BILL ANALYSIS                                                                                                                                                                                                    Ó




           ----------------------------------------------------------------- 
          |SENATE RULES COMMITTEE            |                        SB 660|
          |Office of Senate Floor Analyses   |                              |
          |(916) 651-1520    Fax: (916)      |                              |
          |327-4478                          |                              |
           ----------------------------------------------------------------- 


                                UNFINISHED BUSINESS 


          Bill No:  SB 660
          Author:   Leno (D) and Hueso (D)
          Amended:  9/4/15  
          Vote:     21  

           SENATE ENERGY, U. & C. COMMITTEE:  7-2, 4/27/15
           AYES:  Hueso, Cannella, Hertzberg, Hill, Leyva, McGuire, Wolk
           NOES:  Fuller, Morrell
           NO VOTE RECORDED:  Lara, Pavley

           SENATE APPROPRIATIONS COMMITTEE:  5-2, 5/28/15
           AYES:  Lara, Beall, Hill, Leyva, Mendoza
           NOES:  Bates, Nielsen

           SENATE FLOOR:  29-7, 6/2/15
           AYES:  Allen, Anderson, Beall, Block, Cannella, De León,  
            Galgiani, Glazer, Hall, Hancock, Hernandez, Hertzberg, Hill,  
            Hueso, Jackson, Lara, Leno, Leyva, Liu, McGuire, Mendoza,  
            Mitchell, Monning, Moorlach, Pan, Pavley, Roth, Wieckowski,  
            Wolk
           NOES:  Berryhill, Gaines, Huff, Morrell, Nguyen, Nielsen, Stone
           NO VOTE RECORDED:  Bates, Fuller, Runner, Vidak

           ASSEMBLY FLOOR:  80-0, 9/10/15 - See last page for vote

           SUBJECT:   Public Utilities Commission


          SOURCE:    Author

          DIGEST:   This bill proposes a suite of reforms of the  
          governance, rules, operations and procedures of the California  
          Public Utilities Commission (CPUC), including: reform of the  
          laws and rules related to ex parte communications; criteria and  
          process for disqualification of commissioners to a proceeding;  








                                                                     SB 660  
                                                                    Page  2



          and authorizes the commission to appoint the chief  
          administrative law judge.

          Assembly Amendments remove provisions of this bill that (1)  
          limit the powers of the president of the agency, (2) require the  
          commission to vote in an open meeting on the assignment or  
          reassignment of any proceeding; and narrow other provisions.   
          The amendments also add provisions, including: (1) authorizing  
          the commission to appoint the Chief Administrative Law Judge  
          (ALJ); (2) requiring a summary log to disclose ex parte  
          communications in quasi-legislative proceedings; and other  
          provisions. 

          ANALYSIS:
          
          Existing law:

           1) Establishes the CPUC with five members appointed by the  
             governor and confirmed by the Senate and empowers the CPUC to  
             regulate privately owned public utilities in California.  
             (Article XII of the California Constitution; Public Utilities  
             Code §301 et seq.)

           2) Requires the Governor to designate one of the commissioners  
             as president, who is authorized to direct and prescribe  
             duties of an attorney (general counsel), executive director,  
             and other staff and preside at CPUC meetings. (Public  
             Utilities Code §305)

           3) Authorizes the CPUC to appoint a general counsel to  
             represent the CPUC in all actions, to commence, prosecute or  
             intervene in proceedings as directed by the president, and to  
             advise the CPUC and each commissioner on all matters. (Public  
             Utilities Code §307)

           4) Authorizes the executive director to employ officers, ALJs,  
             and other staff to perform the duties and exercise powers  
             conferred on the CPUC. (Public Utilities Code §309)

           5) Requires the CPUC to adopt procedures on the  
             disqualification of ALJs due to bias or prejudice. (Public  
             Utilities Code §309.6)








                                                                     SB 660  
                                                                    Page  3




           6) Requires the CPUC to determine the nature of a proceeding,  
             specifically whether it is quasi-legislative, ratesetting, or  
             adjudicatory and establishes definitions and rules related to  
             each. (Public Utilities Code §1701 et seq.)

