SOUTHERN CALIFORNIA GAS COMPANY (DATA REQUEST CALADVOCATES-SK-SCG-2020-01) DATE RECEIVED: JANUARY 24, 2020 DATE SUBMITTED: FEBRUARY 7, 2020 ______________________________________________________________________ In response to Questions 1 and 2 of SK-SCG-2019-01, SoCalGas states “[t]he consultant’s work is shareholder funded.” The “consultant’s work” is in reference to the approximately $10,000 in consultant charges identified in SoCalGas’ response to Questions 3 and 4 of HB-SCG-2019-13. QUESTION 1: 1. Has the referenced “consultant’s work” always been booked to shareholder funded accounts? a. Please provide all journal entries for the referenced consultant contract showing the account charged and any transfers of charges between accounts. RESPONSE 1: SoCalGas objects to this request as seeking information that is outside the statutory authority delegated to the Public Advocates Office by Pub. Util. Code §§ 309.5 and 314. The consultant’s work is shareholder funded. The information requested would reveal relationships and strategic business choices made by SoCalGas and others with whom it associates and chill the exercise of SoCalGas’ and other’s constitutional rights. See e.g., NAACP v. Alabama (1958) 357 U.S. 449, 462; Perry v. Schwarzenegger (9th Cir. 2010) 591 F.3d 1147, 1160. The appropriateness of the disclosure of this information is the subject of an appeal being reviewed by the full Commission. Subject to the above, and without waiving its objection, SoCalGas responds as follows: Although the consultant charges have always been charged to the Balanced Energy internal order (IO) and the intent in setting up that IO was that it be shareholder funded, due to an inadvertent accounting error, the balanced energy IO was not initially properly designated as a shareholder account. That error was identified and fixed. See the response to question 4. Journal entries related to the consultant charges are below. There were $474.16 in expenses paid to the consultant related to the same scope of work. Through an inadvertent error, the consultant was paid two $10,000 payments. SoCalGas is endeavoring to recover the second $10,000 payment from the vendor and the amount has been removed to a receivable account. Pursuant to its objection, SoCalGas has not provided the vendor name in the first screenshot. Posting Date Ref. document number Order Cost Element 1 Cost element name Val/COArea Crcy Aux. acct assignment_1 Offsetting acct no. SOUTHERN CALIFORNIA GAS COMPANY (DATA REQUEST CALADVOCATES-SK-SCG-2020-01) DATE RECEIVED: JANUARY 24, 2020 DATE SUBMITTED: FEBRUARY 7, 2020 ______________________________________________________________________ 9/5/2019 1901415826 300796601 6220600 10/1/2019 1901419493 300796601 6220600 10/1/2019 1901419500 300796601 6220600 2 SRVCONSULTINGOTHER SRVCONSULTINGOTHER SRVCONSULTINGOTHER 10,000.00 CTR 22002204 131345 474.16 CTR 22002204 131345 10,000.00 CTR 22002204 131345 SOUTHERN CALIFORNIA GAS COMPANY (DATA REQUEST CALADVOCATES-SK-SCG-2020-01) DATE RECEIVED: JANUARY 24, 2020 DATE SUBMITTED: FEBRUARY 7, 2020 ______________________________________________________________________ Question 2 of SK-SCG-2019-01 requests SoCalGas to provide any and all documentary evidence that the above referenced consultant costs were charged to shareholders. In response to Question 2 of SK-SCG-2019-01, SoCalGas provides a screenshot of a table labeled “Display Invoice 1766820 (1/3),” and SoCalGas states “The consultant charges were charged to IO 30076601, Balanced Energy, which is shareholder funded.” 1 QUESTION 2: Please provide any and all documentary evidence that the cost of the $10,000 were charged to shareholders. RESPONSE 2: SoCalGas objects to this request as seeking information that is outside the statutory authority delegated to the Public Advocates Office by Pub. Util. Code §§ 309.5 and 314. The consultant’s work is shareholder funded. The information requested would reveal relationships and strategic business choices made by SoCalGas and others with whom it associates and chill the exercise of SoCalGas’ and other’s constitutional rights. See e.g., NAACP v. Alabama (1958) 357 U.S. 449, 462; Perry v. Schwarzenegger (9th Cir. 2010) 591 F.3d 1147, 1160. The appropriateness of the disclosure of this information is the subject of an appeal being reviewed by the full Commission. SoCalGas objects to this request as overbroad in seeking “any and all documentary evidence.” Subject to the above, and without waiving its objection, SoCalGas responds as follows: Please see SoCalGas’ Response to Question 2 of SK-SCG-2019-01. In addition, please see the below regarding the $474.16 in expenses, which were charged to the Balanced Energy IO. The second $10,000 was also charged to the Balanced Energy IO and SoCalGas is seeking repayment of that amount by the vendor. Pursuant to its objection, SoCalGas has redacted the vendor name, vendor ID, and the description of the activity. 