BEFORE THE PUBLIC UTILITIES COMMISSION OF THE STATE OF CALIFORNIA NOTICE OF EX PARTE COMMUNICATION OF SOUTHERN CALIFORNIA EDISON COMPANY (U 338-E)

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1 BEFORE THE PUBLIC UTILITIES COMMISSION OF THE STATE OF CALIFORNIA Application of Southern California Edison Company (U 338-E) for Authority to, Among Other Things, Increase its Authorized Revenues for Electric Service in 2015, and to Reflect That Increase in Rates. A Filed November 12, 2013 NOTICE OF EX PARTE COMMUNICATION OF SOUTHERN CALIFORNIA EDISON COMPANY (U 338-E) KRIS G. VYAS GLORIA M. ING Attorneys for SOUTHERN CALIFORNIA EDISON COMPANY 2244 Walnut Grove Avenue Post Office Box 800 Rosemead, California Telephone: (626) Facsimile: (626) Dated: November 2, 2015

2 BEFORE THE PUBLIC UTILITIES COMMISSION OF THE STATE OF CALIFORNIA Application of Southern California Edison Company (U 338-E) for Authority to, Among Other Things, Increase its Authorized Revenues for Electric Service in 2015, and to Reflect That Increase in Rates. A Filed November 12, 2013 NOTICE OF EX PARTE COMMUNICATION OF SOUTHERN CALIFORNIA EDISON COMPANY (U 338-E) Pursuant to Rule 8.4 of the Rules of Practice and Procedure of the California Public Utilities Commission (CPUC or Commission), Southern California Edison Company (SCE) hereby gives notice of the following written ex parte communication relating to the abovereferenced proceeding. On October 29, 2015, at approximately 3:00 p.m., SCE sent a letter to Commissioner Carla J. Peterman regarding the tax-related issues in this case. SCE served the letter by overnight delivery and by electronic mail. Copies of the letter were concurrently served by overnight delivery and electronic mail on President Michael Picker, Commissioner Liane M. Randolph, Commissioner Mike Florio, Commissioner Catherine J.K. Sandoval, Administrative Law Judge Kevin Dudney, and Administrative Law Judge Melanie Darling. Copies of the letter were also concurrently served by electronic mail on all parties to this proceeding. A copy of the letter is found at Attachment A. The letter is signed by SCE President Pedro Pizarro. In summary, the letter states that: (1) If the final decision in this proceeding adopts the Proposed Decision s (PD s) tax adjustment and the Internal Revenue Service (IRS) were to subsequently determine 1

3 that the decision violates the normalization rules, SCE would be precluded from claiming accelerated depreciation on SCE s 2015 federal income tax return and subsequently-filed federal income tax returns until the violation is corrected. This would eliminate approximately $210 million of accumulated deferred income tax credits from SCE s 2015 rate base, which would grow to $360 million by SCE could not claim bonus depreciation (which is a form of accelerated depreciation) if Congress extends it. (2) If the Commission decides not to change the PD s tax adjustment or does not place resolution of this issue on a separate track, then SCE asks that the Commission add language similar to what the Commission included in SCE s 2012 General Rate Case decision (D ). That decision provided that if the IRS found a normalization violation, it could be cured through an advice letter filing, which adjusted revenues effective to the beginning of the test year. (3) In light of the ongoing uncertainty over tax repair deductions, SCE asks that the Commission keep open the existing memorandum account in this proceeding for the limited purpose of continued tracking of these amounts and adjusting the authorized revenue requirement accordingly. 2

4 Respectfully submitted, KRIS G. VYAS GLORIA M. ING /s/kris G. Vyas By: Kris G. Vyas Attorneys for SOUTHERN CALIFORNIA EDISON COMPANY 2244 Walnut Grove Avenue Post Office Box 800 Rosemead, California Telephone: (626) Facsimile: (626) November 2,

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8 BEFORE THE PUBLIC UTILITIES COMMISSION OF THE STATE OF CALIFORNIA Application of Southern California Edison Company (U 338-E) for Authority to, Among Other Things, Increase its Authorized Revenues for Electric Service in 2015, and to Reflect That Increase in Rates. A Filed November 12, 2013 CERTIFICATE OF SERVICE I hereby certify that I have this day served a copy of NOTICE OF EX PARTE COMMUNICATION OF SOUTHERN CALIFORNIA EDISON COMPANY (U 338-E) on all known parties to A to each person named in the official service list by: [X] Transmitting the copies via to all parties who have provided an address [X] Placing the copies in sealed envelopes and causing such envelopes to be delivered by hand or by overnight courier to the offices of the Assigned ALJ(s) or other addressee(s). ALJ Kevin R. Dudney CPUC 505 Van Ness Avenue San Francisco, CA ALJ Melanie Darling CPUC 505 Van Ness Avenue San Francisco, CA Executed this Monday, November 02, 2015 at Rosemead, CA. /s/ Alejandra Arzola Alejandra Arzola, Project Analyst SOUTHERN CALIFORNIA EDISON COMPANY 2244 Walnut Grove Avenue Post Office Box 800 Rosemead, California 91770

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