damages to the

property of others; also the cost of in-

vestigation of and defense against ac-

tions for such injuries and damages. In-

surance recovered or recoverable on ac-

count of compensation paid for injuries

to persons incident to construction

shall be credited to the account or ac-

counts to which such compensation is

charged Insurance recovered or recov-

erable on account of property damages

incident to construction shall be cred-

ited to the account or accounts

charged with the cost of the damages.

(9) Privileges and permits includes pay-

ments for and expenses incurred in se-

curing temporary privileges, permits or

rights in connection with construction

work, such as for the use of private or

public property, streets, or highways,

but it does not include rents, or

amounts chargeable as franchises and

consents for which see account 302,

Franchises and Consents.

(10) Rents includes amounts paid for

the use of construction quarters and of-

fice space occupied by construction

forces and amounts properly includible

in construction costs for such facilities

jointly used.

(11) Engineering and supervision in-

cludes the portion of the pay and ex-

penses of engineers, surveyors,

draftsmen, inspectors, superintendents

and their assistants applicable to con-

struction work.

(12) General administration capitalized includes the portion of the pay and ex-

penses of the general officers and ad-

ministrative and general expenses ap-

plicable to construction work.

(13) Engineering services includes

amounts paid to other companies,

firms, or individuals engaged by the

utility to plan, design, prepare esti-

mates, supervise, inspect, or give gen-

eral advice and assistance in connec-

tion with construction work.

(14) Insurance includes premiums paid

or amounts provided or reserved as

self-insurance for the protection

against loss and damages in connection

with construction, by fire or other cas-

ualty injuries to or death of persons

other than employees, damages to

property of others, defalcation of em-

ployees and agents, and the non-

performance of contractual obligations

of others. It does not include work-

men’s compensation or similar insur-

ance on employees included as labor in

item 2, above.

(15) Law expenditures includes the

general law expenditures incurred in

connection with construction and the

court and legal costs directly related

thereto, other than law expenses in-

cluded in protection, item 7, and in in-

juries and damages, item 8.

(16) Taxes includes taxes on physical

property (including land) during the

period of construction and other taxes

properly includible in construction

costs before the facilities become avail-

able for service.

(17) Allowance for funds used during construction (Major and Nonmajor Util-

ities) includes the net cost for the pe-

riod of construction of borrowed funds

used for construction purposes and a

reasonable rate on other funds when so

used, not to exceed, without prior ap-

proval of the Commission, allowances

computed in accordance with the for-

mula prescribed in paragraph (a) of this

subparagraph. No allowance for funds

used during construction charges shall

be included in these accounts upon ex-

penditures for construction projects

which have been abandoned.

(a) The formula and elements for the

computation of the allowance for funds

used during construction shall be:

Ai=s(S/W)+d(D/D+P+C)(1¥S/W)

Ae=[1¥S/W][p(P/D+P+C)+c(C/D+P+C)]

Ai=Gross allowance for borrowed funds used

during construction rate.


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Ae=Allowance for other funds used during

construction rate.

S=Average short-term debt.

s=Short-term debt interest rate.

D=Long-term debt.

d=Long-term debt interest rate.

P=Preferred stock.

p=Preferred stock cost rate.

C=Common equity.

c=Common equity cost rate.

W= Average balance in construction work in

progress plus nuclear fuel in process of re-

finement, conversion, enrichment and fab-

rication, less asset retirement costs (See

General Instruction 25) related to plant

under construction.

(b) The rates shall be determined an-

nually. The balances for long-term

debt, preferred stock and common eq-

uity shall be the actual book balances

as of the end of the prior year. The cost

rates for long-term debt and preferred

stock shall be the weighted average

cost determined in the manner indi-

cated in § 35.13 of the Commission’s

Regulations Under the Federal Power

Act. The cost rate for common equity

shall be the rate granted common eq-

uity in the last rate proceeding before

the ratemaking body having primary

rate jurisdictions. If such cost rate is

not available, the average rate actually

earned during the preceding three

years shall be used. The short-term

debt balances and related cost and the

average balance for construction work

in progress plus nuclear fuel in process

of refinement, conversion, enrichment,

and fabrication shall be estimated for

the current year with appropriate ad-

justments as actual data becomes

available.

NOTE: When a part only of a plant or

project is placed in operation or is completed

and ready for service but the construction

work as a whole is incomplete, that part of

the cost of the property placed in operation

or ready for service, shall be treated as Elec-

tric Plant in Service and allowance for funds

used during construction thereon as a charge

to construction shall cease. Allowance for

funds used during construction on that part

of the cost of the plant which is incomplete

may be continued as a charge to construc-

tion until such time as it is placed in oper-

ation or is ready for service, except as lim-

ited in item 17, above.

(18) Earnings and expenses during con-struction. The earnings and expenses

during construction shall constitute a

component of construction costs.

(a) The earnings shall include reve-

nues received or earned for power pro-

duced by generating plants during the

construction period and sold or used by

the utility. Where such power is sold to

an independent purchaser before inter-

mingling with power generated by

other plants, the credit shall consist of

the selling price of the energy. Where

the power generated by a plant under

construction is delivered to the util-

ity’s electric system for distribution

and sale, or is delivered to an associ-

ated company, or is delivered to and

used by the utility for purposes other

than distribution and sale (for manu-

facturing or industrial use, for exam-

ple), the credit shall be the fair value

of the energy so delivered. The reve-

nues shall also include rentals for

lands, buildings etc., and miscellaneous

receipts not properly includible in

other accounts.

(b) The expenses shall consist of the

cost of operating the power plant, and

other costs incident to the production

and delivery of the power for which

construction is credited under para-

graph (a), above, including the cost of

repairs and other expenses of operating

and maintaining lands, buildings, and

other property, and other miscella-

neous and like expenses not properly

includible in other accounts.

(19) Training costs (Major and

Nonmajor Utilities). When it is nec-

essary that employees be trained to op-

erate or maintain plant facilities that

are being constructed and such facili-

ties are not conventional in nature, or

are new to the company’s operations,

these costs may be capitalized as a

component of construction cost. Once

plant is placed in service, the capital-

ization of training costs shall cease and

subsequent training costs shall be ex-

pensed. (See Operating Expense In-

struction 4.)

(20) Studies includes the costs of stud-

ies such as nuclear operational, safety,

or seismic studies or environmental

studies mandated by regulatory bodies

relative to plant under construction.

Studies relative to facilities in service

shall be charged to account 183, Pre-

liminary Survey and Investigation

Charges.


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(21) Asset retirement costs. The costs

recognized as a result of asset retire-

ment obligations incurred during the

construction and testing of utility

plant shall constitute a component of

construction costs.

B. For Nonmajor utilities, the cost of

construction of property chargeable to

the electric plant accounts shall in-

clude, where applicable, the cost of

labor; materials and supplies; transpor-

tation; work done by others for the

utility; injuries and damages incurred

in construction work; privileges and

permits; special machine service; al-

lowance for funds used during con-

struction, not to exceed without prior

approval of the Commission, amounts

computed in accordance with the for-

mula prescribed in paragraph (a) of

paragraph (17) of this Instruction;

training costs; and such portion of gen-

eral engineering, administrative sala-

ries and expenses, insurance, taxes, and

other analogous items as may be prop-

erly includable in construction costs.

(See Operating Expense Instruction 4.)

The rates and balances of short and

long-term debt, preferred stock, com-

mon equity and construction work in

progress shall be determined as pre-

scribed in paragraph (b) of paragraph

(17) of this Instruction.

4. Overhead Construction Costs. A. All overhead construction costs,

such as engineering, supervision, gen-

eral office salaries and expenses, con-

struction engineering and supervision

by others than the accounting utility,

law expenses, insurance, injuries and

damages, relief and pensions, taxes and

interest, shall be charged to particular

jobs or units on the basis of the

amounts of such overheads reasonably

applicable thereto, to the end that each

job or unit shall bear its equitable pro-

portion of such costs and that the en-

tire cost of the unit, both direct and

overhead, shall be deducted from the

plant accounts at the time the prop-

erty is retired.

B. As far as practicable, the deter-

mination of pay roll charges includible

in construction overheads shall be

based on time card distributions there-

of. Where this procedure is impractical,

special studies shall be made periodi-

cally of the time of supervisory em-

ployees devoted to construction activi-

ties to the end that only such overhead

costs as have a definite relation to con-

struction shall be capitalized. The ad-

dition to direct construction costs of

arbitrary percentages or amounts to

cover assumed overhead costs is not

permitted.

C. For Major utilities, the records

supporting the entries for overhead

construction costs shall be so kept as

to show the total amount of each over-

head for each year, the nature and

amount of each overhead expenditure

charged to each construction work

order and to each electric plant ac-

count, and the bases of distribution of

such costs.

5. Electric Plant Purchased or Sold.

A. When electric plant constituting

an operating unit or system is acquired

by purchase, merger, consolidation, liq-

uidation, or otherwise, after the effec-

tive date of this system of accounts,

the costs of acquisition, including ex-

penses incidental thereto properly in-

cludible in electric plant, shall be

charged to account 102, Electric Plant

Purchased or Sold.