1 The correct IO is 300796601. (Emphasis added.) 3 SOUTHERN CALIFORNIA GAS COMPANY (DATA REQUEST CALADVOCATES-SK-SCG-2020-01) DATE RECEIVED: JANUARY 24, 2020 DATE SUBMITTED: FEBRUARY 7, 2020 ______________________________________________________________________ 4 SOUTHERN CALIFORNIA GAS COMPANY (DATA REQUEST CALADVOCATES-SK-SCG-2020-01) DATE RECEIVED: JANUARY 24, 2020 DATE SUBMITTED: FEBRUARY 7, 2020 ______________________________________________________________________ 5 SOUTHERN CALIFORNIA GAS COMPANY (DATA REQUEST CALADVOCATES-SK-SCG-2020-01) DATE RECEIVED: JANUARY 24, 2020 DATE SUBMITTED: FEBRUARY 7, 2020 ______________________________________________________________________ QUESTION 3: Please provide any and all documentary evidence that the $10,000 was the full amount of the charges associated with the consultant’s work. RESPONSE 3: SoCalGas objects to this request as seeking information that is outside the statutory authority delegated to the Public Advocates Office by Pub. Util. Code §§ 309.5 and 314. The consultant’s work is shareholder funded. The information requested would reveal relationships and strategic business choices made by SoCalGas and others with whom it associates and chill the exercise of SoCalGas’ and other’s constitutional rights. See e.g., NAACP v. Alabama (1958) 357 U.S. 449, 462; Perry v. Schwarzenegger (9th Cir. 2010) 591 F.3d 1147, 1160. The appropriateness of the disclosure of this information is the subject of an appeal being reviewed by the full Commission. SoCalGas objects to this request as overbroad in seeking “any and all documentary evidence.” Subject to the above, and without waiving its objection, SoCalGas responds as follows: Through an inadvertent error, the consultant was paid two $10,000 payments. SoCalGas is endeavoring to recover the second $10,000 payment from the vendor. There were also $474.16 in expenses paid to the consultant related to the same scope of work. 6 SOUTHERN CALIFORNIA GAS COMPANY (DATA REQUEST CALADVOCATES-SK-SCG-2020-01) DATE RECEIVED: JANUARY 24, 2020 DATE SUBMITTED: FEBRUARY 7, 2020 ______________________________________________________________________ QUESTION 4: Please provide any and all documentary evidence that charges to IO 30076601 are shareholder funded. RESPONSE 4: SoCalGas objects to this request as seeking information that is outside the statutory authority delegated to the Public Advocates Office by Pub. Util. Code §§ 309.5 and 314. The consultant’s work is shareholder funded. The information requested would reveal relationships and strategic business choices made by SoCalGas and others with whom it associates and chill the exercise of SoCalGas’ and other’s constitutional rights. See e.g., NAACP v. Alabama (1958) 357 U.S. 449, 462; Perry v. Schwarzenegger (9th Cir. 2010) 591 F.3d 1147, 1160. The appropriateness of the disclosure of this information is the subject of an appeal being reviewed by the full Commission. SoCalGas objects to this request as overbroad in seeking “any and all documentary evidence.” Subject to the above, and without waiving its objection, SoCalGas responds as follows: See response to question 5. The Balanced Energy internal order (IO) 300796601 was created in March 2019 for tracking all costs associated with Balanced Energy activities and the intent was to make it a shareholder funded IO. However, an incorrect settlement rule was set up for this IO to FERC 920.0 A&G Salaries, consequently, the costs initially settled to the incorrect FERC account. On September 21, 2019, the SoCalGas Accounting Controller and Accounting Director met with the Strategy, Engagement & Chief Environmental Officer, and confirmed that the Balanced Energy activities should be classified as FERC 426.4 - Expenditures-Civic & Related Activities/Lobbying Costs. The settlement rule was corrected on October 30, 2019 with an effective date of November 1, 2019. Accounting booked retroactive adjustments in November and December 2019 to correct the FERC account balances. 