BEFORE THE PUBLIC UTILITIES COMMISSION OF THE STATE OF ...

BEFORE THE PUBLIC UTILITIES COMMISSION OF THESTATE OF CALIFORNIAOrder Instituting Rulemaking to Revise andClarify Commission Regulations Relating to theSafety of Electric Utility and CommunicationsInfrastructure Provider Facilities.))))))Rulemaking 08-11-005(Filed November 6, 2008)OPENING COMMENTS OF SOUTHERN CALIFORNIA EDISON COMPANY(U 338-E) TO THE PROPOSED DECISION IN PHASE 2 – REGULATIONS TOREDUCE FIRE HAZARDS ASSOCIATED WITH OVERHEAD POWER LINES ANDCOMMUNICATION FACILITIESJAMES M. LEHRERROBERT F. LeMOINEAttorneys forSOUTHERN CALIFORNIA EDISON COMPANY2244 Walnut Grove AvenuePost Office Box 800Rosemead, California 91770Telephone: (626) 302-4182Facsimile: (626) 302-6693E-mail: Robert.F.LeMoine@sce.comDated: June 30, 20111820181

TABLE OF CONTENTSI. INTRODUCTION AND SUMMARY.....................................................................................................1II. DISCUSSION .........................................................................................................................................2A. Section 6.3 – GO 95, Rule 18A (Resolution of Safety Hazards).........................................2B. Section 6.4 – Rule 18C (Fire Prevention Plans) ..................................................................5C. Section 6.5 – GO 95, 31.1....................................................................................................6D. Section 6.6 – GO 95, 80.1A, Detailed Inspections: Definition of“One-Year” ..........................................................................................................................6E. Section 6.8 – GO 95, Rule 35, Paragraph 4.........................................................................8F. Section 6.9 – GO 95, Rule 35, Third Exemption.................................................................9G. Section 6.10 – GO 95, Appendix E (Radial Clearance Table) ............................................9H. Section 6.12 – GO 95, Rule 38, Table 2, Footnote (aaa)(Conductor Clearance).........................................................................................................9I. Section 6.13 – GO 95, Rule 44.2 (Additional Construction).............................................10J. Section 6.14 – GO 95 Rule 48 (Ultimate Strength of Materials).......................................12K. Section 6.16 – Data Collection ..........................................................................................12L. Section 6.17 – Fire Threat Maps........................................................................................12M. Section 6.20 – Cost Recovery............................................................................................13III. CONCLUSION....................................................................................................................................13

TABLE OF AUTHORITIESCommission DecisionsD.04-04-065.................................................................................................................................... 7D.09-08-029........................................................................................................................... passim

SUBJECT INDEX – RECOMMENDED CHANGES TO THE PD1. Include the proposed consensus Section E “Changes to Requirements Herein”language in GO 165.2. Confirm that electric utilities with General Order (GO) 165 inspection andmaintenance programs that are consistent with the purpose of Rule 18A shouldcontinue to follow those programs, including all timelines for corrective actioncontained in those programs.3. Remove the note added sua sponte to GO 165 defining a “year” as 12 consecutivecalendar months.4. Delete the new note added sua sponte to Rule 44.2 defining “a material increase”sufficient to require a pole load calculation and reaffirm Ordering Paragraph 4 of thePhase 1 Decision (D.09-08-029).5. Remove language from the PD interpreting Rule 48 that is inconsistent with GO 95,Appendix F, Part 1, Example 11.

BEFORE THE PUBLIC UTILITIES COMMISSION OF THESTATE OF CALIFORNIAOrder Instituting Rulemaking to Revise andClarify Commission Regulations Relating to theSafety of Electric Utility and CommunicationsInfrastructure Provider Facilities.))))))Rulemaking 08-11-005(Filed November 6, 2008)OPENING COMMENTS OF SOUTHERN CALIFORNIA EDISON COMPANY(U 338-E) TO THE PROPOSED DECISION IN PHASE 2 – REGULATIONS TOREDUCE FIRE HAZARDS ASSOCIATED WITH OVERHEAD POWER LINES ANDCOMMUNICATION FACILITIESI.INTRODUCTION AND SUMMARYPursuant to Rule 14.3(a) of the Rules of Practice of Procedure of the California PublicUtilities Commission (Commission or CPUC), Southern California Edison Company (SCE)respectfully files its Opening Comments on the Proposed Decision (PD) in Phase 2 – Regulationsto Reduce Fire Hazards Associated with Overhead power Lines and Communication Facilities.SCE appreciates the dedication and hard work of ALJ Kenney and Commissioner Simonand especially ALJs Minkin and Vieth for their assistance in facilitating the discussion amongthe stakeholders during the 25 days of workshops held in this proceeding. SCE’s OpeningComments focus on aspects of the PD that can be improved in the final Commission decision. Inaccordance with Rule 14.3, a Subject Index of Recommended Changes to the PD is includedabove, and an Appendix of Changes to the Findings of Fact and Conclusions of Law is appendedto the end of these comments.‐1‐

SCE will not comment specifically on each and every one of the rules adopted by thePD. 1 However, SCE reserves the right to comment on any of the proposed rule changes in itsReply Comments in response to other parties’ arguments.II.DISCUSSIONA. Section 6.3 – GO 95, Rule 18A (Resolution of Safety Hazards)Recommendation: Confirm that electric utilities with General Order (GO) 165inspection and maintenance programs that are consistent with the purpose of Rule 18Ashould continue to follow those programs, including all timelines for corrective actioncontained in those programs.The Commission’s Phase 1 Decision in this proceeding adopted Rule 18A, whichrequires electric and communications utilities to have an inspection and maintenance programthat identifies problems, prioritizes maintenance items, and performs corrective actions. 2 Inrecognition of the fact that the electric utilities in California have already developed inspectionand maintenance programs consistent with General Order 95, Rule 18A was adopted with thefollowing language included:Companies that have existing General Order 165 auditable inspection andmaintenance programs that are consistent with the purpose of Rule 18A shallcontinue to follow their General Order 165 programs. 31 SCE appreciates the PD’s acceptance of the consensus proposals. SCE requests that the PD be modified to includethe consensus Section E to GO 165, “Changes to Requirements Herein,” which was rejected by the PD. No partyobjected to its inclusion. The language is intended to permit parties to request exemptions from particularrequirements in special cases, with permission from the Commission. The procedure is more efficient thanrequiring a full petition or application to request an exemption; and, in every case, an exemption is granted onlyafter consideration by the Commission. SCE notes that a nearly identical section is included in GO 95, Section 15.2 D.09-08-029, at pp. 17-21.3 D.09-08-029, at p. 20.‐2‐

Although the version of Rule 18A adopted in Phase 1 is different from the versionproposed for adoption in Phase 2 PD, the purpose of adding this rule to GO 95 has not changed.In D.09-08-029, the opening paragraph of Section 5.3 reads:We add Rule 18 to General Order 95 to establish an auditable utility maintenanceprogram, provide a framework for notification of safety hazards involvingequipment owned by one company and discovered by another company, andprioritize corrective actions for General Order 95 violations. While CPSD offeredits proposal to incorporate a new Rule 18 to ensure, among other things, adequaterecordkeeping, some parties, including SDG&E, pointed out that certaincompanies already operate under their own comprehensive rules for the purposeof maintenance. These rules relate to the utilities’ existing General Order 165maintenance programs. SDG&E suggested that these companies should bepermitted to continue to rely on their existing rules. To the extent that the purposeof these existing rules is consistent with Rule 18, we agree. 4Thus, the Commission accepted SDG&E’s rationale, stated in Phase 1, that certain electriccompanies already have comprehensive maintenance programs.During the Phase 2 workshops, SDG&E argued that certain communications companies(CIPs) in SDG&E’s service territory were not promptly responding to GO 95 violation notices,and were not correcting those violations following notification within the time period establishedby SDG&E in its own GO 165 maintenance program. 5 Therefore, SDG&E proposed an additionto Rule 18A, which would require companies subject to the rule to remedy Level 2 nonconformanceswithin 12 months if those non-conformances compromise worker safety or createa fire risk in a high fire hazard area in Southern California. The Phase 2 PD adopts thisrecommendation. 6SCE opposed SDG&E’s rule change during the workshops. SCE continues to believe thechange is unnecessary and ambiguous. Regardless, however, the PD goes well beyond what was4 D.09-08-029, at p. 17.5 R.08-11-005, SDG&E Opening Comments to Phase 2 Workshop Report, at pp. 5-9.6 PD at pp. 42-43.‐3‐