B. The accounting for the acquisition

shall then be completed as follows:

(1) The original cost of plant, esti-

mated if not known, shall be credited

to account 102, Electric Plant Pur-

chased or Sold, and concurrently

charged to the appropriate electric

plant in service accounts and to ac-

count 104, Electric Plant Leased to

Others, account 105, Electric Plant

Held for Future Use, and account 107,

Construction Work in Progress—Elec-

tric, as appropriate.

(2) The depreciation and amortiza-

tion applicable to the original cost of

the properties purchased shall be

charged to account 102, Electric Plant

Purchased or Sold, and concurrently

credited to the appropriate account for

accumulated provision for depreciation

or amortization.

(3) The cost to the utility of any

property includible in account 121,

Nonutility Property, shall be trans-

ferred thereto.

(4) The amount remaining in account

102, Electric Plant Purchased or Sold,

shall then be closed to account 114,

Electric Plant Acquisition Adjust-

ments.


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C. If property acquired in the pur-

chase of an operating unit or system is

in such physical condition when ac-

quired that it is necessary substan-

tially to rehabilitate it in order to

bring the property up to the standards

of the utility, the cost of such work,

except replacements, shall be ac-

counted for as a part of the purchase

price of the property.

D. When any property acquired as an

operating unit or system includes du-

plicate or other plant which will be re-

tired by the accounting utility in the

reconstruction of the acquired property

or its consolidation with previously

owned property, the proposed account-

ing for such property shall be presented

to the Commission.

E. In connection with the acquisition

of electric plant constituting an oper-

ating unit or system, the utility shall

procure, if possible, all existing records

relating to the property acquired, or

certified copies thereof, and shall pre-

serve such records in conformity with

regulations or practices governing the

preservation of records of its own con-

struction.

F. When electric plant constituting

an operating unit or system is sold,

conveyed, or transferred to another by

sale, merger, consolidation, or other-

wise, the book cost of the property sold

or transferred to another shall be cred-

ited to the appropriate utility plant ac-

counts, including amounts carried in

account 114, Electric Plant Acquisition

Adjustments. The amounts (estimated

if not known) carried with respect

thereto in the accounts for accumu-

lated provision for depreciation and

amortization and in account 252, Cus-

tomer Advances for Construction, shall

be charged to such accounts and contra

entries made to account 102, Electric

Plant Purchased or Sold. Unless other-

wise ordered by the Commission, the

difference, if any, between (1) the net

amount of debits and credits and (2)

the consideration received for the prop-

erty (less commissions and other ex-

penses of making the sale) shall be in-

cluded in account 421.1. Gain on Dis-

position of Property, or account 421.2,

Loss on Disposition of Property. (See

account 102, Electric Plant Purchased

or Sold.)

NOTE: In cases where existing utilities

merge or consolidate because of financial or

operating reasons or statutory requirements

rather than as a means of transferring title

of purchased properties to a new owner, the

accounts of the constituent utilities, with

the approval of the Commission, may be

combined. In the event original cost has not

been determined, the resulting utility shall

proceed to determine such cost as outlined

herein.

6. Expenditures on Leased Property. A. The cost of substantial initial im-

provements (including repairs, rear-

rangements, additions, and better-

ments) made in the course of preparing

for utility service property leased for a

period of more than one year, and the

cost of subsequent substantial addi-

tions, replacements, or betterments to

such property, shall be charged to the

electric plant account appropriate for

the class of property leased. If the serv-

ice life of the improvements is ter-

minable by action of the lease, the

cost, less net salvage, of the improve-

ments shall be spread over the life of

the lease by charges to account 404,

Amortization of Limited-Term Electric

Plant. However, if the service life is

not terminated by action of the lease

but by depreciation proper, the cost of

the improvements, less net salvage,

shall be accounted for as depreciable

plant. The provisions of this paragraph

are applicable to property leased under

either capital leases or operating

leases. B. If improvements made to property

leased for a period of more than one

year are of relatively minor cost, or if

the lease is for a period of not more

than one year, the cost of the improve-

ments shall be charged to the account

in which the rent is included, either di-

rectly or by amortization thereof. 7. Land and Land Rights. A. The accounts for land and land

rights shall include the cost of land

owned in fee by the utility and rights.

Interests, and privileges held by the

utility in land owned by others, such as

leaseholds, easements, water and water

power rights, diversion rights, submer-

sion rights, rights-of-way, and other

like interests in land. Do not include in

the accounts for land and land rights

and rights-of-way costs incurred in

connection with first clearing and

grading of land and rights-of-way and


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the damage costs associated with the

construction and installation of plant.

Such costs shall be included in the ap-

propriate plant accounts directly bene-

fited.

B. Where special assessments for pub-

lic improvements provide for deferred

payments, the full amount of the as-

sessments shall be charged to the ap-

propriate land account and the unpaid

balance shall be carried in an appro-

priate liability account. Interest on un-

paid balances shall be charged to the

appropriate interest account. If any

part of the cost of public improvements

is included in the general tax levy, the

amount thereof shall be charged to the

appropriate tax account.

C. The net profit from the sale of

timber, cord wood, sand, gravel, other

resources or other property acquired

with the rights-of-way or other lands

shall be credited to the appropriate

plant account to which related. Where

land is held for a considerable period of

time and timber and other natural re-

sources on the land at the time of pur-

chase increases in value, the net profit

(after giving effect to the cost of the

natural resources) from the sales of

timber or its products or other natural

resources shall be credited to the ap-

propriate utility operating income ac-

count when such land has been re-

corded in account 105, Electric Plant

Held for Future Use or classified as

plant in service, otherwise to account

421, Miscellaneous Nonoperating In-

come.

D. Separate entries shall be made for

the acquisition, transfer, or retirement

of each parcel of land, and each land

right (except rights of way for distribu-

tion lines), or water right, having a life

of more than one year. A record shall

be maintained showing the nature of

ownership, full legal description, area,

map reference, purpose for which used,

city, county, and tax district on which

situated, from whom purchased or to

whom sold, payment given or received,

other costs, contract date and number,

date of recording of deed, and book and

page of record. Entries transferring or

retiring land or land rights shall refer

to the original entry recording its ac-

quisition.

E. Any difference between the

amount received from the sale of land

or land rights, less agents’ commis-

sions and other costs incident to the

sale, and the book cost of such land or

rights, shall be included in account

411.6, Gains from Disposition of Utility

Plant, or 411.7, Losses from Disposition

of Utility Plant when such property

has been recorded in account 105, Elec-

tric Plant Held for Future Use, other-

wise to account 421.1, Gain on Disposi-

tion of Property or 421.2, Loss on Dis-

position of Property, as appropriate,

unless a reserve therefor has been au-

thorized and provided. Appropriate ad-

justments of the accounts shall be

made with respect to any structures or

improvements located on land sold.

F. The cost of buildings and other

improvements (other than public im-

provements) shall not be included in

the land accounts. If at the time of ac-

quisition of an interest in land such in-

terest extends to buildings or other im-

provements (other than public im-

provements) which are then devoted to

utility operations, the land and im-

provements shall be separately ap-

praised and the cost allocated to land

and buildings or improvements on the

basis of the appraisals. If the improve-

ments are removed or wrecked without

being used in operations, the cost of re-

moving or wrecking shall be charged

and the salvage credited to the account

in which the cost of the land is re-

corded.

G. When the purchase of land for

electric operations requires the pur-

chase of more land than needed for

such purposes, the charge to the spe-

cific land account shall be based upon

the cost of the land purchased, less the

fair market value of that portion of the

land which is not to be used in utility

operations. The portion of the cost

measured by the fair market value of

the land not to be used shall be in-

cluded in account 105, Electric Plant

Held for Future Use, or account 121,

Nonutility Property, as appropriate.

H. Provisions shall be made for amor-

tizing amounts carried in the accounts

for limited-term interests in land so as

to apportion equitably the cost of each

interest over the life thereof. (For

Major utilities, see account 111, Accu-

mulated Provision for Amortization of

Electric Plant Utility, and account 404,

Amortization of Limited-Term Electric


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Plant. For Nonmajor utilities, see ac-

count 404.)

I. The items of cost to be included in

the accounts for land and land rights

are as follows:

1. Bulkheads, buried, not requiring mainte-

nance or replacement.

2. Cost, first, of acquisition including

mortgages and other liens assumed (but not

subsequent interest thereon).

3. [Reserved]

4. Condemnation proceedings, including

court and counsel costs.

5. Consents and abutting damages, pay-

ment for.

6. Conveyancers’ and notaries’ fees.

7. Fees, commissions, and salaries to bro-

kers, agents and others in connection with

the acquisition of the land or land rights.

8. [Reserved]

9. Leases, cost of voiding upon purchase to

secure possession of land.

10. Removing, relocating, or recon-

structing, property of others, such as build-

ings, highways, railroads, bridges, ceme-

teries, churches, telephone and power lines,

etc., in order to acquire quiet possession.

11. Retaining walls unless identified with

structures.

12. Special assessments levied by public au-

thorities for public improvements on the

basis of benefits for new roads, new bridges,

new sewers, new curbing, new pavements,

and other public improvements, but not

taxes levied to provide for the maintenance

of such improvements.