7 SOUTHERN CALIFORNIA GAS COMPANY (DATA REQUEST CALADVOCATES-SK-SCG-2020-01) DATE RECEIVED: JANUARY 24, 2020 DATE SUBMITTED: FEBRUARY 7, 2020 ______________________________________________________________________ 8 SOUTHERN CALIFORNIA GAS COMPANY (DATA REQUEST CALADVOCATES-SK-SCG-2020-01) DATE RECEIVED: JANUARY 24, 2020 DATE SUBMITTED: FEBRUARY 7, 2020 ______________________________________________________________________ QUESTION 5: Please describe in narrative form how SoCalGas accounts for, tracks, and distinguishes shareholder funded IOs and ratepayer funded IOs. RESPONSE 5: During the development of the general rate case (GRC) forecasts, it is sometimes necessary to remove incurred costs so that ratepayers are not funding activities that should be borne by shareholders. There are three main ways that SoCalGas is able to do this for internal orders. The first way is the FERC account that the internal order settles to. Certain FERC accounts such as 426.4 are automatically excluded from the financial information provided to the GRC teams for analysis. Secondly, all internal orders associated with a regulatory account are assigned a unique refundable code. For example, non-GRC refundable programs such as Energy Efficiency are assigned a unique refundable code so that it may be automatically excluded from the financial information provided to the GRC teams for analysis. Third, specific internal orders associated with activities that should be excluded from the GRC may be separately identified by specific internal order number as in the case of the Aliso Incident related expenses that were removed from the TY2019 GRC as ordered by the TY2016 GRC Final Decision (D.) 16-06-054, Ordering Paragraph (OP) 12. 9 SOUTHERN CALIFORNIA GAS COMPANY (DATA REQUEST CALADVOCATES-SK-SCG-2020-01) DATE RECEIVED: JANUARY 24, 2020 DATE SUBMITTED: FEBRUARY 7, 2020 ______________________________________________________________________ QUESTION 6: Please provide any and all documentary evidence that shows SoCalGas will not seek to recover charges made to IO 30076601 in the next General Rate Case. RESPONSE 6: SoCalGas objects to this request as overbroad in seeking “any and all documentary evidence.” Subject to the above, and without waiving its objection, SoCalGas responds as follows: See responses to questions 4 and question 5. The Balanced Energy IO has a FERC designation that will result in its automatic exclusion from the financial information provided to the GRC teams for analysis in its next General Rate Case. SoCalGas will not seek to recover charges made to IO 300796601 in the next General Rate Case. 10 SOUTHERN CALIFORNIA GAS COMPANY (DATA REQUEST CALADVOCATES-SK-SCG-2020-01) DATE RECEIVED: JANUARY 24, 2020 DATE SUBMITTED: FEBRUARY 7, 2020 ______________________________________________________________________ QUESTION 7: Was the invoice for the “consultant’s work” matched to a purchase order? a. If yes, please provide the purchase order. RESPONSE 7: SoCalGas objects to this request as seeking information that is outside the statutory authority delegated to the Public Advocates Office by Pub. Util. Code §§ 309.5 and 314. The consultant’s work is shareholder funded. The information requested would reveal relationships and strategic business choices made by SoCalGas and others with whom it associates and chill the exercise of SoCalGas’ and other’s constitutional rights. See e.g., NAACP v. Alabama (1958) 357 U.S. 449, 462; Perry v. Schwarzenegger (9th Cir. 2010) 591 F.3d 1147, 1160. The appropriateness of the disclosure of this information is the subject of an appeal being reviewed by the full Commission. Subject to the above and without waiving its objections, SoCalGas responds as follows: No, the invoice for the consultant’s work was not matched to a purchase order. 11 SOUTHERN CALIFORNIA GAS COMPANY (DATA REQUEST CALADVOCATES-SK-SCG-2020-01) DATE RECEIVED: JANUARY 24, 2020 DATE SUBMITTED: FEBRUARY 7, 2020 ______________________________________________________________________ QUESTION 8: Please provide the name(s) and title(s) of the SoCalGas employee who signed the contract with the consultant on SoCalGas’ behalf. RESPONSE 8: SoCalGas objects to this request as seeking information that is outside the statutory authority delegated to the Public Advocates Office by Pub. Util. Code §§ 309.5 and 314. The consultant’s work is shareholder funded. Subject to the above, and without waiving its objections, SoCalGas responds as follows: There was not a written contract between SoCalGas and the consultant. 12