discussed in the workshops by adding the following interpretation of the new requirement inrelation to the electric utilities GO 165 programs:Today’s decision retains the current provision in Rule 18A that electric utilitieswhich have established maintenance programs under GO 165 “that are consistentwith the purpose of Rule 18” shall continue to follow their GO 165 programs. [FN36] We interpret this provision to mean that the deadlines for corrective actionsunder GO 165 maintenance programs cannot exceed the deadlines for correctiveactions in Rule 18, as revised by today’s decision. 7Parties did not have an opportunity during the workshops to argue against applying the12-month Level 2 limitation to utilities with existing GO 165 programs. If that interpretation hadbeen clearly at issue, SCE would have requested hearings to present evidence of its own programand the method we use to prioritize and schedule corrective actions to oppose applying thetimelines in Rule 18A to GO 165 compliant utilities. SCE is concerned that the ambiguity in theterms “worker safety” and “fire risk” will create unnecessary differences in interpretation amongthe utilities and CPSD. 8 Ultimately, these terms could be interpreted so broadly as to evisceratethe purpose of Level 2’s flexibility, requiring all Level 2 corrective actions to be performedwithin 12 months. Such a change would have an impact on SCE’s costs to maintain its currentlyGO 165 compliant program with no demonstrated increase in safety or reliability. Thisinterpretation of Rule 18A and Conclusion of Law Number 5 were not vetted with participantsand should be removed from the final version of the PD before its adoption by the Commission.Finally, SCE’s GO 165 inspection and maintenance program is, in fact, consistent withthe “purpose” of Rule 18A because it is auditable and includes a three-level methodology forprioritizing corrective actions. Moreover, SCE’s program, the Distribution Inspection and7 PD at p. 43, and Conclusion of Law No. 5.8 For example, under its current program, SCE permits its inspectors to use their judgment within the confines of theprogram to schedule the date for corrective action differently for similar conditions depending upon the severityof the condition, its potential effect on safety and reliability, and whether the condition is in a rural area or urban,is isolated or near traffic, is in a residential area or commercial, is in a high fire hazard area or not, etc. SCE plansto maintain this practice because this flexibility is efficient and cost effective without compromising safety orreliability; and SCE believes that the ambiguity created by the 12-month carve-out in Level 2 proposed in the PDmay cause interpretation differences between SCE and CPSD.‐4‐

Maintenance Program (DIMP), is the model for Rule 18A, the language of which was takendirectly from the Memorandum of Understanding between CPSD and SCE that resulted from thenegotiations the Commission called for in its decision in SCE’s line maintenance OII. 9 SCE’sprogram has been audited by CPSD and accepted as a valid GO 165 compliant program since theimplementation of DIMP. We strongly urge the Commission to reconsider its proposedinterpretation and reaffirm that existing GO 165 maintenance and inspection programs that areauditable and prioritize corrective actions into three levels are understood to be “consistent withthe purpose of Rule 18A.”B. Section 6.4 – Rule 18C (Fire Prevention Plans)The Phase 2 PD adopts two different requirements for the development of FirePrevention Plans: one for utilities serving Imperial, Los Angeles, Orange, Riverside, SantaBarbara, San Bernardino, San Diego, and Ventura counties; and one for utilities serving all othercounties. 10 Since SCE serves customers in both the listed Southern California counties and insome of the “other” Northern California counties as well, our intent is to submit one fireprevention plan for our entire service territory that will take into account the geography of ourservice territory while maintaining consistency of operations. Therefore, one fire prevention planwill be developed for the entire company that may contain different mitigation measures fordifferent geographic areas.9 See. Joint Party Workshop Report for Workshops Held April 28-29, 2009, filed May 14, 2009 in R.08-11-005, atpp. 48-49 (stating that proposed Rule 18A “is based on the MOU developed between CPSD and SCE. . . . Thepurpose of the MOU was to develop a ‘Common Platform’ for correcting GO 95 violations.”); see also D.09-08-029, at pp. 17-22 (adopting new Rule 18A).10 PD at pp. 46-54.‐5‐

C. Section 6.5 – GO 95, 31.1SCE agrees with the PD’s adoption of the contested proposal to revise GO 95, Rule 31.1to clarify its applicability and define “accepted good practice.” 11 As stated in the PD, “theproposed revisions to Rule 31.1 will improve public safety by clarifying the complianceobligations of electric utilities and CIPs under GO 95.” 12 We agree.D. Section 6.6 – GO 95, 80.1A, Detailed Inspections: Definition of “One-Year”Recommendation: Remove new definition of “year” – defined as 12 consecutivecalendar months – added sua sponte to GO 165.As part of its discussion of new rules for communication company patrol and detailinspections, the PD adds the following statement at pages 71 and 72:To ensure consistent implementation of the adopted inspection intervals, wedefine the term “year” as 12 consecutive calendar months starting the first fullcalendar month after an inspection is performed. For example, if an inspection isperformed in January of 2012 and the required inspection interval is one year, thenext inspection must be completed by the end of January 2013. [FN 68] We willalso add this definition of “year” to GO 165 to ensure consistent interpretation ofinspection intervals for both CIPs and electric utilities.[FN 68] Likewise, if an inspection interval is two or five years, the nextinspection must be completed within 24 or 60 calendar months, respectively.SCE opposes this proposed reinterpretation of “one-year.” This interpretation was notcontemplated during the workshop discussions or the development of new inspectionrequirements for CIP facilities rules, nor was it contemplated during the development orworkshop discussion of revisions to General Order 165. Importantly, the interpretation itself is atodds with the Commission’s previous interpretation of inspection cycles (measured in years)and, if retained, the new definition will compromise both the new and established inspectionprograms for electric and communication facilities alike.11 PD at pp. 57-59.12 PD at p. 58.‐6‐

This new interpretation of the definition of “one-year” in the context of utility inspectionswas not discussed during the workshop process. If SCE had known that such a definition werebeing considered, SCE would have asked for evidentiary hearings to present the facts of ourcurrent inspection programs detailing why flexibility in the interpretation of “year” is importantfor efficiency, cost effectiveness, safety, and reliability. 13The new definition is also at odds with the Commission’s previous determination thatthe term “year” in GO 165 does not mean “12 consecutive calendar months.” In D.04-04-065,after litigation with a complete record, the Commission considered this exact issue, andaddressed “inspection intervals” following CPSD’s allegation that SCE had violated GO 165because more than 12 months had elapsed between inspections. There, the Commission rightlyconcluded –The key language of this GO is that the inspection intervals should be such as to[e]nsure “reliable, high quality and safe operation.” Edison has operated for yearswith an understanding of this GO that permits it some flexibility in scheduling thelowest priority inspections. In a small number of instances, approximately 7% ofinspections, actual inspections may be separated by more than 365 days.However, there is no evidence in the record that such intervals compromise thegoals of system safety and reliability. Barring such a showing and recognizingthat our historic practice has permitted this limited degree of flexibility inscheduling, we are not persuaded that a more restrictive interpretation of GO 165does anything but add cost to the utility’s compliance. 14SCE acknowledges that the typical definition of a yearly interval is the span of 365 days.But applying a 365-day definition to Rule 80.1A and GO 165 exalts form over substance. Just asthe Commissions noted in D.04-04-065, during this proceeding neither CPSD nor any other partyhas claimed or submitted evidence indicating that the current flexibility afforded by the GO 16513 One example of why such flexibility is important is where SCE schedules inspections during summer months forfacilities located in mountain areas typically covered by snow during the winter. Under this new definition, SCEwill have to schedule inspections out 11-months or less to ensure that it doesn’t miss the 12-month window due tounforeseen circumstances. After a couple years of 11-month inspection cycles, the inspections will be pushedback into the winter months, making compliance nearly impossible. There are many other reasons whyinspections might not be efficiently completed within 12 months, including access issues like locked gates,requiring inspections to be rescheduled.‐7‐

inspection intervals has any impact on actual safety or system reliability. SCE, on the other hand,offered uncontroverted evidence to the Commission in I.01-08-029, 15 the proceeding that led toD.04-04-065, that reducing flexibility in performing inspections over the calendar year wouldsubstantially undermine efficiency. Industry expert Allen Clapp testified that some flexibility ininspection intervals is typical in the industry and facilitates efficient workforce scheduling:[I]t is typical in the industry to add a number of months to the calendar“minimum” as SCE has done…If regulators were to insist on a rigid 12-month inspection interval for a certaincategory of facilities, almost all of the actual inspection intervals would have to besignificantly less then 12 months in order to ensure that in no case did anyinspection fall outside the 12-month period. The cost impact of such an approachwould be very significant while the safety and reliability enhancement would beminimal. 16SCE urges the Commission to continue to exercise its discretion to permit flexibility inthe interest of efficiency and interpret the term “yearly” for the purposes of Rules 31.2, 80.1A,and GO 165 to mean a calendar year rather than a 365-day interval. 17E. Section 6.8 – GO 95, Rule 35, Paragraph 4SCE agrees with the PD’s adoption of a revised version of the proposal for newparagraph 4 in Rule 35 permitting utilities to disconnect power to landowners who obstructvegetation management activities. 18 SCE will file the Tier 3 advice letter mentioned in the PD tomodify its tariffs within 60 days in accordance with the decision.Continued from the previous page14 D.04-04-065, at pp. 28-29 (emphasis added).15 Order Instituting Investigation Into Southern California Edison Company’s Electric Line Construction, Operation,and Maintenance Practices.16 I.01-08-029: SCE/Clapp, Ex. 214 at 19:3-4 and 9-14.17 The calendar year approach to inspections is also consistent with SCE’s CAISO approved transmission inspectionand maintenance program.18 PD at pp. 82-89.‐8‐