13. Surveys in connection with the acquisi-

tion, but not amounts paid for topographical

surveys and maps where such costs are at-

tributable to structures or plant equipment

erected or to be erected or installed on such

land.

14. Taxes assumed, accrued to date of

transfer of title.

15. Title, examining, clearing, insuring and

registering in connection with the acquisi-

tion and defending against claims relating to

the period prior to the acquisition.

16. Appraisals prior to closing title.

17. Cost of dealing with distributees or

legatees residing outside of the state or

county, such as recording power of attorney,

recording will or exemplification of will, re-

cording satisfaction of state tax.

18. Filing satisfaction of mortgage.

19. Documentary stamps.

20. Photographs of property at acquisition.

21. Fees and expenses incurred in the ac-

quisition of water rights and grants.

22. Cost of fill to extend bulkhead line over

land under water, where riparian rights are

held, which is not occasioned by the erection

of a structure.

23. Sidewalks and curbs constructed by the

utility on public property.

24. Labor and expenses in connection with

securing rights of way, where performed by

company employees and company agents.

8. Structures and Improvements. A. The accounts for structures and

improvements shall include the cost of

all buildings and facilities to house,

support, or safeguard property or per-

sons, including all fixtures perma-

nently attached to and made a part of

buildings and which cannot be removed

therefrom without cutting into the

walls, ceilings, or floors, or without in

some way impairing the buildings, and

improvements of a permanent char-

acter on or to land. Also include those

costs incurred in connection with the

first clearing and grading of land and

rights-of-way and the damage costs as-

sociated with construction and instal-

lation of plant. B. The cost of specially provided

foundations not intended to outlast the

machinery or apparatus for which pro-

vided, and the cost of angle irons, cast-

ings, etc., installed at the base of an

item of equipment, shall be charged to

the same account as the cost of the

machinery, apparatus, or equipment. C. Minor buildings and structures,

such as valve towers, patrolmen’s tow-

ers, telephone stations, fish and wild-

life, and recreation facilities, etc.,

which are used directly in connection

with or form a part of a reservoir, dam,

waterway, etc., shall be considered a

part of the facility in connection with

which constructed or operated and the

cost thereof accounted for accordingly. D. Where furnaces and boilers are

used primarily for furnishing steam for

some particular department and only

incidentally for furnishing steam for

heating a building and operating the

equipment therein, the entire cost of

such furnaces and boilers shall be

charged to the appropriate plant ac-

count, and no part to the building ac-

count. E. Where the structure of a dam

forms also the foundation of the power

plant building, such foundation shall

be considered a part of the dam. F. The cost of disposing of materials

excavated in connection with construc-

tion of structures shall be considered

as a part of the cost of such work, ex-

cept as follows: (a) When such material

is used for filling, the cost of loading,


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hauling, and dumping shall be equi-

tably apportioned between the work in

connection with which the removal oc-

curs and the work in connection with

which the material is used; (b) when

such material is sold, the net amount

realized from such sales shall be cred-

ited to the work in connection with

which the removal occurs. If the

amount realized from the sale of exca-

vated materials exceeds the removal

costs and the costs in connection with

the sale, the excess shall be credited to

the land account in which the site is

carried.

G. Lighting or other fixtures tempo-

rarily attached to buildings for pur-

poses of display or demonstration shall

not be included in the cost of the build-

ing but in the appropriate equipment

account.

H. The items of cost to be included in

the accounts for structures and im-

provements are as follows:

1. Architects’ plans and specifications in-

cluding supervision.

2. Ash pits (when located within the build-

ing). (Major Utilities)

3. Athletic field structures and improve-

ments.

4. Boilers, furnaces, piping, wiring, fix-

tures, and machinery for heating, lighting,

signaling, ventilating, and air-conditioning

systems, plumbing, vacuum cleaning sys-

tems, incinerator and smoke pipe, flues, etc.

5. Bulkheads, including dredging, riprap

fill, piling, decking, concrete, fenders, etc.,

when exposed and subject to maintenance

and replacement.

6. Chimneys (Major Utilities).

7. Coal bins and bunkers.

8. Commissions and fees to brokers, agents,

architects, and others.

9. Conduit (not to be removed) with its

contents.

10. Damages to abutting property during

construction.

11. Docks (Major Utilities).

12. Door checks and door stops (Major Util-

ities).

13. Drainage and sewerage systems.

14. Elevators, cranes, hoists, etc., and the

machinery for operating them.

15. Excavation, including shoring, bracing,

bridging, refill and disposal of excess exca-

vated material, cofferdams around founda-

tion, pumping water from cofferdams during

construction, and test borings.

16. Fences and fence curbs (not including

protective fences isolating items of equip-

ment, which shall be charged to the appro-

priate equipment account).

17. Fire protection systems when forming a

part of a structure. 18. Flagpole (Major Utilities). 19. Floor covering (permanently attached)

(Major Utilities). 20. Foundations and piers for machinery,

constructed as a permanent part of a build-

ing or other item listed herein. 21. Grading and clearing when directly oc-

casioned by the building of a structure. 22. Intrasite communication system, poles,

pole fixtures, wires, and cables. 23. Landscaping, lawns, shrubbery, etc. 24. Leases, voiding upon purchase to secure

possession of structures. 25. Leased property, expenditures on. 26. Lighting fixtures and outside lighting

system. 27. Mailchutes when part of a building

(Major Utilities). 28. Marquee, permanently attached to

building (Major Utilities). 29. Painting, first cost. 30. Permanent paving, concrete, brick,

flagstone, asphalt, etc., within the property

lines. 31. Partitions, including movable (Major

Utilities). 32. Permits and privileges. 33. Platforms, railings, and gratings when

constructed as a part of a structure.

34. Power boards for services to a building

(Major Utilities).

35. Refrigerating systems for general use

(Major Utilities).

36. Retaining walls except when identified

with land.

37. Roadways, railroads, bridges, and tres-

tles intrasite except railroads provided for in

equipment accounts.

38. Roofs (Major Utilities).

39. Scales, connected to and forming a part

of a structure (Major Utilities).

40. Screens (Major Utilities).

41. Sewer systems, for general use (Major

Utilities).

42. Sidewalks, culverts, curbs and streets

constructed by the utility on its property

(Major Utilities).

43. Sprinkling systems (Major Utilities).

44. Sump pumps and pits (Major Utilities).

45. Stacks—brick, steel, or concrete, when

set on foundation forming part of general

foundation and steelwork of a building.

46. Steel inspection during construction

(Major Utilities).

47. Storage facilities constituting a part of

a building.

48. Storm doors and windows (Major Utili-

ties).

49. Subways, areaways, and tunnels, di-

rectly connected to and forming part of a

structure.

50. Tanks, constructed as part of a building

or as a distinct structural unit.

51. Temporary heating during construction

(net cost) (Major Utilities).


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52. Temporary water connection during

construction (net cost) (Major Utilities). 53. Temporary shanties and other facilities

used during construction (net cost) 54. Topographical maps (Major Utilities). 55. Tunnels, intake and discharge, when

constructed as part of a structure, including

sluice gates, and those constructed to house

mains. 56. Vaults constructed as part of a build-

ing. 57. Watchmen’s sheds and clock systems

(net cost when used during construction

only) (Major Utilities). 58. Water basins or reservoirs. 59. Water front improvements (Major Utili-

ties). 60. Water meters and supply system for a

building or for general company purposes

(Major Utilities). 61. Water supply piping, hydrants and wells

(Major Utilities). 62. Wharves. 63. Window shades and ventilators (Major

Utilities). 64. Yard drainage system (Major Utilities). 65. Yard lighting system (Major Utilities). 66. Yard surfacing, gravel, concrete, or oil.

(First cost only.) (Major Utilities)

NOTE: Structures and Improvements ac-

counts shall be credited with the cost of coal

bunkers, stacks, foundations, subways, tun-

nels, etc., the use of which has terminated

with the removal of the equipment with

which they are associated even though they

have not been physically removed.

9. Equipment. A. The cost of equipment chargeable

to the electric plant accounts, unless otherwise indicated in the text of an equipment account, includes the net purchase price thereof, sales taxes, in-vestigation and inspection expenses necessary to such purchase, expenses of transportation when borne by the util-ity, labor employed, materials and sup-plies consumed, and expenses incurred by the utility in unloading and placing the equipment in readiness to operate. Also include those costs incurred in connection with the first clearing and grading of land and rights-of-way and the damage costs associated with con-struction and installation of plant.

B. Exclude from equipment accounts hand and other portable tools, which are likely to be lost or stolen or which have relatively small value (for exam-ple, $500 or less) or short life, unless the correctness of the accounting therefor as electric plant is verified by current inventories. Special tools ac-quired and included in the purchase

price of equipment shall be included in

the appropriate plant account. Port-

able drills and similar tool equipment

when used in connection with the oper-

ation and maintenance of a particular

plant or department, such as produc-

tion, transmission, distribution, etc.,

or in stores, shall be charged to the

plant account appropriate for their use.

