BEFORE THE PUBLIC UTILITIES COMMISSION OF THE STATE OF CALIFORNIA

Transcription

1 BEFORE THE PUBLIC UTILITIES COMMISSION OF THE STATE OF CALIFORNIA Order Instituting Rulemaking Proceeding to Consider Amendments to General Order 95. Rulemaking JOINT COMMENTS OF SOUTHERN CALIFORNIA EDISON COMPANY (U 338-E), CALIFORNIA MUNICIPAL UTILITIES ASSOCIATION, LOS ANGELES DEPARTMENT OF WATER AND POWER, AND SACRAMENTO MUNICIPAL UTILITY DISTRICT TO JOINT PARTIES OCTOBER 31, 2018 WORKSHOP REPORT FADIA KHOURY GLORIA M. ING Attorneys for SOUTHERN CALIFORNIA EDISON COMPANY 2244 Walnut Grove Avenue Post Office Box 800 Rosemead, California Telephone: (626) SYNDI DRISCOLL Attorney for the LOS ANGELES DEPARTMENT OF WATER & POWER 111 North Hope Street, Room 340 Los Angeles, CA Telephone: (213) JOY MASTACHE Attorney for the SACRAMENTO MUNICIPAL UTILITY DISTRICT 6301 S Street, Mail Stop A311 Sacramento, CA Telephone: (916) Joy.Mastache@smud.org LAURA FERNANDEZ Attorney for the CALIFORNIA MUNICIPAL UTILITIES ASSOCIATION Braun Blaising Smith Wynne, P.C. 915 L Street, Suite 1480 Sacramento, CA Telephone: (916) fernandez@braunlegal.com Dated: November 20, 2018

2 BEFORE THE PUBLIC UTILITIES COMMISSION OF THE STATE OF CALIFORNIA Order Instituting Rulemaking Proceeding to Consider Amendments to General Order 95. Rulemaking JOINT COMMENTS OF SOUTHERN CALIFORNIA EDISON COMPANY (U 338-E), CALIFORNIA MUNICIPAL UTILITIES ASSOCIATION, LOS ANGELES DEPARTMENT OF WATER AND POWER, AND SACRAMENTO MUNICIPAL UTILITY DISTRICT TO JOINT PARTIES OCTOBER 31, 2018 WORKSHOP REPORT I. INTRODUCTION Pursuant to the Assigned Commissioner s Scoping Memo and Ruling dated July 31, 2018, Southern California Edison Company (SCE) and the Joint POUs 1 (collectively, SCE/Joint POUs ) submit these Opening Comments on the October 31, 2018 Joint Parties Workshop Report for Workshops Held August September II. SCE/JOINT POU S COMMENTS SCE/Joint POUs support the changes to General Order 95 rule included in the abovereferenced Workshop Report (Report). As noted in the Report the Joint Parties 2 reached 1 The Joint POUs consist of the California Municipal Utilities Association (CMUA), the Los Angeles Department of Water and Power (LADWP), and the Sacramento Municipal Utility District (SMUD). 2 The Joint Parties consist of: AT&T, Bear Valley Electric Service Company, a division of Golden State Water Company, California Cable and Telecommunications Association, the Public Advocates Office, Charter, California Municipal Utilities Association, Comcast Phone of California, LLC, Cox Communications California, LLC, the Commission s Safety and Enforcement Division, Crown Castle, CTIA The Wireless Association, International Brotherhood of Electrical Workers Local Union 1245, Frontier, Los Angeles Department of Water and Power, Modesto Irrigation District, PacifiCorp, Pacific Gas and Electric Company, San Diego Gas & Electric Company, Southern California Edison Company, Sacramento Municipal Utility District, T-Mobile West LLC dba T-Mobile, and Verizon. 1