F. Section 6.9 – GO 95, Rule 35, Third ExemptionSCE disagrees with the PD’s failure to adopt Exemption Three to Rule 35 of GO 95. Weunderstand that the proposal was interpreted as a “limitation of liability” and therefore outsidethe scope of Phase 2. SCE fundamentally disagrees with the notion that any proposal that mighthave the ancillary effect of limiting utility liability must be discarded. The ratepayers, theCommission, DRA, CPSD, and the utilities should all be in favor of limiting utility liability insituations such as this where the resulting liability is no fault of the utility’s (blocked access toperform vegetation management). Where a utility is forced to pay claims caused by others’negligence, costs increase for ratepayers. SCE urges the Commission to consider remedies toproblems like this that increase costs without any safety or reliability benefit.G. Section 6.10 – GO 95, Appendix E (Radial Clearance Table)SCE disagrees with the PD’s failure to adopt the proposed increase to the vegetationclearance guidelines at time of trim found in Appendix E to Rule 35 for the reasons stated inSCE’s briefs following the Phase 2 workshop report. Nonetheless, SCE appreciates the PD’sinterpretation of the guidelines as providing “wide latitude . . . to exceed the minimum time-oftrimclearances.” 19 SCE will take this interpretation into consideration when implementing itsvegetation management program.statement that:H. Section 6.12 – GO 95, Rule 38, Table 2, Footnote (aaa)(Conductor Clearance)Although the PD does not adopt the Joint Utility proposal, SCE appreciates the PD’s. . . electric utilities and CIPs . . . are required by GO 95 to take sag characteristicsinto account when installing new conductors to ensure that the minimumclearance requirements between conductors that in Table 2 of Rule 38 are19 PD at p. 95.‐9‐

maintained at all times. We view any failure to maintain minimum conductor-toconductorclearances as a serious fire hazard. Any failure to maintain the requiredminimum clearances shall be deemed either a Level 1 of Level 2nonconformance, depending on circumstances, and must be corrected within thetimeframes specified in Rule 18 (as revised by today’s decision). 20SCE takes seriously encroachments upon its lines by conductors installed by othercompanies. SCE will notify companies pursuant to Rule 18B who install facilities that fail tomeet the conductor-to-conductor clearance requirements and create a safety hazard. Pursuant tothe language in the PD, SCE will expect the infringing company to remedy the non-conformingcondition within the timeframes required by the company’s inspection and maintenance programand applicable regulations.I. Section 6.13 – GO 95, Rule 44.2 (Additional Construction)Recommendation: Delete the new note added sua sponte to Rule 44.2 defining“a material increase” sufficient to require a pole load calculation and reaffirmOrdering Paragraph 4 of the Phase 1 Decision (D.09-08-029).SCE supports the consensus revisions to Rule 44.2 as presented in the Workshop Report 21and as further described in the Proposed Decision. 22 However, SCE is concerned with the PD’sdeletion of the consensus note adopted in the Phase 1 decision and the addition of a new note, thecontent of which was never vetted during the workshops in this proceeding. 23 This new note toRule 44.2 is a modified version of Ordering Paragraph (4) from D.09-08-029: 24Ordering Paragraph 4: For purposes of pole loading and Rule 44.2 of GeneralOrder 95, additional facilities that “materially increase the load on a structure”refers to an addition which increases the load on a pole by more than five percentper installation, or 10 percent over a 12 month span of the utility’s orCommunication Infrastructure Provider’s current load.20 PD at p. 103.21 PHASE 2 JOINT PARTIES’ WORKSHOP REPORT FOR WORKSHOPS HELD JANUARY – JUNE 2010, Appx. A, at p. 27.22 PD at p. 24.23 PD at p. 109.24 D.09-08-029, at p. 38.‐10‐

The proposed new note reads -Note: For the purpose of Rule 44.2, a material increase in load is when a proposedaddition to a structure could exceed 10 percent of the estimated remaining unusedload, or carrying capacity, of the structure (with the remaining unused load, orcarrying capacity, computed using the minimum end-of-service-life safety factorsfor the structure required by Rule 44). 25The decision to add this new note to Rule 44.2 is apparently based on the fact that noneof the parties – not the Joint Utilities, the CIPs, nor CPSD – offered rule change proposals toaddress the intent of Ordering Paragraph 4. Although it is true that no proposals made it into theworkshop report, this important matter was discussed during the workshops and the Rule 44Workgroup (chaired by CPSD). In fact, this subject proved too difficult to be resolved during theworkshops, and although the workgroup members exchanged several drafts, it was not possibleto develop a proposal sufficiently robust to put before the Commission.The proposed new note to Rule 44.2 is unworkable. First, it assumes incorrectly thatevery company has access to every other company’s loading information for all the facilities on apole so that the attaching entity can estimate “the remaining unused load or carrying capacity.”Second, the only means of determining whether a proposed addition exceeds the allowable 10%limit is to perform a pole load calculation, which defeats the purpose of the 10% exemption.SCE respectfully recommends the Commission reaffirm the applicability of the Phase 1Ordering Paragraph 4 until such time as the Commission is able to consider further revisions toRule 44.2 in Phase 3 of this proceeding or in a future rulemaking. Finally, SCE respectfullysuggests that the Commission ask the GO 95/128 Rules Committee to consider this issue alongwith the future review of GO 95, Section IV recommended in the PD. 26J. Section 6.14 – GO 95 Rule 48 (Ultimate Strength of Materials)SCE appreciates the PD’s discussion of the proper interpretation of Rule 48, specifically:25 PD at p. 109.‐11‐

Rule 48 should not be interpreted as establishing an absolute requirement thatstructures “will not fail” when subjected to loads that exceed the maximumworking loads but less than the applicable safety factors”; and further – “As aresult, the failure of a structure that is subjected to loads that exceed the maximumworking loads for the structure must be evaluated in light of the conditions at thetime of the failure and the innate variability in the strengths of the materials thatwere used to build the structure, particularly wood products. 27However, SCE believes that the PD’s should not endorse the language in Rule 48 thatstates that anticipated maximum working loads are to be “multiplied by the safety factors in Rule44.” Such an interpretation is contrary to the Appendix “F” example of calculating transverseloading for a wood poles in Part 1, Example 11. In addition, the PD’s statement that “Structuresshould never fail at loads equal to, or less than maximum working loads” is incorrect.Particularly given the natural variability in the strength of wood products, which the PDrecognizes, it is possible (although not likely) that a wood pole can be designed in accordancewith GO 95 and yet fail at less than its maximum working load. SCE respectfully suggests thatthis interpretation be removed from the PD pending the review of GO 95 Section IV by CPSDand the GO 95/128 Rules Committee mentioned in this section of the PD.K. Section 6.16 – Data CollectionSCE supports and will fully participate in Phase 3 with CPSD as directed by the PD toassist in development of a data collection plan that is workable, useful, and cost effective.L. Section 6.17 – Fire Threat MapsSCE supports and will fully participate in Phase 3 to develop a set of fire threat maps forthe state of California. We need one set of maps that can be used consistently throughout thestate to identify high and very high fire threat areas. We envision that the maps, once developed,would be updated as frequently as appropriate to remain current.Continued from the previous page26 PD at 115.27 PD at 114.‐12‐