C. The equipment accounts shall in-

clude angle irons and similar items

which are installed at the base of an

item of equipment, but piers and foun-

dations which are designed to be as

permanent as the buildings which

house the equipment, or which are con-

structed as a part of the building and

which cannot be removed without cut-

ting into the walls, ceilings or floors or

without in some way impairing the

building, shall be included in the build-

ing accounts.

D. The equipment accounts shall in-

clude the necessary costs of testing or

running a plant or parts thereof during

an experimental or test period prior to

such plant becoming ready for or

placed in service. In the case of

Nonmajor utilities, the utility shall

pay the fee prescribed in part 381 of

this chapter and shall furnish the Com-

mission with full particulars of and

justification for any test or experi-

mental run extending beyond a period

of 30 days. In the case of Major utili-

ties, the utility shall furnish the Com-

mission with full particulars of and

justification for any test or experi-

mental run extending beyond a period

of 120 days for nuclear plant, and a pe-

riod of 90 days for all other plant. Such

particulars shall include a detailed

operational and downtime log showing

days of production, gross kilowatts

generated by hourly increments, types,

and periods of outages by hours with

explanation thereof, beginning with

the first date the equipment was either

tested or synchronized on the line to

the end of the test period.

E. The cost of efficiency or other

tests made subsequent to the date

equipment becomes available for serv-

ice shall be charged to the appropriate

expense accounts, except that tests to

determine whether equipment meets

the specifications and requirements as

to efficiency, performance, etc., guar-

anteed by manufacturers, made after


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operations have commenced and within

the period specified in the agreement

or contract of purchase may be charged

to the appropriate electric plant ac-

count.

10. Additions and Retirements of Elec-tric Plant.

A. For the purpose of avoiding undue

refinement in accounting for additions

to and retirements and replacements of

electric plant, all property will be con-

sidered as consisting of (1) retirement

units and (2) minor items of property.

Each utility shall maintain a written

property units listing for use in ac-

counting for additions and retirements

of electric plant and apply the listing

consistently.

B. The addition and retirement of re-

tirement units shall be accounted for

as follows:

(1) When a retirement unit is added

to electric plant, the cost thereof shall

be added to the appropriate electric

plant account, except that when units

are acquired in the acquisition of any

electric plant constituting an oper-

ating system, they shall be accounted

for as provided in electric plant in-

struction 5.

(2) When a retirement unit is retired

from electric plant, with or without re-

placement, the book cost thereof shall

be credited to the electric plant ac-

count in which it is included, deter-

mined in the manner set forth in para-

graph D, below. If the retirement unit

is of a depreciable class, the book cost

of the unit retired and credited to elec-

tric plant shall be charged to the accu-

mulated provision for depreciation ap-

plicable to such property. The cost of

removal and the salvage shall be

charged or credited, as appropriate, to

such depreciation account.

C. The addition and retirement of

minor items of property shall be ac-

counted for as follows:

(1) When a minor item of property

which did not previously exist is added

to plant, the cost thereof shall be ac-

counted for in the same manner as for

the addition of a retirement unit, as

set forth in paragraph B(1), above, if a

substantial addition results, otherwise

the charge shall be to the appropriate

maintenance expense account.

(2) When a minor item of property is

retired and not replaced, the book cost

thereof shall be credited to the electric

plant account in which it is included;

and, in the event the minor item is a

part of depreciable plant, the account

for accumulated provision for deprecia-

tion shall be charged with the book

cost and cost of removal and credited

with the salvage. If, however, the book

cost of the minor item retired and not

replaced has been or will be accounted

for by its inclusion in the retirement

unit of which it is a part when such

unit is retired, no separate credit to

the property account is required when

such minor item is retired.

(3) When a minor item of depreciable

property is replaced independently of

the retirement unit of which it is a

part, the cost of replacement shall be

charged to the maintenance account

appropriate for the item, except that if

the replacement effects a substantial

betterment (the primary aim of which

is to make the property affected more

useful, more efficient, of greater dura-

bility, or of greater capacity), the ex-

cess cost of the replacement over the

estimated cost at current prices of re-

placing without betterment shall be

charged to the appropriate electric

plant account.

D. The book cost of electric plant re-

tired shall be the amount at which

such property is included in the elec-

tric plant accounts, including all com-

ponents of construction costs. The

book cost shall be determined from the

utility’s records and if this cannot be

done it shall be estimated. Utilities

must furnish the particulars of such es-

timates to the Commission, if re-

quested. When it is impracticable to

determine the book cost of each unit,

due to the relatively large number or

small cost thereof, an appropriate aver-

age book cost of the units, with due al-

lowance for any differences in size and

character, shall be used as the book

cost of the units retired.

E. The book cost of land retired shall

be credited to the appropriate land ac-

count. If the land is sold, the difference

between the book cost (less any accu-

mulated provision for depreciation or

amortization therefore which has been

authorized and provided) and the sale

price of the land (less commissions and

other expenses of making the sale)

shall be recorded in account 411.6,


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Gains from Disposition of Utility

Plant, or 411.7, Losses from Disposition

of Utility Plant when the property has

been recorded in account 105, Electric

Plant Held for Future Use, otherwise

to accounts 421.1, Gain on Disposition

of Property or 421.2, Loss on Disposi-

tion of Property, as appropriate. If the

land is not used in utility service but is

retained by the utility, the book cost

shall be charged to account 105, Elec-

tric Plant Held for Future Use, or ac-

count 121, Nonutility Property, as ap-

propriate.

F. The book cost less net salvage of

depreciable electric plant retired shall

be charged in its entirety to account

108. Accumulated Provision for Depre-

ciation of Electric Plant in Service

(Account 110, Accumulated Provision

for Depreciation and Amortization of

Electric Utility Plant, in the case of

Nonmajor utilities). Any amounts

which, by approval or order of the

Commission, are charged to account

182.1, Extraordinary Property Losses,

shall be credited to account 108 (Ac-

count 110 for Nonmajor utilities).

G. In the case of Major utilities, the

accounting for the retirement of

amounts included in account 302, Fran-

chises and Consents, and account 303,

Miscellaneous Intangible Plant, and

the items of limited-term interest in

land included in the accounts for land

and land rights, shall be as provided for

in the text of account 111. Accumulated

Provision for Amortization of Electric

Plant in Service, account 404, Amorti-

zation of Limited-Term Electric Plant,

and account 405, Amortization of Other

Electric Plant.

11. Work Order and Property Record System Required.

A. Each utility shall record all con-

struction and retirements of electric

plant by means of work orders or job

orders. Separate work orders may be

opened for additions to and retirements

of electric plant or the retirements

may be included with the construction

work order, provided, however, that all

items relating to the retirements shall

be kept separate from those relating to

construction and provided, further,

that any maintenance costs involved in

the work shall likewise be segregated.

B. Each utility shall keep its work

order system so as to show the nature

of each addition to or retirement of

electric plant, the total cost thereof,

the source or sources of costs, and the

electric plant account or accounts to

which charged or credited. Work orders

covering jobs of short duration may be

cleared monthly.

C. In the case of Major utilities, each

utility shall maintain records in which,

for each plant account, the amounts of

the annual additions and retirements

are classified so as to show the number

and cost of the various record units or

retirement units.

12. Transfers of Property. When property is transferred from

one electric plant account to another,

from one utility department to an-

other, such as from electric to gas,

from one operating division or area to

another, to or from accounts 101, Elec-

tric Plant in Service, 104. Electric

Plant Leased to Others, 105. Electric

Plant Held for Future Use, and 121,

Nonutility Property, the transfer shall

be recorded by transferring the original

cost thereof from the one account, de-

partment, or location to the other. Any

related amounts carried in the ac-

counts for accumulated provision for

depreciation or amortization shall be

transferred in accordance with the seg-

regation of such accounts.

13. Common Utility Plant. A. If the utility is engaged in more

than one utility service, such as elec-

tric, gas, and water, and any of its util-

ity plant is used in common for several

utility services or for other purposes to

such an extent and in such manner

that it is impracticable to segregate it

by utility services currently in the ac-

counts, such property, with the ap-

proval of the Commission, may be des-

ignated and classified as common utility plant.

B. The book amount of utility plant

designated as common plant shall be

included in account 118, Other Utility

Plant, and if applicable in part to the

electric department, shall be seg-

regated and accounted for in sub-

accounts as electric plant is accounted

for in accounts 101 to 107, inclusive,

and electric plant adjustments in ac-

count 116; any amounts classifiable as

common plant acquisition adjustments

or common plant adjustments shall be

subject to disposition as provided in


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paragraphs C and B of accounts 114 and

116, respectively, for amounts classified

in those accounts. The original cost of

common utility plant in service shall

be classified according to detailed util-

ity plant accounts appropriate for the

property.

C. The utility shall be prepared to

show at any time and to report to the

Commission annually, or more fre-

quently, if required, and by utility

plant accounts (301 to 399) the fol-

lowing: (1) The book cost of common

utility plant, (2) The allocation of such

cost to the respective departments

using the common utility plant, and (3)

The basis of the allocation.

D. The accumulated provision for de-

preciation and amortization of the util-

ity shall be segregated so as to show

the amount applicable to the property

classified as common utility plant.

