XXI. Expedited Advice Letter Process

Edison also requests that the commission adopt an expedited Advice Letter (AL) process whereby the Commission can pre-approve capital additions/betterments projects and certain reclassification of charges permitted under the PPA.

A. Capital Additions/Betterments

If MVL intends to undertake expenditures relating to capital additions or betterments and Edison intends to approve such expenditures, Edison may seek pre-approval at the Commission to include these costs as part of the CRC or the O&M charge. Pursuant to the PPA, qualifying expenditures must: (1) increase or improve the output or operating efficiency of Mountainview (Betterment Work); (2) result of change in law or regulation (Compliance Work); (3) enable the facility to maintain a consistent level of operating efficiency over the PPA term (facility refurbishment); or (4) result due to necessary major equipment repair or replacement work.

Edison proposes filing an AL before this Commission that includes a description of the expenditure, classification, estimated cost, and Edison's preferred approach for rate recovery. Edison proposes that the Commission issue a Final Resolution within 95 days of the AL filing, with protests due at Day 20, Edison responses due Day 25, Energy Draft Resolution issued Day 55, Comments due Day 69, Reply comments due Day 74, Final Resolution due Day 95.

B. Reclassification of Charges

Section 8.08 of the PPA permits Edison and MVL to mutually agree to reclassify a charge identified in Section 7.02 or Section 7.03 of the PPA and expressly gives Edison the right to seek Commission pre-approval of that reclassification before it is implemented. If Edison and MVL decide to do this, Edison proposes to obtain Commission pre-approval through the expedited AL process.

Edison would file an AL that includes a description of the proposed reclassification, justification for the reclassification, and the dollar impact on the applicable charge categories on both a recorded and forecast basis. Edison proposes that the same procedural schedule as described for the capital/betterments expenditures be followed.

No party has submitted evidence opposing this procedure. We find it is reasonable as it saves after-the-fact reasonableness review under ERRA. We adopt the expedited AL process, including the 95-day procedural schedule, described above for Capital Additions/Betterment projects and certain reclassification of charges.