M. Section 6.20 – Cost RecoverySCE has included the forecast of Phase 1 mitigation measures in its 2012 GRC. As theimpacts of the Phase 2 decision become better understood, we intend to include thoseincremental forecast costs in our 2015 GRC, and plan to close the FHPMA following a decisionin that proceeding. In accordance with the PD, SCE will seek recovery for the costs recorded inthe FHPMA in future applications.III.CONCLUSIONSCE appreciates the parties’, the ALJ’s, the facilitators’, Assigned CommissionerSimon’s, CPSD’s, and the Commission’s commitment to this proceeding. SCE requests that theCommission adopt the changes to the Proposed Decision suggested herein.Respectfully submitted,JAMES M. LEHRERROBERT F. LeMOINE/s/ ROBERT F. LeMOINEBy: Robert F. LeMoineAttorneys forSOUTHERN CALIFORNIA EDISON COMPANY2244 Walnut Grove AvenuePost Office Box 800Rosemead, California 91770Telephone: (626) 302-4182Facsimile: (626) 302-6693E-mail: Robert.F.LeMoine@sce.comJune 30, 2011‐13‐

Appendix of Recommended Changes to Findings of Fact and Conclusions of Law1. Revise pages 28 and 29 of the PD as follows:Our one reservation with the consensus revisions to GO 165 is the followingprovision that would add a new mechanism for seeking future exemptions from, ormodifications to, GO 165:If, in a particular case, exemption from or modification of any of therequirements herein is desired, the Commission will consider a request forsuch exemption or modification when accompanied by a full statement ofconditions existing and the reasons why such exemption or modification isasked and is believed to be justifiable. It is to be understood that, unlessotherwise ordered, any exemption or modification so granted shall belimited to the particular case covered by the request.The above provision is vague because it does not (1) state who may ask for anexemption or modification, or (2) specify a procedure for seeking an exemption ormodification. The provision is also unnecessary because the Commission already hasprocedures to request an exemption or modification, including applications, petitions formodification of Commission decisions, and petitions for new rulemaking proceedings.We therefore see no value or need for the above provision, and we decline to adopt it.Revise text of GO 165 in Appendix B of the PD (page B-22) to include thefollowing Section E under Heading III:E. Changes to Requirements HereinIf, in a particular case, exemption from or modification of any of therequirements herein is desired, the Commission will consider a request forsuch exemption or modification when accompanied by a full statement ofconditions existing and the reasons why such exemption or modification isasked and is believed to be justifiable. It is to be understood that, unlessotherwise ordered, any exemption or modification so granted shall belimited to the particular case covered by the request.2. Revise page 43 of the PD as follows:Today’s decision retains the current provision in Rule 18A that electric utilitieswhich have established maintenance programs under GO 165 “that are consistent with theA‐1

purpose of Rule 18” shall continue to follow their GO 165 programs. [FN.36: D.09-08-029 at 20] We interpret this provision to mean that the deadlines for corrective actionsunder GO 165 maintenance programs cannot exceed the deadlines for corrective actionsin Rule 18, as revised by today’s decision.Revise Conclusion of Law No. 5 as follows:Companies that have existing General Order 165 auditable inspection andmaintenance programs that are consistent with the purpose of Rule 18A shall continue tofollow their General Order 165 programs. The deadlines for completing correctiveactions under the inspection and maintenance programs established by electric utilitiespursuant to GO 165 may not exceed the deadlines for completing corrective actionsspecified in Rule 18A of GO 95, as modified by today’s decision.3. Revise pages 71 and 72 and footnote 68 of the PD as follows:To ensure consistent implementation of the adopted inspection intervals, wedefine the term “year” as 12 consecutive calendar months starting the first full calendarmonth after an inspection is performed. For example, if an inspection is performed inJanuary of 2012 and the required inspection interval is one year, the next inspection mustbe completed by the end of January 2013. [FN 68] We will also add this definition of“year” to GO 165 to ensure consistent interpretation of inspection intervals for both CIPsand electric utilities.Footnote 68: Likewise, if an inspection interval is two or five years, thenext inspection must be completed within 24 or 60 calendar months,respectively.Revise Conclusion of Law No. 12 as follows, and renumber remainingConclusions of Law:For the purpose of implementing the inspection intervals for CIP facilitiesin GO 95, Rule 80.1, and for electric utility facilities in GO 165, the term“year” should be defined as 12 consecutive calendar months starting thefirst full calendar month after an inspection is performed.Revise text of GO 165 in Appendix B of the PD (page B-24) as follows:A‐2

Note: For the purpose of implementing the inspection intervals in Table 1above, the term “year” is defined as 12 consecutive calendar monthsstarting the first full calendar month after an inspection is performed.4. Revise page 109 of the PD as follows:As a final matter, we note that the Phase 1 Decision indicated the Commissionwould revisit in Phase 2 the following provision in Ordering Paragraph 4 of D.09-08-029regarding what constitutes a “material increase” in load on a structure:Ordering Paragraph 4: For purposes of pole loading and Rule 44.2 ofGeneral Order 95, additional facilities that “materially increase the load ona structure” refers to an addition which increases the load on a pole bymore than five percent per installation, or 10 percent over a 12 month spanof the utility’s or Communication Infrastructure Provider’s current load.(D.09-08-029 at 38. Emphasis added)Surprisingly, nNeither the CIP Coalition’s proposal nor the Joint Utilities’proposal addresses the issue of what constitutes a material increase in the load on astructure, which triggers the need for a pole-loading calculation. We conclude that inorder to protect public safety, a pole-loading calculation should be required whenever aproposed attachment would exceed 10% of the estimated remaining unused load, orcarrying capacity, of a structure (computed using the minimum end-of-service-life safetyfactors for the structure required by Rule 44). Our determination of what constitutes amaterial increase in the load on a structure is included in the adopted text of Rule 44.2that is contained in Appendix B of today’s decision. reaffirm and adopt OrderingParagraph 4 from the Phase 1 Decision, D.09-08-029. In accordance with our instructionto CPSD in Section 6.14 below, we encourage CPSD to work with the GO 95/128 RulesCommittee to develop a technically appropriate definition for what constitutes a “materialincrease” on the load of a structure in Rule 44.2 of GO 95.Revise text of Rule 44.2 in Appendix B (page B-13) of the PD as follows:Note: For the purpose of Rule 44.2, a material increase in load is when aproposed addition to a structure could exceed 10 percent of the estimatedremaining unused load, or carrying capacity, of the structure (with theremaining unused load, or carrying capacity, computed using theA‐3

minimum end-of-service-life safety factors for the structure required byRule 44).5. Revise pages 113 and 114 of the PD as follows:On the other hand, the Joint Utilities’ proposal does implicate an issue that iswithin the scope of this proceeding, namely, the proper interpretation of the “will notfail” provision in Rule 48. [FN 90] We conclude that the purpose of Rule 48 is to ensurethat structures “will not fail” when subjected to “maximum working loads.91” Therequirement to build structures to bear maximum working loads is a core safetyrequirement. Structures should never fail at loads equal to, or less than, maximumworking loads. Rule 48 accomplishes this objective by requiring companies to buildstructures that are designed to bear the anticipated maximum working loads multiplied bythe safety factors in Rule 44. The intended result is structures that are typically muchstronger than needed for the maximum working loads.Revise Conclusion of Law Number 16 as follows, and renumber remainingConclusions of Law:Rule 48 of GO 95 requires CIPs and electric utilities to build structures that willnot fail when subjected to loads that are equal to, or less than, the “maximum workingstresses” defined by Rule 44.A‐4

CERTIFICATE OF SERVICEI hereby certify that, pursuant to the Commission’s Rules of Practice andProcedure, I have this day served a true copy of OPENING COMMENTS OFSOUTHERN CALIFORNIA EDISON COMPANY (U 338-E) TO THEPROPOSED DECISION IN PHASE 2 – REGULATIONS TO REDUCE FIREHAZARDS ASSOCIATED WITH OVERHEAD POWER LINES ANDCOMMUNICATION FACILITIES on all parties identified on the attached servicelist(s). Service was effected by one or more means indicated below:Transmitting the copies via e‐mail to all parties who have providedan e‐mail address. First class mail will be used if electronic servicecannot be effectuated.Executed this 30th day of June, 2011, at Rosemead, California./s/ Melissa Ann Schary HernandezMELISSA ANN SCHARY HERNANDEZProject AnalystSOUTHERN CALIFORNIA EDISON COMPANY2244 Walnut Grove AvenuePost Office Box 800Rosemead, California 91770