E. The expenses of operation, mainte-

nance, rents, depreciation and amorti-

zation of common utility plant shall be

recorded in the accounts prescribed

herein, but designated as common ex-

penses, and the allocation of such ex-

penses to the departments using the

common utility plant shall be sup-

ported in such manner as to reflect

readily the basis of allocation used.

14. Transmission and Distribution Plant.

For the purpose of this system of ac-

counts:

A. Transmission system means:

(1) All land, conversion structures,

and equipment employed at a primary

source of supply (i.e., generating sta-

tion, or point of receipt in the case of

purchased power) to change the voltage

or frequency of electricity for the pur-

pose of its more efficient or convenient

transmission;

(2) All land, structures, lines, switch-

ing and conversion stations, high ten-

sion apparatus, and their control and

protective equipment between a gener-

ating or receiving point and the en-

trance to a distribution center or

wholesale point; and

(3) All lines and equipment whose pri-

mary purpose is to augment, integrate

or tie together the sources of power

supply

B. Distribution system means all land,

structures, conversion equipment,

lines, line transformers, and other fa-

cilities employed between the primary source of supply (i.e., generating sta-tion, or point of receipt in the case of purchased power) and of delivery to customers, which are not includible in transmission system, as defined in paragraph A, whether or not such land, structures, and facilities are operated as part of a transmission system or as part of a distribution system.

NOTE: Stations which change electricity

from transmission to distribution voltage

shall be classified as distribution stations.

C. Where poles or towers support both transmission and distribution conductors, the poles, towers, anchors, guys, and rights of way shall be classi-fied as transmission system. The con-ductors, crossarms, braces, grounds, tiewire, insulators, etc., shall be classi-fied as transmission or distribution fa-cilities, according to the purpose for which used.

D. Where underground conduit con-tains both transmission and distribu-tion conductors, the underground con-duit and right of way shall be classified as distribution system. The conductors shall be classified as transmission or distribution facilities according to the purpose for which used.

E. Land (other than rights of way) and structures used jointly for trans-mission and distribution purposes shall be classified as transmission or dis-tribution according to the major use thereof.

15. Hydraulic production plant (Major Utilities).

For the purpose of this system of ac-counts hydraulic production plant means all land and land rights, struc-tures and improvements used in con-nection with hydraulic power genera-tion, reservoirs dams and waterways, water wheels, turbines, generators, ac-cessory electric equipment, miscella-neous powerplant equipment, roads, railroads, and bridges, and structures and improvements used in connection with fish and wildlife, and recreation.

16. Nuclear Fuel Records Required (Major Utilities).

Each utility shall keep all the nec-

essary records to support the entries to

the various nuclear fuel plant accounts

classified under ‘‘Assets and Other Deb-

its,’’ Utility Plant 120.1 through 120.6,

inclusive, account 518, Nuclear Fuel


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Expense and account 157, Nuclear Ma-

terials Held for Sale. These records

shall be so kept as to readily furnish

the basis of the computation of the net

nuclear fuel costs.

Operating Expense Instructions

1. Supervision and Engineering (Major Utilities).

The supervision and engineering in-

cludible in the operating expense ac-

counts shall consist of the pay and ex-

penses of superintendents, engineers,

clerks, other employees and consult-

ants engaged in supervising and direct-

ing the operation and maintenance of

each utility function. Wherever alloca-

tions are necessary in order to arrive

at the amount to be included in any ac-

count, the method and basis of alloca-

tion shall be reflected by underlying

records.

ITEMS

Labor

1. Special tests to determine efficiency of

equipment operation.

2. Preparing or reviewing budgets, esti-

mates, and drawings relating to operation or

maintenance for departmental approval.

3. Preparing instructions for operations

and maintenance activities.

4. Reviewing and analyzing operating re-

sults.

5. Establishing organizational setup of de-

partments and executing changes therein.

6. Formulating and reviewing routines of

departments and executing changes therein.

7. General training and instruction of em-

ployees by supervisors whose pay is charge-

able hereto. Specific instruction and train-

ing in a particular type of work is chargeable

to the appropriate functional account (See

Electric Plant Instruction 3(19)).

8. Secretarial work for supervisory per-

sonnel, but not general clerical and steno-

graphic work chargeable to other accounts.

Expenses

9. Consultants’ fees and expenses.

10. Meals, traveling and incidental ex-

penses.

2. Maintenance. A. The cost of maintenance charge-

able to the various operating expense

and clearing accounts includes labor,

materials, overheads and other ex-

penses incurred in maintenance work.

A list of work operations applicable

generally to utility plant is included hereunder. Other work operations ap-plicable to specific classes of plant are listed in functional maintenance ex-pense accounts.

B. Materials recovered in connection with the maintenance of property shall be credited to the same account to which the maintenance cost was charged.

C. If the book cost of any property is carried in account 102, Electric Plant Purchased or Sold, the cost of main-taining such property shall be charged to the accounts for maintenance of property of the same class and use, the book cost of which is carried in other

electric plant in service accounts.

Maintenance of property leased from

others shall be treated as provided in

operating expense instruction 3.

ITEMS

1. Direct field supervision of maintenance. 2. Inspecting, testing, and reporting on

condition of plant specifically to determine

the need for repairs, replacements, re-

arrangements and changes and inspecting

and testing the adequacy of repairs which

have been made. 3. Work performed specifically for the pur-

pose of preventing failure, restoring service-

ability or maintaining life of plant. 4. Rearranging and changing the location

of plant not retired. 5. Repairing for reuse materials recovered

from plant. 6. Testing for locating and clearing trou-

ble. 7. Net cost of installing, maintaining, and

removing temporary facilities to prevent

interruptions in service. 8. Replacing or adding minor items of plant

which do not constitute a retirement unit.

(See electric plant instruction 10.)

3. Rents. A. The rent expense accounts pro-

vided under the several functional

groups of expense accounts shall in-

clude all rents, including taxes paid by

the lessee on leased property, for prop-

erty used in utility operations, except

(1) minor amounts paid for occasional

or infrequent use of any property or

equipment and all amounts paid for use

of equipment that, if owned, would be

includible in plant accounts 391 to 398,

inclusive, which shall be treated as an

expense item and included in the ap-

propriate functional account and (2)

rents which are chargeable to clearing


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Decision 1988, D. 87-12-066, Section J, Plants Held for Future Use

A-16

ALJ/FSF,SSM/ltg

Decl'sion 87-12-066 December i 2 , 1987

BEFORE THE PUBLIC UTILITIES COMMISSION OF THE STATE OF CALIFORNIA

In the Matter of the Application of Southern California Edison Company for authority to increase rates charged by it for electric service.

(Electric) (U 338 E)

Order Instituting Investigation into the rates, charges, and practices of the Southern California Edison Company

Application 86-12-047. (Filed December 26, 1986)

1.87-01-017 (Filed January 14, 1987)

(Appearances are listed in Appendix J.)

- 1' -

A-17

A. 86-12-047, 1.87-01-017 AU/FSF,SSM/ltq, jt *

rates. The only difference between Edison's and PSD's estimates of depreciation expense and reserve is due to differing plant estimates. We will adopt Edison's revised depeciation rates for use in this decision. J. Plant Held for Future Use fPHFU)

PHFU includes land and plant related items that have been acquired by Edison for use in the future. In its application Edison requested that it be allowed to earn a return on $128.2 million in PHFU for test year 1988. Since its application was filed, Edison reevaluated its PHFU estimate in light of the PHFU guidelines it and PSD developed and agreed to reduce the amount by $7.1 million.

During the course of its audit, PSD questioned Edison's specific plans for using 56 parcels of land in PHFU. PSD claims that under current plans, the average time that these parcels would remain in the PHFU account is 27 years and as of January 1, 1987 they have averaged over 16 years in PHFU. Additionally, PSD points out that the carrying charges for the ratepayers (18.07%, return times net to gross) is sxibstantially greater than for Edison (10.75%, return on rate base). Faced with this circumstance, PSD recommends that all of the 56 parcels be excluded from rate base for the test period, an adjustment of $20.4 million. Finally, PSD identified a parcel valued at $520,000 that was dovible counted in Edison's application.

In response to a request by ALJ Ferraro, PSD propounded a series of guidelines to govern the length of time that items could be retained in PHFU. The guidelines, attached as Appendix B, provide for the following:

1. Distribution substations and transmission plant (not related to new power plants) could be held in PHFU and not placed in Edison's plant expenditure review committee (PERC) budget for five years. If by the end of five years, the property has not

- 38 - A-18

A.86-12-047, 1.87-01-017 AU/FSF, SSM/ltq, jt *

been included in the PERC budget, it would be removed from PHFU until it is included in a future PERC budget.

2. Generation and transmission plant (related to new power plants) can be held in PHFU and not be included in the PERC budget for ten years. If at the end of ten years, the property has not been included in the PERC budget, it would be removed until it is included in a future PERC budget.

While PSD states that the guidelines may be valuable for the future, implementing them on a prospective basis will not remedy the injustice that ratepayers have endured by absorbing significant carrying costs over past years.