           7) Directs the CPUC to adopt by regulation rules to define  
             decisionmakers and persons of interests for purposes of  
             applying ex parte communication rules. (Public Utilities Code  
             §1701.1)

           8) Prohibits ex parte communication in adjudication cases.  
             (Public Utilities Code §1701.2)

           9) Prohibits ex parte communication in ratesetting cases, but  
             permits oral ex parte communication if (a) all-parties are  
             invited with no less than three day notice (b) written ex  
             communication provided copies are transmitted to all parties,  
             and (c) when an ex parte meeting is granted to a party, all  
             other parties are also granted individual ex parte. (Public  
             Utilities Code §1701.3)

           10)Provides that ex parte communication in quasi-legislative  
             cases is permitted without restriction. (Public Utilities  
             Code §1701.4) 

           11)Establishes rules for state agencies to ensure meetings are  
             open, public and available to all, as noted in the  
             Bagley-Keene Open Meeting Act. Restricts a majority of  
             members of a state governing body, including the CPUC, from  
             meeting without proper notice, public access, and  
             transparency. (Government Code §11120)

          This bill:

           1) Reforms and expands ex parte communications rules for  
             proceedings, including prohibiting these communications in  
             ratesetting proceedings and allowing these communications in  
             quasi-legislative proceedings with disclosure requirements on  
             decisionmakers. 

           2) Requires the CPUC to define decisionmaker to include  








                                                                     SB 660  
                                                                    Page  4



             commissioners, their personal staff advisors, the general  
             counsel, the executive director, the Chief ALJ and assigned  
             ALJ. 

           3) Requires the CPUC to adopt procedures for disqualification  
             of commissioners due to bias or prejudice similar to those of  
             ALJs and specifies criteria for such action in ratesetting  
             and adjudicatory proceedings. 

           4) Requires the CPUC to specify procedural matters that do not  
             constitute an ex parte communication in its rules and  
             practice and procedures.

           5) Requires the CPUC to appoint a Chief ALJ to be responsible  
             for executive and administrative management and oversight of  
             the Administrative Law Division. Requires the Chief ALJ,  
             rather than the executive director, to keep a true and full  
             record of all commission proceedings.

           6) Authorizes the CPUC to delegate specific management and  
             internal oversight functions to committees comprised of two  
             commissioners. 
           7) Prohibits interested parties from oral or written ex parte  
             communications related to procedural issues, except with the  
             presiding ALJ.

           8) Makes a violation of the ex parte communications rules  
             enforceable by the Attorney General with consideration for  
             the severity of the violation. 

          Background

          The CPUC quasi-independent, but still accountable to the  
          Legislature.  The CPUC was established by constitutional  
          amendment as part of the sweep of progressive reforms in the  
          early 1900s. Article XII of the California Constitution grants  
          the CPUC authority to regulate public utilities "subject to  
          control of the Legislature" and grants the Legislature "plenary  
          power" to confer authority and jurisdiction upon the CPUC, with  
          the intent that the CPUC be accountable to the Legislature. 

          Emails demonstrate "Culture of Conversation."  During the summer  








                                                                     SB 660  
                                                                    Page  5



          and fall of 2014, PG&E, bowing to legal pressure from the City  
          of San Bruno, began to release a growing number of emails  
          between the utility and CPUC officials.  PG&E released 65,000  
          emails from over a five-year period that PG&E says it believes  
          "violated CPUC rules governing ex parte communications."   The  
          initial release of emails revealed efforts by PG&E executives to  
          influence the CPUC's assignment of the administrative law judge  
          to the San Bruno proceeding.  Many of the other emails exposed  
          regular, private, familiar communications between PG&E and  
          certain CPUC commissioners, including former CPUC President  
          Michael Peevey and current commissioner Peter Florio, as well as  
          senior CPUC officials. 