CPUC - Service Lists - R0811005http://docs.cpuc.ca.gov/published/service_lists/R0811005_77981.htmPage 1 of 106/30/2011CPUC HomeCALIFORNIA PUBLIC UTILITIES COMMISSIONService ListsPROCEEDING: R0811005 - CPUC - OIR TO REVISEFILER: CPUCLIST NAME: LISTLAST CHANGED: JUNE 29, 2011DOWNLOAD THE COMMA-DELIMITED FILEABOUT COMMA-DELIMITED FILESBack to Service Lists IndexPartiesLEON M. BLOOMFIELDNELSON G. BINGLE, IIIWILSON & BLOOMFIELD, LLPOSMOSE UTILITIES SERVICES, INC.EMAIL ONLY215 GREENCASTLE ROADEMAIL ONLY, CA 00000 TYRONE, GA 30290FOR: T-MOBILEFOR: OSMOSE UTILITIES SERVICES, INC.MATTHEW YATESCHRISTOPHER A. HILENLEGAL COUNSELSIERRA PACIFIC POWER COMPANYWECC6100 NEIL ROAD155 N 400 W, STE. 200 RENO, NV 89520SALT LAKE CITY, UT 84100-1114FOR: SIERRA PACIFIC POWER COMPANYFOR: WESTERN ELECTRICITY COORDINATINGCOUNCIL (WECC)J. SCOTT KUHN OSCAR A. ALVAREZCOUNTY OF LOS ANGELESLOS ANGELES DEPT. OF WATER AND POWERKENNETH HAHN HALL OF ADMINISTRATION 111 N. HOPE STREET, ROOM 1246500 W. TEMPLE STREET, RM 648 LOS ANGELES, CA 90012LOS ANGELES, CA 90012FOR: L.A. DEPARTMENT OF WATER AND POWERFOR: LOS ANGELES COUNTYSHANISE BLACKSTEVEN M. MEYERLOS ANGELES DEPT. OF WATER AND POWER PSC TECHNOLOGY INCORPORATED111 NORTH HOPE STREET, ROOM 340 21839 SADDLE PEAK RDLOS ANGELES, CA 90012 TOPANGA, CA 90290FOR: CITY OF LOS ANGELES, DEPT OF WATER FOR: PSC TECHNOLOY INCORPORATEDAND POWERJESUS G. ROMANROBERT F. LEMOINEVERIZON CALIFORNIA, INC.SOUTHERN CALIFORNIA EDISON2535 W HILLCREST DR., MC CAM21LB 2244 WALNUT GROVE AVE.

CPUC - Service Lists - R0811005http://docs.cpuc.ca.gov/published/service_lists/R0811005_77981.htmPage 2 of 106/30/2011NEWBURY PARK, CA 91320 ROSEMEAD, CA 91770FOR: VERIZON CALIFORNIAFOR: SOUTHERN CALIFORNIA EDISONDIANE CONKLINKEITH MELVILLEMUSSEY GRADE ROAD ALLIANCESAN DIEGO GAS & ELECTRIC COMPANYPO BOX 683101 ASH STREET, HQ 13DRAMONA, CA 92065 SAN DIEGO, CA 92101FOR: MUSSEY GRADE ROAD ALLIANCEFOR: SAN DIEGO GAS & ELECTRIC COMPANYMICHAEL BAGLEYJON DOHMVERIZON WIRELESSCROWN CASTLE USA, WEST AREA15505 SAND CANYON AVENUE 510 CASTILLO STREET, SUITE 303IRVINE, CA 92612 SANTA BARBARA, CA 93101FOR: VERIZON WIRELESSFOR: CALWAJAMES E. BRITSCHCLEVELAND LEEFACILITIES MANAGEMENT SPECIALISTS LLC CALIF PUBLIC UTILITIES COMMISSION1231 CRESTLINE DRIVE LEGAL DIVISIONSANTA BARBARA, CA 93105 ROOM 5122FOR: FACILITIES MANAGEMENT SPECIALISTS, 505 VAN NESS AVENUELLC. SAN FRANCISCO, CA 94102-3214FOR: DRAKIMBERLY LIPPININA SUETAKECALIF PUBLIC UTILITIES COMMISSIONTHE UTILITY REFORM NETWORKLEGAL DIVISION 115 SANSOME STREET, SUITE 900ROOM 5001 SAN FRANCISCO, CA 94104505 VAN NESS AVENUE FOR: THE UTILITY REFROM NETWORKSAN FRANCISCO, CA 94102-3214FOR: CPSDROBERT FINKELSTEINKRISTIN L. JACOBSONTHE UTILITY REFORM NETWORKSPRINT NEXTEL115 SANSOME STREET, SUITE 900 201 MISSION STREET, SUITE 1500SAN FRANCISCO, CA 94104 SAN FRANCISCO, CA 94105FOR: TURNFOR: SPRINT NEXTELLISE H. JORDAN, ESQ.NELSONYA CAUSBYPACIFIC GAS AND ELECTRIC COMPANYAT&T CALIFORNIA77 BEALE STREET, B30A. RM 3151 525 MARKET ST., STE 2025SAN FRANCISCO, CA 94105 SAN FRANCISCO, CA 94105FOR: PG & EFOR: AT&T CALIFORNIA AND NEW CINGULARWIRELESS PCS, LLCPETER A. CASCIATOJEANNE B. ARMSTRONGA PROFESSIONAL CORPORATIONGOODIN MACBRIDE SQUERI DAY & LAMPREY LLP355 BRYANT STREET, SUITE 410 505 SANSOME STREET, SUITE 900SAN FRANCISCO, CA 94107 SAN FRANCISCO, CA 94111FOR: COMCAST PHONE OF CALIFORNIA/TW FOR: CTIA-THE WIRELESS ASSOCIATIONTELECOM OF CALIFORNIA, LLC/TIME WARNERCABLEMARLO A. GOPATRICK M. ROSVALLGOODIN MACBRIDE SQUERI DAY & LAMPREY LLP COOPER, WHITE & COOPER LLP505 SANSOME STREET, SUITE 900 201 CALIFORNIA STREET, 17TH FLOORSAN FRANCISCO, CA 94111 SAN FRANCISCO, CA 94111FOR: PACIFICORPFOR: SMALL LECS, SUREWEST TELEPHONESARAH DEYOUNGVIDHYA PRABHAKARANEXECUTIVE DIRECTORDAVIS WRIGHT & TREMAINE LLPCALTEL 505 MONTGOMERY STREET, SUITE 80050 CALIFORNIA STREET, SUITE 500 SAN FRANCISCO, CA 94111SAN FRANCISCO, CA 94111FOR: CALIFORNIA PACIFIC ELECTRICFOR: CALTELCOMPANY, LLC