Edison worked with PSD in developing the guidelines and believes that they should be adopted prospectively. Edison states that the guidelines give guidance, are fair and workable, and benefit Edison and its ratepayers. Finally, Edison points out that the guidelines give Edison appropriate flexibility, provide reasonable compensation, and give ratepayers protection from paying for property that may ultimately end up not being needed.

Adoption of the guidelines prospectively results in a $7.1 million reduction from the amount Edison originally requested be included in PHFU. Edison is in agreement with this reduction, but is opposed to PSD's recommended exclusion of $20.4 million from PHFU. Edison argues that PSD's recommendation is unfair because the needs for the property were not considered and it was based solely on PSD's judgement that: the property has been in PHFU too long.

PHFU is an area in which we do not have specific criteria for judging the reasonableness of a utility's property acquisition policies. Because of this, utilities do not have a strong incentive to closely monitor their procedures for acquiring and maintaining PHFU. A U Ferraro directed PSD and Edison to work together to develop guidelines which could be used to judge the

- 39 -

A-19

A. 86-12-047, 1.87-01-017 AU/FSF, SSM/ltq, jt *

reasonableness of utility expenditures on PHFU. As a result, PSD and Edison developed guidelines and agreed to their use in the future. We find these guidelines reasonable and will adopt them for use in this and Edison's future general rate cases. In addition, we will direct our Evaluation and Compliance Division to notify the energy utilities under our jurisdiction that we expect to adopt similar guidelines in their next general rate case.

Although PSD and Edison are in agreement that the guidelines should be used in future general rate cases, they are in disagreement over their use in this proceeding. PSD's auditors are concerned over the length of time that ratepayers have paid high carrying charges on 56 parcels in PHFU, while Edison has identified a specific use for most of these properties and argues that it would be unfair to apply the guidelines retroactively.

Because Edison has identified a specific use for most of the properties at issue, we will not adopt PSD's recommendation in its entirety. However, starting January 1, 1989 we will apply the adopted guidelines as if they were effective prior to the acquisition date of all items in. PHFU. This will result in a reduction of $16.2 million from Edison's original request for 1989. For test year 1988 we will reduce Edison's original request by $7.5 million. This represents $7.1 million, Edison's agreed reduction, and $520,000, PSD's dotible counting adjustment.

By delaying full implementation of the guidelines Edison should have ample opportunity to manage its PHFU account to the level adopted in this decision. Edison can accomplish this by delaying future purchases, selling property not needed in the near future, placing property in plant-in-service as it becomes used and useful, or by transferring property to nonutility property. We believe, by providing ratepayers with lower carrying charges now and in the future and shareholders with the opportunity to adjust to this change, the interests of ratepayers and shareholders are fairly balanced.

- 40 - A-20

Amended Scoping Memo and Ruling of Assigned Commission and Assigned Administrative Law Judges dated April 10, 2020, p. 5

A-21

A.19-08-013 COM/GSH/nd3

- 5 -

review period due to current resource constraints resulting from the COVID-19

pandemic.5

In support of the proposal to consider the third attrition year in Track 1 of

the proceeding, TURN states that it would be unreasonable and unduly

burdensome to parties to delay the resolution of SCE’s third attrition year to a

later track in the proceeding, since it will require parties and the Commission to

evaluate and litigate multiple GRCs at once (most notably SDG&E’s 2024 GRC),

including relitigating SCE’s RAMP and a one-year rate case.6

TURN further argues that SCE already has the authority to shift resources

and spend money differently than forecast in its rate case, and that relitigating a

one-year rate case would be contrary to the Commission’s intent in D.20-01-002

which was adopted to allow the utilities to focus on the “risk-mitigation and

accountability structures” established in the RAMP proceedings, to reduce the

GRC litigation time, and provide greater transparency and Commission review

over re-allocation decisions.7

TURN also states that SCE has already admitted that it is physically unable

to do more work than it is proposing in this rate case, and thus the next RAMP is

not likely to dramatically impact one-year revenues, but rather should impact

SCE’s resource allocation decisions to ensure SCE is properly managing all risks,

including wildfire risk.8

Finally, TURN argues that the proposal not to file a 2024 RAMP report

complies with D.14-12-025 and D.18-12-014 since the RAMP process is tied to a

5 CUE March 20, 2020 PHC Statement at 1-2. 6 TURN March 20, 2020 PHC Statement at 2 and 8-10. 7 Ibid at 3-4. 8 Ibid.

5 / 12

A-22

TURN further argues that SCE already has the authority to shift resources

and spend money differently than forecast in its rate case, and that relitigating a

TURN March 20, 2020 PHC Statement at 2 and 8-10.

Ibid at 3-4.7

66 TURN March

2018 GRC, Exhibit SCE-07, Vol. 03, Book C, p. 332

A-23

Workpaper – Southern California Edison / 2018 GRC

Exhibit No. SCE-07 / Vol. 03 / Book C Witness: N. Desrocher

Project Description:

Program Area Unit Capital Cost

Construction EstimateElemental BreakdownA. Substructure 75,000 sf $1,652,051B. Shell 75,000 sf $4,213,582C. Interior Construction 75,000 sf $15,281,246D. Services 75,000 sf $9,190,829E. Equipment and Furnishing 75,000 sf $222,031F. Special Construction 75,000 sf $710,680G. Sitework 75,000 sf $20,304,294H. Demolition 75,000 sf $247,269

Sub Total - Construction Estimate $51,821,983

FFE & IT Estimate1. Moves $02. Incidentals $12,3633. Internal Signage $80,3624. Artwork $61,8175. Appliances $24,7276. Furniture $618,1727. Equipment $08. SCE Security Systems $989,0759. IT and Audio / Visual infrastructure $7,439,000

Sub Total - FFE & IT Estimate $9,225,517

Pre-Construction Services EstimateDesign, Plan Check / Permitting Fees $2,872,300Constructability and Risk Management $4,341,300

Sub Total - Pre-Construction Services Estimate $7,213,600

Project Management EstimateProject & Construction Management / Program Management / Project Controls / Procurement

$825,900

Sub Total - Project Management Estimate $825,900

Land AcquisitionLand Costs $22,950,000

Sub Total - Land Acquisition $22,950,000

Total 75,000 SF $92,037,000

Cost Summary

T&D Technical Training CenterPlanning Estimate

July 2016

This project consists of developing a new purchased site to become a consolidated training center. This facility will include multiple training areas on-site and a new training classroom building with offices, labs, storage areas and food service. Sitework will include grading, utilities and paved driveways and parking.

332

A-24

Decision 2020, D. 19-05-020, p. 227

A-25

A.16-09-001 ALJ/SCR/EW2/jt2

- 227 -

9.3.2.2.1. Infrastructure Upgrade Projects

SCE states that infrastructure upgrade projects address deficiencies of

existing facilities based on poor Fitness for Purpose evaluation outcomes with

respect to new business operational requirements. SCE forecasts capital

expenditures for nine projects during the 2018-2020 GRC period, including

$45.978 million for Test Year 2018. SCE’s request is unopposed, and we

authorize SCE’s requested spending levels for infrastructure upgrade projects, as

shown in the table at the end of this section.

9.3.2.2.2. Substation Maintenance and Test Buildings (Substation Reliability Upgrades)

SCE states that the T&D crews that perform maintenance and testing at

SCE’s 900 substations are strategically located throughout the service territory, in

order to best access these substations. SCE’s Substation Maintenance and Test

Building Program is designed to replace temporary and outdated facilities at

certain substation locations, in order to improve the productivity of its crews.

SCE forecasts $8.254 million in Test Year 2018 expenditures for this program,

which will fund improvements at six substations identified as high priority

projects. SCE’s request is unopposed, and we authorize SCE’s requested

spending levels for these substation upgrades, as shown in the table at the end of

this section.

9.3.2.2.3. Facility Repurpose Projects

SCE states that Facility Repurpose projects are major renovations of

existing SCE facilities to address new or changed operational requirements. SCE

lists five projects in its testimony, and forecasts $6.775 million in Test Year 2018

expenditures for this program. TURN opposes one program that accounts for

A-26

TURN-SCE-030, Question 14, with attachment

A-27

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

DATA REQUEST SET T U R N - S C E - 0 3 0

To: TURNPrepared by: Jill Carlisle

Job Title : Senior Advisor, Corporate Real EstateReceived Date: 3/9/2020

Response Date: 3/23/2020

Question 14:Enterprise Operations - Capital - T&D Training Center. Refer to SCE-06 - Vol 5 Workpapers page 88. Provide support for the amounts shown (e.g, bids, contracts, invoices, etc.)

Response to Question 14:The T&D Training Center project referenced in SCE-06 - Vol 5 Workpapers page 88 is based on:

SCE’s project description Preliminary Site Programming Document

The project was evaluated by CCMI at Program Level Design for estimating purposes.