3 consensus on eighteen of the original twenty-four Proposed Regulations (PRs) reviewed and discussed over the course of six-days of workshop meetings encompassing technical presentations by members of the GO 95/128 Rules Committee and invited technical experts. Each of these consensus PRs represent numerous hours of review and discussion during the workshop meetings as well as supplemental, collaborative conversations among the workshop participants to research and refine PRs in advance of the workshops. As reported, the Joint Parties followed the workshop protocols that were agreed upon during the opening workshop meeting, which was vital to addressing all of the PRs in an organized and timely manner, but more importantly offered each party the opportunity and time to consider their preliminary vote on each PR in advance of a closing review and final vote. Notably, the parties only voted on the PRs and not the accompanying rationales. The rationales for each PR were drafted and added by the Workshop Report team comprised of representatives from SED, AT&T, PacifiCorp, SDG&E, Crown Castle, and SCE, and prior to filing, the Report and Appendix A (with rationales) were reviewed by the Joint Parties and each had the opportunity to provide edits to the Report and rationales, but not the PRs. A. Worker Safety Of particular note are PRs 4, 10, and 14 that offer three new rules for Sections V, VIII, and IX of GO 95 addressing Interference with Fall Protection Equipment and an associated PR 13 (revising Rule 93) addressing the installation of wood pole steps. Combined, PRs 4, 10, 13, and 14 represent a significant step forward in promoting the safety of the electric and communication line workers and technicians that construct and maintain overhead lines and equipment. B. Implementation SCE/Joint POUs recommend that the amendments to General Order 95 adopted by the Commission become effective 180 days from the effective date of a final decision and that the 2

4 decision include a statement advising electric and communication companies that the adopted amendments may be implemented sooner. III. CONCLUSION In furtherance of the Commission s goals to enhance worker and public safety, SCE/Joint POUs encourage the Commission to adopt all of the proposed amendments to GO 95 recommended in the Workshop Report, and also grant electric and communication companies ample opportunity to revise their standards, practices, and procedures in order to comply with the amended GO 95 rules. SCE/Joint POUs would also like to thank the Workshop Report team - Gwen Johnson (AT&T), Heide Caswell (PacifiCorp), Greg Walters (SDG&E), James Tomlinson (Davis, Wright, Tremaine on behalf of Crown Castle), and Raffy Stepanian (SED-ESRB), who also served as the Workshop co-chair - for their efforts producing the Report. Respectfully submitted on behalf of Southern California Edison Company California Municipal Utilities Association Los Angeles Department of Water & Power, and Sacramento Municipal Utility District FADIA KHOURY GLORIA M. ING November 20, 2018 /s/ Gloria M. Ing By: Gloria M. Ing Attorneys for SOUTHERN CALIFORNIA EDISON COMPANY 2244 Walnut Grove Avenue Post Office Box 800 Rosemead, California Telephone: (626) Gloria.Ing@sce.com 3

5 BEFORE THE PUBLIC UTILITIES COMMISSION OF THE STATE OF CALIFORNIA Order Instituting Rulemaking Proceeding to Consider Amendments to General Order 95. Rulemaking CERTIFICATE OF SERVICE I hereby certify that, pursuant to the Commission s Rules of Practice and Procedure, I have this day served a true copy of the JOINT COMMENTS OF SOUTHERN CALIFORNIA EDISON COMPANY (U 338-E), CALIFORNIA MUNICIPAL UTILITIES ASSOCIATION, LOS ANGELES DEPARTMENT OF WATER AND POWER, AND SACRAMENTO MUNICIPAL UTILITY DISTRICT TO JOINT PARTIES OCTOBER 31, 2018 WORKSHOP REPORT on all parties identified on the attached service list for R Service was effected by transmitting copies via to all parties who have provided an address and by placing copies in sealed envelopes and causing such envelopes to be delivered via United States mail with first-class postage prepaid to the offices of the ALJ or other addressee(s). ALJ Robert Mason California Public Utilities Commission Division of Administrative Law Judges 505 Van Ness Avenue, Room 5016 San Francisco, CA Executed on November 20, 2018, at Rosemead, California. /s/ Olivia Gutierrez Olivia Gutierrez SOUTHERN CALIFORNIA EDISON COMPANY 2244 Walnut Grove Avenue Post Office Box 800 Rosemead, California 91770