CPUC - Service Lists - R0811005http://docs.cpuc.ca.gov/published/service_lists/R0811005_77981.htmPage 3 of 106/30/2011EDWARD O'NEILLJANE WHANGDAVIS WRIGHT TREMAINE LLPDAVIS WRIGHT TREMAINE LLP505 MONTGOMERY STREET, SUITE 800 505 MONTGOMERY STREET, SUITE 800SAN FRANCISCO, CA 94111-6533 SAN FRANCISCO, CA 94111-6533FOR: COXCOM, INC./COX CALIFORNIA TELCOM FOR: NEXTG NETWORKS OF CALIFORNIA, INC.LLCJEFFREY P. GRAYSUZANNE TOLLERDAVIS WRIGHT TREMAINE, LLPDAVIS WRIGHT TREMAINE505 MONTGOMERY STREET, SUITE 800 505 MONTGOMERY STREET, SUITE 800SAN FRANCISCO, CA 94111-6533 SAN FRANCISCO, CA 94111-6533FOR: CALIFORNIA INDEPENDENT SYSTEM FOR: SUNESYS, LLCOPERATORLARRY ABERNATHYJOHN GUTIERREZDAVEY TREE SURGERY COMPANYDRECTOR, GOVERNMENT AFFAIRSPO BOX 5015COMCASTLIVERMORE, CA 945513055 COMCAST PLACEFOR: DAVEY TREE SURGERY COMPANY LIVERMORE, CA 94551-9559FOR: COMCAST CABLE COMMUNICATIONS, INC.ANITA TAFF-RICEWILLIAM P. ADAMSEXTENET SYSTEMS, LLCADAMS ELECTRICAL SAFETY CONSULTING1547 PALOS VERDES MALL, NO. 298 716 BRETT AVENUEWALNUT CREEK, CA 94597 ROHNERT PARK, CA 94928-4012FOR: EXTENET SYSTEMS (CALIFORNIA) LLC FOR: ADAMS ELECTRICAL SAFETY CONSULTINGKEVIN COLLINSBARRY F. MCCARTHYLOMPICO WATERSHED CONSERVANCYATTORNEYPO BOX 99MCCARTHY & BERLIN, LLPFELTON, CA 95018 100 W. SAN FERNANDO ST., SUITE 501FOR: LOMPICO WATERSHED CONSERVANCY SAN JOSE, CA 95113FOR: NORTHERN CALIFORNIA POWER AGENCYROBERT L. DELSMANCASEY HASHIMOTONEXTG NETWORKS OF CALIFORNIA, INCTURLOCK IRRIGATION DISTRICT2216 OTOOLE AVENUE 333 CANAL DRIVESAN JOSE, CA 95131 TURLOCK, CA 95380FOR: NEXTG NETWORKS OF CALIFORNIA, INC. FOR: TURLOCK IRRIGATION DISTRICTSTEPHEN R. CIESLEWICZJUDITH SANDERSCN UTILITY CONSULTING, INCCALIFORNIA ISO120 PLEASANT HILL AVE. NORTH, STE.190 151 BLUE RAVINE ROADSEBASTOPOL, CA 95472 FOLSOM, CA 95630FOR: CN UTILITY CONSULTING, INCFOR: CALIFORNIA INDEPENT SYSTEMOPERATOR CORPORATIONLANDIS MARTTILACHARLIE BORNIBEW 1245FRONTIER COMMUNICATIONS30 ORANGE TREE CIRCLE PO BOX 340VACAVILLE, CA 95687 ELK GROVE, CA 95759FOR: INTERNATIONAL BROTHERHOOD OFFOR: FRONTIER COMMUNICATIONSELECTRICAL WORKERS LOCAL UNION 1245BRUCE MCLAUGHLINJUSTIN C. WYNNEBRAUN & BLAISING MCLAUGHLIN, P.C.ATTORNEY AT LAW915 L STREET, SUITE 1270 BRAUN BLAISING MCLAUGHLIN, P.C.SACRAMENTO, CA 95814 915 L STREET, SUITE 1270FOR: CALIFORNIA MUNICIPAL UTILITIES SACRAMENTO, CA 95814ASSOCIATIONSFOR: CALIFORNIA MUNICIPAL UTILITIESASSOCIATIONJEROME F. CANDELARIAJEDEDIAH J. GIBSONCALIFORNIA CABLE TV ASSOCIATIONATTORNEY1001 K STREET, 2ND FLOOR ELLISON, SCHNEIDER & HARRIS LLPSACRAMENTO, CA 95814-3832 2600 CAPITOL AVENUE, SUITE 400

CPUC - Service Lists - R0811005http://docs.cpuc.ca.gov/published/service_lists/R0811005_77981.htmPage 4 of 106/30/2011FOR: CCTA - CALIFORNIA CABLE & SACRAMENTO, CA 95816-5905TELECOMMUNICATIONS ASSOCIATIONFOR: SIERRA PACIFIC POWERKAREN NORENE MILLSATTORNEY AT LAWCALIFORNIA FARM BUREAU FEDERATION2300 RIVER PLAZA DRIVESACRAMENTO, CA 95833FOR: CALIFORNIA FARM BUREAU FEDERATIONInformation OnlyDONALD C. LIDDELLJEREMY SADLERDOUGLASS & LIDDELLEMAIL ONLYEMAIL ONLY EMAIL ONLY, CA 00000EMAIL ONLY, CA 00000JOSEPH W. MITCHELL, PH. D.PHYLLIS A. WHITTENM-BAR TECHNOLOGIES AND CONSULTING, LLC FRONTIER COMMUNICATIONSEMAIL ONLYEMAIL ONLYEMAIL ONLY, CA 00000 EMAIL ONLY, CA 00000TARYN CIARDELLAMRW & ASSOCIATES, LLCSR. LEGAL SECRETARYEMAIL ONLYNV ENERGY EMAIL ONLY, CA 00000EMAIL ONLYEMAIL ONLY, NV 00000BOB RITTERNICK LIMBEROPOULOSCROWN CASTLE USA, INC.CROWN CASTLE2000 CORPORATE DRIVE 2000 CORPORATE DRIVECANONSBURG, PA 15317 CANONSBURG, PA 15317MIKE RODENMATT PAWLOWSKIEXECUTIVE DIR-REGULATORYNEXTERA ENERGY RESOURCESCINGULAR WIRELESS SERVICES, LLCRELIABILITY & COMPLIANCE GROUP1057 LENOX PARK BLVD RM - 1C138 700 UNIVERSE BLVD.ATLANTA, GA 30319 JUNO BEACH, FL 33408-2683MARJORIE HERLTHJORDAN A. WHITEREGIONAL DIRECTOR, PUBLIC POLICYSR. ATTORNEYQWEST COMMUNICATIONS CORPORATIONPACIFICORP1801 CALIFORNIA ST., 10TH FL. 1407 W. NORTH TEMPLE, SUITE 320DENVER, CO 80202 SALT LAKE CITY, UT 84116JAMES COLELINDA C. STINAROSMOSE UTILITIES SERVICES, INC.QWEST COMMUNICATIONS COMPANY, LLC4862 S PURPLE SAGE DRIVE 6700 VIA AUSTI PARKWAYCHANDLER, AZ 85248 LAS VEGAS, NV 89119LARI SHEEHANDARYL A. BUCKLEYCOUNTY OF LOS ANGELESELECTRICAL SERVICE MANAGER500 W. TEMPLE STREET, ROOM 723 LOS ANGELES DEPT OF WATER AND POWERLOS ANGELES, CA 90012 111 N. HOPE STREET, ROOM 856LOS ANGELES, CA 90012-2694STANTON J. SNYDER, ESQ.MICHAEL R. THORPDEPUTY CITY ATTORNEY, LEGAL DIV.SEMPRA ENERGYDEPARTMENT OF WATER & POWER555 W. 5TH STREET111 N. HOPE STREET, ROOM 340 LOS ANGELES, CA 90013-1011LOS ANGELES, CA 90012-2694

CPUC - Service Lists - R0811005http://docs.cpuc.ca.gov/published/service_lists/R0811005_77981.htmPage 5 of 106/30/2011JOHN R. TODDCRAIG HUNTERPREVENTION SERVICES BUREAUATTORNEY AT LAWCOUNTY OF LOS ANGELES FIRE DEPARTMENT WILSON ELSER MOSKOWITZ EDELMAN & DICKER1320 N. EASTERN AVENUE 555 S. FLOWER STREET, SUITE 2900LOS ANGLELES, CA 90063-3294 LOS ANGELES, CA 90071-2407JACQUE LOPEZLORRAINE A. KOCENVERIZON CALIFORNIA INC.SENIOR STAFF CONSULTANT2535 W. HILLCREST DR., MC CAM21LB VERIZON CALIFORNIA INC.NEWBURY PARK, CA 91320112 S. LAKEVIEW CANYON ROAD, MC 501LSTHOUSAND OAKS, CA 91362STEVE FORDCASE ADMINISTRATIONMANAGER, CONSTRUCTION METHODSAMBER WYATTCHINO OFFICE BUILDINGSOUTHERN CALIFORNIA EDISON COMPANY14005 S. BENSON AVE., 2244 WALNUT GROVE AVE. / PO BOX 800CHINO, CA 91710-7026 ROSEMEAD, CA 91770FOR: CONSTRUCTION METHODSJAMES LEHRERNGUYEN QUANSOUTHERN CALIFORNIA EDISONBEAR VALLEY ELECTRIC SERVICELAW DEPARTMENT630 EAST FOOTHILL BLVD.2244 WALNUT GROVE AVENUE SAN DIMAS, CA 91773ROSEMEAD, CA 91770STEVE M. DUNNSHAWN CAINEDEPARTMENT OF PUBLIC WORKSLAW OFFICE OF SHAWN CAINECOUNTY OF LOS ANGELES1221 CAMINO DEL MARPO BOX 1460 DEL MAR, CA 92014-2505ALHAMBRA, CA 91802-1460DAVE DOWNEYALLEN K. TRIALNORTH COUNTY TIMESATTORNEY207 E. PENNSYLVANIA AVENUE SAN DIEGO GAS & ELECTRIC COMPANYESCONDIDO, CA 92025101 ASH STREET, HQ-12BSAN DIEGO, CA 92101ESTHER NORTHRUPLAURA M. EARLCOX COMMUNICATIONSSAN DIEGO GAS & ELECTRIC COMPANY350 10TH AVENUE, SUITE 600 101 ASH STREET, HQ-12SAN DIEGO, CA 92101 SAN DIEGO, CA 92101LISA URICKJOHN A. PACHECOSAN DIEGO GAS & ELECTRIC COMPANYSEMPRA ENERGY101 ASH STREET, HQ-12B 101 ASH STREET, HQ-12SAN DIEGO, CA 92101 SAN DIEGO, CA 92101-3017STEVE CHRISTIANSONREBECCA BLAINTOSDAL SMITH STEINER & WAXTHORSNES, BARTOLOTTA & MCGUIRE401 WEST A STREET, SUITE 320 2550 FIFTH AVENUE, 11TH FLOORSAN DIEGO, CA 92101-7911 SAN DIEGO, CA 92103DAVID DOHRENGREGORY L. WALTERSSAN DIEGO GAS & ELECTRIC COMPANYSAN DIEGO GAS & ELECTRIC COMPANY8316 CENTURY PARK COURT, CP51D 8316 CENTURY PARK COURTSAN DIEGO, CA 92123 SAN DIEGO, CA 92123REBECCA GILESTHE LAW OFFICES OF ALEXANDER M. SCHACKSDG&E AND SOCALGAS 16870 WEST BERNARDO DRIVE, SUITE 4008330 CENTURY PARK COURT - CP32D SAN DIEGO, CA 92127SAN DIEGO, CA 92123BILL D. CARNAHANMITCHELL S. WAGNER