The following cost items were subject to the following assumptions/qualifications by CCMI within the estimate:

A Escalation is excluded from the EstimateB Phasing of the work within this estimate is excludedC Overtime pay is excluded. All work is during daytime shifts, Monday thru FridayD All work is anticipated to be open shop laborE Contractor’s Bond is excluded since it is not required by SCEF Additional work required by permitting authority is excludedI FF&E Costs

1) Furniture is per SCE standards and pricing2) On-Site Security Escorts is based on (2) FTE security escort3) SCE Security System is per SCE standards and pricing4) Audio / Visual and IT Infrastructure budget is per SCE IT’s standards and

pricingJ Pre-Construction Service Costs

1) Design fees budget is provided by SCE per work completedK SCE Management Costs

1) Project Management2) Construction Management3) Project Controls and Scheduling support included

L Constructability/Risk Management1) A risk management allowance is included based on rating of SCE’s ten risk

factors for this project A-28

TURN-SCE-030: 14Page 2 of 2

Wherever possible, CCMI made its estimate based upon the actual measurement of different items of work. For the remaining items, CCMI utilized parametric measurements were used in conjunction with references from other projects of a similar nature.

The estimate was prepared by a team of CCMI’s cost consultants experience in construction costs atall stages of design. These consultants have used pricing data from CCMI’s database for construction, updated to reflect conditions in the local area of the project. In some cases, quotes were solicited from outside sources to substantiate in-house pricing data.

The attachment to this response entitled, “TURN-030 Q14 T&D Training Center Statement” provides additional details. Please note the Quantity listed under the Construction Section of the estimate is the square footage of the overall project.

A-29

Quantity U/M Unit $ Capital O&M Totals

SubcontractDivision 2 - Site Work 80,000 sf $90.34 $7,226,941 $0 $7,226,941Division 3 - Concrete and Reinforcement 80,000 sf $13.11 $1,048,899 $0 $1,048,899Division 5 - Steel 80,000 sf $8.74 $699,266 $0 $699,266Division 6 - Carpentry and Millwork 80,000 sf $3.20 $256,398 $0 $256,398Division 7 - Moisture Protection 80,000 sf $0.58 $46,618 $0 $46,618Division 8 - Doors, Frames, Glass and Glazing 80,000 sf $2.91 $233,089 $0 $233,089Division 9 - Finishes 80,000 sf $88.43 $7,074,242 $0 $7,074,242Division 10 - Specialties 80,000 sf $1.02 $81,581 $0 $81,581Division 12 - Furnishings 80,000 sf $1.46 $116,544 $0 $116,544Division 13 - Special Construction 80,000 sf $69.93 $5,594,129 $0 $5,594,129Division 15 - Mechanical 80,000 sf $55.36 $4,428,685 $0 $4,428,685Division 16 - Electrical 80,000 sf $46.62 $3,729,419 $0 $3,729,419

Subtotal 80,000 sf $381.70 $30,535,810 $0 $30,535,810General Conditions / Insurances 80,000 sf $38.78 $3,102,409 $0 $3,102,409G.C. Fee 80,000 sf $25.27 $2,021,592 $0 $2,021,592

Total - Construction Cost $35,659,811 $0 $35,659,811

Moves $0.00 $0 $0 $0Incidentals 1 ls $12,130.00 $0 $12,130 $12,130Internal Signage 1 ls $89,370.00 $89,370 $0 $89,370Artwork, allowance 1 ls $67,030.00 $67,030 $0 $67,030Appliances, allowance 1 ls $75,830.00 $75,830 $0 $75,830Furniture 1 ls $2,000,000.00 $2,000,000 $0 $2,000,000Equipment 1 ls $176,930.00 $176,930 $0 $176,930

1 ls $460,000 $460,000 $0 $460,000SCE IT and Audio / Visual infrastructure 1 ls $1,026,000.00 $1,026,000 $0 $1,026,000

Subtotal FF&E Costs $3,895,160 $12,130 $3,907,290

Plan Check & Permit Fees 1 ls $662,000 $0 $662,000Arch/Engineering 1 ls $1,623,000 $0 $1,623,000Procurement 1 ls $309,000 $0 $309,000

Subtotal SCE Costs $2,594,000 $0 $2,594,000

Planning (charged to overhead)1 ls $284,600 $284,600 $0 $284,600

1 ls $350,700 $350,700 $0 $350,700

Project Controls 1 ls $57,600 $57,600 $0 $57,600Procurement 1 ls $145,000 $145,000 $0 $145,000

Subtotal SCE Mngmt Costs $837,900 $0 $837,900Subtotal Project $42,999,001Constructability and Risk Management $3,562,000 $0 $3,562,000Project Totals $46,561,000

Construction Management (1) FTE CM for 12 months @ $150 / hour.

FF&E

SCE Security

Pre-Construction Services

Management Costs

Project Management: 1 PM @ 18 hours / week for 2 months pre-construction; 24 hours / week for 12 months construction; 12 hours / week for 1 month closeout @ $175 / hour, including subsistance $250.00 / day..

T&D Training Facility Conceptual Design Statement of Probable Cost

SCE Project Cost Summary

Construction Cost

Prepared by Cumming A-30


A-31






Question 18:Enterprise Operations - Capital - Vehicle Maintenance. Refer to SCE-06 - Vol 5 Workpapers page 95. Provide support for the amounts shown (e.g, bids, contracts, invoices, etc.)

Response to Question 18:The Vehicle Maintenance Facilities project referenced in SCE-06 - Vol 5 Workpapers page 95 is based on:

SCE’s project description

The project was evaluated by CCMI at Rough Order of Magnitude (ROM) design for estimating purposes.

The estimate is based on traditional Design-Build competitively bid with qualified General Contractors and main subcontractors.


A Escalation is excluded from the EstimateB Phasing of the work within this estimate is excludedC Overtime pay is excluded. All work is during daytime shifts, Monday thru FridayD All work is anticipated to be open shopE Contractor’s Bond is excluded since it is not required by SCEF Additional work required by permitting authority is excludedG Hazardous materials studies, abatement and removals is excludedH FF&E Costs

1) On-Site Security Escorts is based on (1) FTE security escort2) SCE Security System is per SCE standards and pricing3) Audio / Visual and IT Infrastructure budget is per SCE IT’s standards and

pricingI SCE Management Costs

1) Project Management2) Construction Management3) Project Controls and Scheduling costs are included

J Constructability/Risk Management1) A risk management allowance is included based on rating of SCE’s ten risk

factors for this project A-32



The estimate was prepared by a team of CCMI’s cost consultants experience in construction costs atall stages of design. These consultants have used pricing data from CCMI’s database for construction, updated to reflect conditions in the local area of the projects. In some cases, quotes were solicited from outside sources to substantiate in-house pricing data.

The attachment to this response entitled, “TURN-030 Q18 Vehicle Maintenance Facility Statement”provides additional details. Please note the Quantity listed under the Construction Section of the estimate is the square footage at each site.

A-33


SubcontractDivision 1 - General Requirements 23,300 sf $34.20 $796,958 $0 $796,958Division 2 - Site Work 23,300 sf $115.89 $2,700,183 $0 $2,700,183Division 3 - Concrete and Reinforcement 23,300 sf $35.50 $827,155 $0 $827,155Division 5 - Steel 23,300 sf $13.96 $325,230 $0 $325,230Division 6 - Carpentry and Millwork 23,300 sf $2.59 $60,380 $0 $60,380Division 7 - Moisture Protection 23,300 sf $17.34 $404,138 $0 $404,138Division 8 - Doors, Frames, Glass and Glazing 23,300 sf $2.37 $55,273 $0 $55,273Division 9 - Finishes 23,300 sf $79.40 $1,849,975 $0 $1,849,975Division 10 - Specialties 23,300 sf $4.50 $104,886 $0 $104,886Division 11 - Equipment 23,300 sf $161.66 $3,766,672 $0 $3,766,672Division 13 - Special Construction 23,300 sf $73.30 $1,707,988 $0 $1,707,988Division 15 - Mechanical 23,300 sf $57.00 $1,328,080 $0 $1,328,080Division 16 - Electrical 23,300 sf $88.19 $2,054,752 $0 $2,054,752

Subtotal 23,300 sf $685.91 $15,981,668 $0 $15,981,668General Conditions / Bonds & Ins 23,300 sf $74.60 $1,738,200 $0 $1,738,200G.C. Fee 23,300 sf $48.02 $1,118,887 $0 $1,118,887


Moves 1 ls $0.00 $0 $0 $0Incidentals 1 ls $12,990.00 $0 $12,990 $12,990Internal Signage, allowance 1 ls $43,235.00 $43,235 $0 $43,235Artwork, allowance 0 ls $0.00 $0 $0 $0Appliances 0 ls $0.00 $0 $0 $0Furniture 0 ls $0.00 $0 $0 $0Equipment 1 ls $139,181.00 $0 $139,181 $139,181

1 ls $371,100 $371,100 $0 $371,100SCE IT and Audio / Visual infrastructure 1 ls $357,000.00 $357,000 $0 $357,000

Subtotal FF&E Costs $771,335 $152,171 $923,505

Plan Check & Permit Fees 1 ls $296,000 $0 $296,000Arch/Engineering 1 ls $40,000 $0 $40,000Procurement 1 ls $66,000 $0 $66,000

Subtotal SCE Costs $402,000 $0 $402,000


1 ls $477,600 $477,600 $477,600

Project Controls 1 ls $92,100 $92,100 $0 $92,100Procurement 1 ls $72,700 $72,700 $0 $72,700

Subtotal SCE Mngmt Costs $1,126,400 $0 $1,126,400Subtotal Project $21,290,660Constructability and Risk Management $1,355,340 $0 $1,355,340Project Totals $22,646,000

SCE Security Systems


Project Management

Project Management: 1 PM @ 18 hours / week for 6 months pre-construction; 24 hours / week for 18 months construction; 12 hours / week for 3 month closeout @ $175 / hour, including subsistance Construction Management (1) FTE CM for 18 months @ $150 / hour., including subsistance $125.00 / day.