          Criminal investigations opened.  Since PG&E's initial release of  
          the emails, both the state Attorney General and the United  
          States Department of Justice have opened investigations into  
          communications between the CPUC and regulated entities.  PG&E  
          has fired three senior executives.  A senior CPUC official has  
          resigned, while other top CPUC officials - including longtime  
          CPUC President Michael Peevey and Executive Director Paul  
          Clannon - have retired under pressure. Investigators working  
          with the Attorney General's Office have raided the CPUC offices  
          and the homes of former CPUC Commissioner President Peevey and  
          PG&E former-Vice President Brian Cherry. 

          San Onofre Nuclear Generating Stations (SONGS).  In early  
          February, after a newspaper published details of the search  
          warrant, Southern California Edison disclosed a meeting that  
          occurred two years prior in Warsaw, Poland between then-CPUC  
          President Peevey and a utility executive in which they discussed  
          how to resolve the shutdown plans for SONGS. The facility had a  
          failed steam generator that required SONGS to be permanently  
          retired.  In November 2014, the CPUC approved a settlement  
          agreement between utilities and ratepayer advocates that split  
          the costs of retiring the facility and the associated  
          replacement power, with ratepayers shouldering $3.3 billion of  
          the $4.7 billion total costs.  

          Ex parte communications.  Substantive communication outside of  
          the public record that occurs between a decisionmaker and a  
          party with an interest in a CPUC proceeding are known as "ex  
          parte" communications. Statute recognizes that ex parte  








                                                                     SB 660  
                                                                    Page  6



          communications can conflict with the need for public decision at  
          the CPUC.  The current law directs the CPUC to adopt regulations  
          requiring reporting of ex parte communications. Statute does not  
          require a CPUC decisionmaker to report ex parte communication  
          with an interested party. Statute directs CPUC to identify each  
          of its proceedings according to one of three categories -  
          adjudicatory, quasi-legislative, and ratesetting - and provides  
          ex parte rules applicable to each type of proceeding.

          Party of One.  The CPUC's laws and rules governing ex parte  
          communication are unique among other state agencies, and also  
          among similar agencies across the nation.  Many of the experts  
          who presented at the March 11th oversight hearing of the Senate  
          Energy, Utilities and Communication Committee noted that rules  
          governing ex parte communications in ratesetting proceedings may  
          be the most permissive as compared to other agencies, such as  
          the Federal Regulatory Energy Commission and other states'  
          ratesetting agencies.  The law is less clear in ratesetting  
          proceedings, a major function of the CPUC, both stating that ex  
          parte communication is prohibited, while allowing for a number  
          of exceptions. Many of the presenters at the March 11th, 2015  
          hearing advocated for doing away with ex parte communication  
          because of the lack of fairness, the un-level playing field, the  
          time and resources that are required of commissioners and  
          others.  However, some interested parties have expressed  
          concerns that doing away with ex parte communications may  
          further challenge interests with a less prominent issue in a  
          ratesetting proceeding to have their concerns heard. 

          Disqualification of commissioners.  The law directs the CPUC to  
          establish rules to address incidents when an ALJ may be  
          disqualified from a proceeding.  However, no similar mention is  
          made of addressing concerns of bias by commissioners.  In recent  
          times, any motions to recuse a commissioner from a proceeding  
          due to a party's claim that there is undue bias have been  
          denied.  After the release of the PG&E emails, the City of San  
          Bruno motioned for a recusal of then-CPUC President Peevey. That  
          motion was denied.  The ALJ at the time stated that "No specific  
          rule sets forth a procedure for addressing motions to seek the  
          recusal of a Commissioner for cause."

          Related Legislation








                                                                     SB 660  
                                                                    Page  7



          
          AB 825 (Rendon, 2015) proposes a suite of reforms of the CPUC to  
          make the agency more accessible and transparent to the public.  
          The bill is currently headed to the Assembly Floor for  
          concurrence. 