CPUC - Service Lists - R0811005http://docs.cpuc.ca.gov/published/service_lists/R0811005_77981.htmPage 6 of 106/30/2011EXECUTIVE DIRECTOR24641 WASHINGTON AVEDIRECTOR, PUBLIC UTILITIES DEPARTMENT MURRIETA, CA 925623900 MAIN STREETRIVERSIDE, CA 92522-0600LINDA BURTONWILLIAM A.G. WILDESIERRA TELEPHONE COMPANY, INC.PRESIDENTPO BOX 219CREATIVE INTERCONNECT COM. LLCOAKHURST, CA 93644-0219 555 0LD COUNTY RD., SUITE 100SAN CARLOS, CA 94070WILLIAM K. SANDERSJAMES HENDRYDEPUTY CITY ATTORNEYUTILITIES SPECIALISTCITY AND COUNTY OF SAN FRANCISCOSAN FRANCISCO PUBLIC UTILITIES COMM.1 DR. CARLTON B. GOODLETT PLACE, RM. 234 1155 MARKET STREET, FOURTH FLOORSAN FRANCISCO, CA 94102-4682 SAN FRANCISCO, CA 94103MARCEL HAWIGERMARISA MITCHELLENERGY ATTYENVIRONMENTAL SCIENTISTTHE UTILITY REFORM NETWORKASPEN ENVIRONMENTAL GROUP115 SANSOME STREET, SUITE 900 235 MONTGOMERY STREET, SUITE 935SAN FRANCISCO, CA 94104 SAN FRANCISCO, CA 94104REGINA COSTASTEPHEN P. BOWENTHE UTILITY REFORM NETWORKATTORNEY AT LAW115 SANSOME STREET, SUITE 900 BOWEN LAW GROUPSAN FRANCISCO, CA 94104 235 MONTGOMERY STREET, SUITE 742SAN FRANCISCO, CA 94104BARBARA H. CLEMENTERROL KISSINGERPACIFIC GAS AND ELECTRIC COMPANYPACIFIC GAS AND ELECTRIC COMPANY77 BEALE STREET, B30A 77 BEALE STREET; MC B10ASAN FRANCISCO, CA 94105 SAN FRANCISCO, CA 94105FASSIL FENIKILEGWEN JOHNSONDIRECTOR-REGULATORYAT&T CALIFORNIAAT&T CALIFORNIA 525 MARKET STREET, STE 1927525 MARKET STREET, ROOM 1925 SAN FRANCISCO, CA 94105SAN FRANCISCO, CA 94105KEITH KROMMARGARET M. DILLONGENERAL ATTORNEYASSOCIATE DIRECTORAT&T CALIFORNIAPACIFIC BELL TELEPHONE COMPANY525 MARKET STREET, SUITE 1904 525 MARKET STREET, 18TH FL., NO. 15SAN FRANCISCO, CA 94105 SAN FRANCISCO, CA 94105MICHELLE K. CHOOPAT GEOFFREYAT&T CALIFORNIAPACIFIC GAS AND ELECTRIC COMPANY525 MARKET STREET, 20TH FLOOR, NO.2 245 MARKET STREET, N9FSAN FRANCISCO, CA 94105 SAN FRANCISCO, CA 94105PETER M. HAYESRACHEL A. BIRKEYPACIFIC BELL TELEPHONE COMPANYOFFICE OF THE GENERAL COUNSEL525 MARKET STREET, RM 1919 U.S. DEPT. OF AGRICULTURESAN FRANCISCO, CA 9410533 NEW MONTGOMERY ST., 17TH FLOORSAN FRANCISCO, CA 94105ROSS JOHNSONSANDY LAMBOYAREA MGR - REGULATORYPACIFIC GAS AND ELECTRIC COMPANYAT&T CALIFORNIA77 BEALE STREET, MC B13L525 MARKET STREET, 19TH FL, RM 33 SAN FRANCISCO, CA 94105SAN FRANCISCO, CA 94105THOMAS SELHORSTMARGARET L. TOBIAS

CPUC - Service Lists - R0811005http://docs.cpuc.ca.gov/published/service_lists/R0811005_77981.htmPage 7 of 106/30/2011SENIOR PARALEGALTOBIAS LAW OFFICEAT&T CALIFORNIA460 PENNSYLVANIA AVENUE525 MARKET STREET, 20TH FLR, RM 2023 SAN FRANCISCO, CA 94107SAN FRANCISCO, CA 94105E. GARTH BLACK MARK P. SCHREIBERCOOPER, WHITE & COOPER, LLPCOOPER, WHITE & COOPER, LLP201 CALIFORNIA STREET, 17TH FLOOR 201 CALIFORNIA STREET, 17TH FLOORSAN FRANCISCO, CA 94111 SAN FRANCISCO, CA 94111FOR: SUREWEST TELEPHONESUZY HONGDAVIS WRIGHT TREMAINE LLPATTORNEY AT LAW505 MONTGOMERY STREET, 8TH FLOORGOODIN MACBRIDE SQUERI DAY & LAMPREY SAN FRANCISCO, CA 94111505 SANSOME STREET, SUITE 900SAN FRANCISCO, CA 94111JOSH DAVIDSONIRENE K. MOOSENDAVIS WRIGHT TREMAINE LLPATTORNEY AT LAW505 MONTGOMERY ST, STE 800 53 SANTA YNEZ AVENUESAN FRANCISCO, CA 94111-6533 SAN FRANCISCO, CA 94112HILARY CORRIGANREGULATORY FILE ROOMCALIFORNIA ENERGY MARKETSPACIFIC GAS AND ELECTRIC COMPANY425 DIVISADERO STREET, SUITE 303 PO BOX 7442SAN FRANCISCO, CA 94117-2242 SAN FRANCISCO, CA 94120JANET LIUCASE COORDINATIONPACIFIC GAS AND ELECTRIC COMPANYPACIFIC GAS AND ELECTRIC COMPANYPO BOX 770000; MC B9APO BOX 770000; MC B9ASAN FRANCISCO, CA 94177 SAN FRANCISCO, CA 94177ROBIN HARRINGTONAMY BARTELLCAL.DEPT OF FORESTRY AND FIRE PROTECTION CITY OF PALO ALTOPO BOX 944246 250 HAMILTON AVENUE, PO BOX 10250SACRAMENTO, CA 94244-2460 PALO ALTO, CA 94303GRANT KOLLINGGARRY J.D. HUBERTSR. ASSISTANT CITY ATTORNEYHUBERT & YASUTAKECITY OF PALO ALTO 1320 WILLOW PASS ROAD, SUITE 590250 HAMILTON AVENUE, PO BOX 10250 CONCORD, CA 94520PALO ALTO, CA 94303DOUGLAS GARRETTCARLOS FERNANDEZ-PELLOCOX COMMUNICATIONSUNIVERSITY OF CALIFORNIA BERKELEY2200 POWELL STREET, STE. 1035 DEPARTMENT OF MECHANICAL ENGINEERINGEMERYVILLE, CA 946086105 ETCHEVERRY HALLBERKELEY, CA 94720-1740ROBERT WOLFEC. SUSIE BERLINAT&T CALIFORNIAATTORNEY AT LAW310 MARTIN AVENUE, ROOM 100A MC CARTHY & BERLIN, LLPSANTA CLARA, CA 95050 100 W SAN FERNANDO ST., STE 501SAN JOSE, CA 95113LYNNE MARTINEZTHOMAS S. KIMBALLDIRECTOR GOVERNMENT AFFAIRSMODESTO IRRIGATION DISTRICTPAC-WEST TELECOMM, INC.1231 11TH STREET4210 CORONADO AVE. MODESTO, CA 95352STOCKTON, CA 95204JOY A. WARRENBRIAN LAFOLLETTEMODESTO IRRIGATION DISTRICTTURLOCK IRRIGATION DISTRICT1231 11TH STREET 333 EAST CANAL DRIVE / PO BOX 949