Vehicle Maintenance Facility ProgramRough Order of Magnitude Statement of Probable Cost


Construction Cost

FF&E



A-35






Question 48:Enterprise Operations - Capital - Devers Maintenance & Test Building. Refer to SCE-06 - Vol 5 Workpapers page 173. Provide support for the amounts shown (e.g, bids, contracts, invoices, etc.)

Response to Question 48:The Devers Maintenance and Test Building Project referenced in SCE-06 - Vol 5 Workpapers at page 173 is based on:

SCE’s project description Drawing by Blair Church & Flynn

o A Architecturalo B Civil

The project was evaluated by CCMI at Schematic Design for estimating purposes.


A Escalation is excluded from the EstimateB Phasing of the work within this estimate is excludedC Overtime pay is excluded. All work is during daytime shifts, Monday thru FridayD All work is anticipated to be open shopE Contractor’s Bond is excluded since it is not required by SCEF Additional work required by permitting authority is excludedG The estimated anticipates a construction duration of approximately 8 monthsH Hazardous materials studies, abatement and removals is excludedI FF&E Costs




1) Project Management2) Construction Management A-36


3) Project Controls and Scheduling support


factors for this project


The estimate was prepared by a team of CCMI’s cost consultants experience in construction costs atall stages of design. These consultants have used pricing data from CCMI’s database for construction, updated to reflect conditions in the local area of the project. In some cases quotes were solicited from outside sources to substantiate in-house pricing data.

The attachment to this response entitled, “TURN-030 Q48 Devers M&T Design Statement” provides additional details. Please note the Quantity listed under the Construction Section of the estimate is the square footage of the overall project.

A-37


SubcontractDivision 2 - Site Work 4,000 sf $236.11 $944,445 $0 $944,445Division 3 - Concrete and Reinforcement 4,000 sf $35.58 $142,317 $0 $142,317Division 5 - Steel 4,000 sf $1.96 $7,848 $0 $7,848Division 6 - Carpentry and Millwork 4,000 sf $12.21 $48,831 $0 $48,831Division 7 - Moisture Protection 4,000 sf $7.90 $31,604 $0 $31,604Division 8 - Doors, Frames, Glass and Glazing 4,000 sf $26.75 $106,997 $0 $106,997Division 9 - Finishes 4,000 sf $146.57 $586,270 $0 $586,270Division 10 - Specialties 4,000 sf $10.70 $42,789 $0 $42,789Division 11 - Equipment 4,000 sf $33.84 $135,362 $0 $135,362Division 15 - Mechanical 4,000 sf $50.47 $201,871 $0 $201,871Division 16 - Electrical 4,000 sf $114.75 $458,995 $0 $458,995

Subtotal 4,000 sf $676.83 $2,707,330 $0 $2,707,330General Conditions / Insurances 4,000 sf $73.30 $293,181 $0 $293,181G.C. Fee 4,000 sf $57.23 $228,900 $0 $228,900


Moves 0 ls $0.00 $0 $0 $0Incidentals 1 ls $2,503.00 $0 $2,503 $2,503Internal Signage, allowance 1 ls $4,997.00 $4,997 $0 $4,997Artwork, allowance 1 ls $3,750.00 $3,750 $0 $3,750Appliances 1 ls $31,572.00 $31,572 $0 $31,572Furniture 1 ls $200,000.00 $200,000 $0 $200,000Equipment 1 ls $25,000.00 $0 $25,000 $25,000


Subtotal FF&E Costs $919,319 $27,503 $946,822

Plan Check & Permit Fees 1 ls $68,000 $0 $68,000Arch/Engineering, Budget per SCE 1 ls $167,000 $0 $167,000Procurement 1 ls $32,000 $0 $32,000



1 ls $175,400 $175,400 $175,400

Project Controls 1 ls $37,700 $37,600 $0 $37,600Subtotal SCE Mngmt Costs $328,000 $0 $328,000

Subtotal Project $4,771,233Constructability and Risk Management $234,667 $0 $234,667Project Totals $5,005,900

Devers Maintenance and Test Building Schematic Design Statement of Probable Cost


Construction Cost


FF&E

SCE Security Syatems


Management Costs




A-39






Question 52:Enterprise Operations - Capital - Rector Maintenance. Refer to SCE-06 - Vol 5 Workpapers page 176. Provide support for the amounts shown (e.g, bids, contracts, invoices, etc.)

Response to Question 52:The Rector Maintenance and Test Building project referenced in SCE-06 - Vol 5 Workpapers at page 176 is based on:

SCE’s project description Drawing by Blair Church & Flynn

o A Architecturalo B Civil

The project was evaluated by CCMI at Schematic Design for estimating purposes.


A Escalation is excluded from the EstimateB Phasing of the work within this estimate is excludedC Overtime pay is excluded. All work is during daytime shifts, Monday thru FridayD All work is anticipated to be open shopE Contractor’s Bond is excluded since it is not required by SCEF Additional work required by permitting authority is excludedG The estimated anticipates a construction duration of approximately 8 monthsH Hazardous materials studies, abatement and removals is excludedI FF&E Costs




1) Project Management2) Construction Management3) Project Controls and Scheduling Support A-40



factors for this project

Wherever possible, CCMI made its estimate based upon the actual measurement of differentitems of work. For the remaining items, CCMI utilized parametric measurements were usedin conjunction with references from other projects of a similar nature.

The estimate was prepared by a team of CCMI’s cost consultants experience in construction costs at all stages of design. These consultants have used pricing data from CCMI’s database for construction, updated to reflect conditions in the local area of the project. In some cases quotes were solicited from outside sources to substantiate in-house pricing data.

The attachment to this response entitled, “TURN-030 Q52 Rector M&T Design Statement” provides additional details underlying the estimate shown on the referenced workpaper. Please note the Quantity listed under the Construction Section of the estimate is the square footage of the overall project.

A-41


SubcontractDivision 2 - Site Work 15,000 sf $99.62 $1,494,305 $0 $1,494,305Division 3 - Concrete and Reinforcement 15,000 sf $38.43 $576,395 $0 $576,395Division 5 - Steel 15,000 sf $1.76 $26,365 $0 $26,365Division 6 - Carpentry and Millwork 15,000 sf $7.39 $110,852 $0 $110,852Division 7 - Moisture Protection 15,000 sf $4.11 $61,709 $0 $61,709Division 8 - Doors, Frames, Glass and Glazing 15,000 sf $19.28 $289,265 $0 $289,265Division 9 - Finishes 15,000 sf $70.62 $1,059,275 $0 $1,059,275Division 10 - Specialties 15,000 sf $7.36 $110,469 $0 $110,469Division 11 - Equipment 15,000 sf $11.34 $170,048 $0 $170,048Division 13 - Special Construction 15,000 sf $105.04 $1,575,637 $0 $1,575,637Division 15 - Mechanical 15,000 sf $47.97 $719,553 $0 $719,553Division 16 - Electrical 15,000 sf $73.41 $1,101,083 $0 $1,101,083

Subtotal 15,000 sf $486.33 $7,294,955 $0 $7,294,955General Conditions / Insurances 15,000 sf $28.13 $421,961 $0 $421,961G.C. Fee 15,000 sf $18.89 $283,300 $0 $283,300


Moves 0 ls $0.00 $0 $0 $0Incidentals 1 ls $6,360.00 $0 $6,360 $6,360Internal Signage, allowance 1 ls $23,830.00 $23,830 $0 $23,830Artwork, allowance 1 ls $17,950.00 $17,950 $0 $17,950Appliances 1 ls $31,770.00 $31,770 $0 $31,770Furniture 1 ls $400,000.00 $400,000 $0 $400,000Equipment 1 ls $50,000.00 $0 $50,000 $50,000


Subtotal FF&E Costs $1,251,550 $56,360 $1,307,909

Plan Check & Permit Fees 1 ls $112,000 $0 $112,000Arch/Engineering, Budget per SCE 1 ls $335,000 $0 $335,000Procurement 1 ls $45,075 $0 $45,075



1 ls $350,700 $350,700 $350,700

Project Controls 1 ls 66,300$ $66,300 $0 $66,300Subtotal SCE Mngmt Costs $619,800 $0 $619,800

Subtotal Project $10,420,000Constructability and Risk Management $615,000 $0 $615,000Project Totals $11,035,000


FF&E

SCE Security Syatems


Management Costs


Rector Maintenance and Test Building Schematic Design Statement of Probable Cost


Construction Cost


Documents

SCE-17 Vol. 05 Rebuttal Testimony€¦ · Historical and Forecast of Capital Expenditures SCE Recorded 2014 - 2019 and SCE’s Rebuttal Position (Nominal $000) 3 B. F L O C E 4 Facility