          AB 1023 (Rendon, 2015) proposes to codify the summary log  
          requirements currently required at the CPUC for ratesetting  
          proceedings and extends those requirements to quasi-legislative  
          proceedings. The bill is currently on the Senate Floor. 

          SB 48 (Hill, 2015) proposes a suite of reforms of the CPUC,  
          including modifying the role of the president, meeting location  
          requirements, and other reforms.  The bill is currently on the  
          Assembly Floor. 

          SB 215 (Leno, 2015) proposes a suite of reforms of the CPUC  
          related to governance and operations, including disqualification  
          of commissioners to proceedings, modifying the role of the  
          president, and other reforms. Many of the provisions of this  
          bill were amended into SB 660. The bill is currently in the  
          Senate Energy, Utilities and Communications Committee.

          FISCAL EFFECT:   Appropriation:    No          Fiscal  
          Com.:YesLocal:   Yes

          According to the Assembly Appropriations Committee, increased  
          CPUC costs of an estimated $900,000 including $430,000 limited -  
          term and $470,000 ongoing costs, to implement and enforce the  
          provisions of this bill and hold additional public meetings, as  
          necessary (Public Utilities Reimbursement Account).




          SUPPORT:   (Verified9/10/15)


          California Bus Association
          California Environmental Justice Alliance
          Center for Accessible Technology
          Consumer Federation of California








                                                                     SB 660  
                                                                    Page  8



          Privacy Rights Clearinghouse
          San Diego Area Congregations for Change
          Sierra Club California
          The Greenlining Institute
          The Utility Reform Network


          OPPOSITION:   (Verified9/10/15)


          None received


          ARGUMENTS IN SUPPORT:      The authors state that  
          decision-making based upon the public record is central to the  
          work of the CPUC whose decisions are addressed in proceedings  
          more akin to a judicial process in a courtroom setting and  
          unlike other state agencies or bodies.  The recent release of  
          65,000 emails has demonstrated a cozy relationship between some  
          of the commissioners and staff at the CPUC and the regulated  
          utilities.  These exchanges have severely undermined the  
          public's trust in the agency.  While in some cases rules may  
          have been broken, it is also evident that the problems at the  
          CPUC are more systemic than solely a personality or an  
          individual.  There is a need to strengthen and clarify rules  
          governing ex parte communication to preserve the public trust  
          and prevent future scandals.  Furthermore, the authors state  
          that there is an insufficient role for CPUC commissioners other  
          than the president to direct management of the CPUC and an  
          unreasonable process with unduly restrictive standards for  
          determining whether a commissioner should be disqualified due to  
          prejudice. 

           ASSEMBLY FLOOR:  80-0, 9/10/15
           AYES:  Achadjian, Alejo, Travis Allen, Baker, Bigelow, Bloom,  
            Bonilla, Bonta, Brough, Brown, Burke, Calderon, Campos, Chang,  
            Chau, Chávez, Chiu, Chu, Cooley, Cooper, Dababneh, Dahle,  
            Daly, Dodd, Eggman, Frazier, Beth Gaines, Gallagher, Cristina  
            Garcia, Eduardo Garcia, Gatto, Gipson, Gomez, Gonzalez,  
            Gordon, Gray, Grove, Hadley, Harper, Roger Hernández, Holden,  
            Irwin, Jones, Jones-Sawyer, Kim, Lackey, Levine, Linder,  
            Lopez, Low, Maienschein, Mathis, Mayes, McCarty, Medina,  








                                                                     SB 660  
                                                                    Page  9



            Melendez, Mullin, Nazarian, Obernolte, O'Donnell, Olsen,  
            Patterson, Perea, Quirk, Rendon, Ridley-Thomas, Rodriguez,  
            Salas, Santiago, Steinorth, Mark Stone, Thurmond, Ting,  
            Wagner, Waldron, Weber, Wilk, Williams, Wood, Atkins




          Prepared by:Nidia Bautista / E., U., & C. / (916) 651-4107
          9/10/15 23:28:16


                                   ****  END  ****