Edison's Application

In its February 2001 application in this matter, Edison asked for two forms of relief. First, as noted above, it asked that the balance recorded in the TRRRMA account be transferred as a debit to the TCBA revenue account. Second, Edison requested that it be allowed to collect the $24 million recorded annually in TRRRMA in the PBR distribution rates authorized in D.96-09-092. The authorization to collect this $24 million would continue until Edison's next GRC.

After setting forth the complex history summarized above, Edison's application argues in strong terms that the requested relief should be granted because "the Commission's representations in the FERC case demonstrated that the Commission intended to allow for recovery of [TRRRMA] costs." (Application, p. 11.) Edison contends that in addition to approving the multi-factor allocation methodology in D.97-08-056, the Commission's conduct during the FERC proceedings shows a clear intent to allow recovery of the TRRRMA balances in distribution rates:

"The Commission's position at FERC of: a) agreeing that the overhead allocation methodology presented to FERC is the same method that the Commission approved; and b) indicating to FERC that SCE has another avenue for recovery (i.e., TRRRMA) of these costs in the event FERC rejects SCE's and the Commission's cost allocation methodology, strongly suggests that the Commission intended to treat these costs as distribution-related and provide for TRRRMA recovery in the event FERC adopted a labor allocation methodology. Precluding SCE from recovery of costs recorded in the TRRRMA would be entirely inconsistent with the position taken by the Commission in the FERC proceeding." (Id. at 12-13; emphasis added.)

In addition to arguing that this Commission has essentially promised recovery of the TRRRMA balances in distribution rates, the application sets forth a detailed description of how Edison proposes to do this. A key point is that the A&G and G&I amounts Edison claims it should recover under TRRRMA would "net out" the refunds owed to transmission customers because of FERC's reduction of the $211 million revenue requirement that Edison had requested in Docket No. ER97-2355-000 et al.:

"In this application, SCE is proposing TCBA treatment for both the TRRRMA balance (as a debit to the Revenue Account of the TCBA) and transmission revenue-related refunds (as a credit to the Revenue Account of the TCBA). This ratemaking treatment will result in a net credit to the TCBA by the amount related to the various updates, stipulations and FERC orders discussed in previous sections of this Application (i.e., approximately $14 million in annual revenue requirement). The remaining amount of the transmission revenue-related refunds will effectively net out the balance in the TRRRMA." (Id. at 27.)⁶

The application concludes with a plea that the requested relief be granted ex parte, because Edison "has attached to this application, or incorporated by reference, all of the data needed to support this application." (Id. at 6, 34.)

". . . SCE's transmission revenue requirement request, reflected in [FERC] rates subject to refund on April 1, 1998, of $211 million, was lowered to $173 million, for an annualized revenue requirement difference of $38 million. SCE's requested TRRRMA cost recovery is based on an annualized revenue requirement of $24 million, for a net annualized credit of $14 million to the TCBA. (Note that this analysis ignores the impact of sales growth on the $38 million annualized transmission revenue requirement refund and interest.)" (Id. at 28, n. 39.)