So Cal Edison Co Class C Water and Small Gas Utilities and Safe Annual Yield

BACKGROUND

On March 11, 2026, Southern California Edison Company (SCE) filed an application (A.26-03-003) for authority to, among other things, recover costs for its Class C water utility and small gas utility.  SCE requested recovery in rates for certain costs that SCE incurred in the course of providing water and gas services to customers on Santa Catalina Island. 

SCE requested that the California Public Utilities Commission (CPUC) authorize SCE to recover $6.207 million in recorded costs from several memorandum accounts, including the Catastrophic Event Memorandum Account (CEMA), Catalina Water Pipeline Assessment Memorandum Account (CWPAMA), Catalina Water Decommissioned Pipe Memorandum Account (CWDPMA), Catalina Water Rationing Memorandum Account (CWRMA), and Lead and Copper Rule Memorandum Account (LCMA). SCE also requested to collect its memorandum costs solely from non-residential customers.

On April 30, 2026, SCE filed another application (A.26-04-017) for authority to revise and increase its Tariff Schedule Fresh Water Yield (FWY) to reflect an increase in its Safe Annual Yield (SAY), primarily due to increase in water production of its desalination plant. SCE also requests approval of a Special Agreement with Santa Catalina Islan Company (SCICo), which would increase the water allocation to SCICo. Finally, SCE requests revision of the Water Requirement Factors in its existing Tariff Rule 3.

On September 11, 2026, the CPUC consolidated both applications under rate setting proceedings.

PUBLIC ADVOCATES OFFICE’S POSITION

The Public Advocates Office protested SCE's applications on April 13, 2026, and June 5, 2026, respectively.

On September 11, 2026, the Public Advocates Office filed and provided its report and recommendations for SCE's Class C water utility and small gas utility application. The Public Advocates Office urges the CPUC to reject or reduce SCE's requested recovery because certain costs are untimely, excessive, unsupported, or inconsistent with cost-causation principles. The Public Advocates also recommends that any authorized costs be recovered through a fair and equitable rate design that appropriately reflects cost causation. Specifically, of SCE's $6.207 million recovery request, the Public Advocates Office recommends the CPUC:

• should not authorize SCE’s recovery of $428,197 of expenses recorded in COVID-19 CEMA for its gas operations during 2020-2022 and
• should not authorize SCE’s recovery of $2.57 million of expenses recorded in its COVID-19 CEMA Water expenses for 2020-2021.

On September 18, 2026, the Public Advocates Office filed and provided its recommendations to SCE's SAY application. The Public Advocates Office encourages the CPUC to authorize a revised Tariff Schedule FWY based on a lower SAY of 405.3 Acre Feet Per Year (AFY) to correctly account for significant water loss within the system. Additionally, the CPUC should reject the proposed Special Agreement between SCE and SCICo until both parties agree on the value of easement that SCE will acquire from SCICo and consider the ongoing Operations and Maintenance (O&M) expenses in determining the appropriate amount of water allocation to SCICo. Lastly, the CPUC should also reject SCE’s request to revise the existing Water Requirement Factors in Tarriff Rule 3, as SCE fails to provide sufficient support for the proposed revisions.

Downloads:

A.26-03-003 Public Advocates Office Executive Summary (M. Aslam)

A.26-03-003 Public Advocates Office Report on CEMA Gas Account (L. Loethen)

A.26-03-003 Public Advocates Office Report on Water Memo Acc and Proposed Rev Recovery (S. Ibrahim)

A.26-04-017 Public Advocates Office Report on Safe Annual Yield (A. Andrade)