CPUC - Service Lists - R0811005http://docs.cpuc.ca.gov/published/service_lists/R0811005_77981.htmPage 8 of 106/30/2011MODESTO, CA 95354 TURLOCK, CA 95381-0949GAYATRI SCHILBERGSCOTT TOMASHEFSKYJBS ENERGYNORTHERN CALIFORNIA POWER AGENCY311 D STREET, SUITE A 651 COMMERCE DRIVEWEST SACRAMENTO, CA 95605 ROSEVILLE, CA 95678NICOLE BLAKESCOTT BLAISINGCONSUMER FEDERATION OF CALIFORNIABRAUN BLAISING MCLAUGHLIN, P.C.1107 9TH ST., STE. 625 915 L STREET, SUITE 1270SACRAMENTO, CA 95814 SACRAMENTO, CA 95814LESLA LEHTONENANDREW B. BROWNVP LEGAL AND REGULATORY AFFAIRSELLISON, SCHNEIDER & HARRIS LLPCALIFORNIA CABLE & TELECOM ASSOCIATION 2600 CAPITOL AVENUE, SUITE 4001001 K STREET, 2ND FLOOR SACRAMENTO, CA 95816-5905SACRAMENTO, CA 95814-3832FOR: SIERRA PACIFIC POWER COMPANYCHASE B. KAPPELLYNN HAUGELLISON SCHNEIDER & HARRIS LLPATTORNEY AT LAW2600 CAPITOL AVENUE, SUITE 400 ELLISON, SCHNEIDER & HARRIS, LLPSACRAMENTO, CA 95816-5905 2600 CAPITOL AVENUE, SUITE 400SACRAMENTO, CA 95816-5905MARGARET FELTSDAVID L. BROWN, P.E.PRESIDENTSACRAMENTO MUNICIPAL UTILITY DISTRICTCALIFORNIA COMMUNICATIONS ASSN 6201 S ST., M.S. D-104; PO BOX 158301321 HOWE AVE. SUITE 202 SACRAMENTO, CA 95852-1830SACRAMENTO, CA 95825CALIFORNIA PACIFIC ELECTRIC COMPANY, LL CATHIE ALLEN933 ELOISE AVENUE REGULATORY MGR.SOUTH LAKE TAHOE, CA 96150PACIFICORP825 NE MULTNOMAH, SUITE 2000PORTLAND, OR 97232HEIDE CASWELLSHANNON M. MCWHINNEYPACIFICORPPACIFICORP825 NE MULTNOMAH STREET, SUITE 1500 825 NE MULTNOMAH ST., STE. 1800PORTLAND, OR 97232 PORTLAND, OR 97232CYNTHIA MANHEIMADAM L. SHERRGENERAL ATTORNEYQWEST COMMUNICATIONS CORPORATIONCINGULAR WIRELESS SERVICES, LLC 1600 7TH AVENUE, ROOM 150616331 NE 72ND WAY, ROOM RTC 1 SEATTLE, WA 98191REDMOND, WA 98052State ServiceMELISSA SLAWSON, ESQCYNTHIA LEECALIFORNIA PUBLIC UTILITIES COMMISSION CALIF PUBLIC UTILITIES COMMISSIONEMAIL ONLYSAFETY & RELIABILITY BRANCHEMAIL ONLY, CA 00000 320 West 4th Street Suite 500Los Angeles, CA 90013EDWARD MOLDAVSKYMICHAEL ROBERTSONCALIF PUBLIC UTILITIES COMMISSIONCALIF PUBLIC UTILITIES COMMISSIONLEGAL DIVISIONSAFETY & RELIABILITY BRANCH320 West 4th Street Suite 500 320 West 4th Street Suite 500Los Angeles, CA 90013 Los Angeles, CA 90013

CPUC - Service Lists - R0811005http://docs.cpuc.ca.gov/published/service_lists/R0811005_77981.htmPage 9 of 106/30/2011RAFFY STEPANIANRAYMOND G. FUGERECALIF PUBLIC UTILITIES COMMISSIONCALIF PUBLIC UTILITIES COMMISSIONSAFETY & RELIABILITY BRANCHSAFETY & RELIABILITY BRANCH320 West 4th Street Suite 500 320 West 4th Street Suite 500Los Angeles, CA 90013 Los Angeles, CA 90013BREWSTER FONGCHRISTOPHER MYERSCALIF PUBLIC UTILITIES COMMISSIONCALIF PUBLIC UTILITIES COMMISSIONCOMMUNICATIONS POLICY BRANCHCOMMUNICATIONS POLICY BRANCHROOM 4209 ROOM 4209505 VAN NESS AVENUE 505 VAN NESS AVENUESAN FRANCISCO, CA 94102-3214 SAN FRANCISCO, CA 94102-3214DAVID K. LEEERIC CHIANGCALIF PUBLIC UTILITIES COMMISSIONCALIF PUBLIC UTILITIES COMMISSIONINFRASTRUCTURE PLANNING AND PERMITTING B INFRASTRUCTURE PLANNING AND PERMITTING BAREA 4-A AREA 4-A505 VAN NESS AVENUE 505 VAN NESS AVENUESAN FRANCISCO, CA 94102-3214 SAN FRANCISCO, CA 94102-3214ERIC VAN WAMBEKEHARVEY Y. MORRISCALIF PUBLIC UTILITIES COMMISSIONCALIF PUBLIC UTILITIES COMMISSIONCARRIER OVERSIGHT AND PROGRAMS BRANCH LEGAL DIVISIONAREA 3-E ROOM 5036505 VAN NESS AVENUE 505 VAN NESS AVENUESAN FRANCISCO, CA 94102-3214 SAN FRANCISCO, CA 94102-3214JULIE HALLIGANMICHAEL COENCALIF PUBLIC UTILITIES COMMISSIONCALIF PUBLIC UTILITIES COMMISSIONCONSUMER PROTECTION AND SAFETY DIVISION CARRIER OVERSIGHT AND PROGRAMS BRANCHROOM 2203 AREA 3-E505 VAN NESS AVENUE 505 VAN NESS AVENUESAN FRANCISCO, CA 94102-3214 SAN FRANCISCO, CA 94102-3214MICHAEL GREERPAUL S. PHILLIPSCALIF PUBLIC UTILITIES COMMISSIONCALIF PUBLIC UTILITIES COMMISSIONCOMMUNICATIONS POLICY BRANCHEXECUTIVE DIVISIONROOM 4211 ROOM 5206505 VAN NESS AVENUE 505 VAN NESS AVENUESAN FRANCISCO, CA 94102-3214 SAN FRANCISCO, CA 94102-3214PEJMAN MOSHFEGHRICHARD CLARKCALIF PUBLIC UTILITIES COMMISSIONCALIF PUBLIC UTILITIES COMMISSIONUTILITY & PAYPHONE ENFORCEMENTCONSUMER PROTECTION AND SAFETY DIVISIONAREA 2-E ROOM 2205505 VAN NESS AVENUE 505 VAN NESS AVENUESAN FRANCISCO, CA 94102-3214 SAN FRANCISCO, CA 94102-3214ROBERT ELLIOTTSCOTT MOSBAUGHCALIF PUBLIC UTILITIES COMMISSIONCALIF PUBLIC UTILITIES COMMISSIONINFRASTRUCTURE PLANNING AND PERMITTING B EXECUTIVE DIVISIONAREA 4-A ROOM 5213505 VAN NESS AVENUE 505 VAN NESS AVENUESAN FRANCISCO, CA 94102-3214 SAN FRANCISCO, CA 94102-3214TIMOTHY KENNEYMELODIE DURHAMCALIF PUBLIC UTILITIES COMMISSIONOFFICE OF THE STATE FIRE MARSHALDIVISION OF ADMINISTRATIVE LAW JUDGES WILDLAND FIRE PREVENTIONROOM 50151131 S STREET505 VAN NESS AVENUE SACRAMENTO, CA 95811SAN FRANCISCO, CA 94102-3214STEPHEN BAKKENCALIFORNIA STATE PARKS1416 9TH STREETSACRAMENTO, CA 95814

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