6 Page 1 of 6 CPUC Home CALIFORNIA PUBLIC UTILITIES COMMISSION Service Lists PROCEEDING: R CPUC - OIR TO CONSID FILER: CPUC LIST NAME: LIST LAST CHANGED: SEPTEMBER 12, 2018 Download the Comma-delimited File About Comma-delimited Files Back to Service Lists Index Parties SHARON YANG KRISTIN L. JACOBSON DIRECTOR OF LEGAL SERVICES SPRINT COMMUNICATIONS LIBERTY UTILITIES (WEST REGION) 900 7TH STREET, STE. 700 WASHINGTON, DC 20001, AA FOR: SPRINT COMMUNICATIONS FOR: LIBERTY UTILITIES (CALIFORNIA) SYNDI DRISCOLL CHARLES H. CARRATHERS III DEPUTY CITY FRONTIER COMMUNICATIONS LOS ANGELES DEPT. OF WATER & POWER 2535 W. HILLCREST DRIVE, MC CAM21LB 111 N. HOPE ST., RM. 340 NEWBURY PARK, CA LOS ANGELES, CA FOR: FRONTIER FOR: LOS ANGELES DEPARTMENT OF WATER & POWER GLORIA ING JOHN A. PACHECO AT LAW SR. COUNSEL SOUTHERN CALIFORNIA EDISON COMPANY SAN DIEGO GAS & ELECTRIC COMPANY 2244 WALNUT GROVE AVE./ PO BOX CENTURY PARK CT., CP32 ROSEMEAD, CA SAN DIEGO, CA FOR: SOUTHERN CALIFORNIA EDISON COMPANY FOR: SAN DIEGO GAS AND ELECTRIC COMPANY JESUS G. ROMAN CANDACE CHOE ASSIST. GEN. COUNSEL VERIZON LEGAL DIVISION SAND CANYON AVE. D201 ROOM 4107 IRVINE, CA VAN NESS AVENUE FOR: VERIZON SAN FRANCISCO, CA

7 Page 2 of 6 FOR: ORA PAUL ANGELOPULO CHARLES R. LEWIS IV LEGAL DIVISION ROOM BEALE ST., B30A 505 VAN NESS AVENUE SAN FRANCISCO, CA SAN FRANCISCO, CA FOR: FOR: SAFETY AND ENFORCEMENT DIVISION (SED) JAMES W. MCTARNAGHAN WALID ABDUL-RAHIM ATORNEY AVP & SR. LEGAL COUNSEL PERKINS COIE LLP AT&T CALIFORNIA 505 HOWARD ST., STE BUSH STREET, ROOM 308 SAN FRANCISCO, CA SAN FRANCISCO, CA FOR: CHARTER FIBERLINK CA-COO, LLC AND FOR: AT&T CALIFORNIA TIME WARNER CABLE INFORMATION SERVICES (CALIFORNIA) LLC JEANNE B. ARMSTRONG PATRICK M. ROSVALL GOODIN, MACBRIDE, SQUERI & DAY, LLP COOPER, WHITE & COOPER LLP 505 SANSOME STREET, SUITE CALIFORNIA STREET, 17TH FL. SAN FRANCISCO, CA SAN FRANCISCO, CA FOR: CTIA FOR: CONSOLIDATED COMMUNICATIONS OF CALIFORNIA COMPANY AND THE SMALL LECS SUZANNE TOLLER ANITA TAFF-RICE DAVIS WRIGHT TREMAINE LLP 505 MONTGOMERY STREET, SUITE 800 ICOMMLAW SAN FRANCISCO, CA PALOS VERDES, NO. 298 FOR: SUNESYS, LLC / COMCAST PHONE OF WALNUT CREEK, CA CALIFORNIA, LLC / CROWN CASTLE NG WEST FOR: EXTENET SYSTEMS (CALIFORNIA) LLC LLC / COX COMMUNICATIONS CALIFORNIA, LLC / COX CALIFORNIA TELCOM, LLC LEON M. BLOOMFIELD JEROME F. CANDELARIA CA. CABLE & TELECOMMUNICATION ASSOC. LAW OFFICES OF LEON M. BLOOMFIELD 1001 K STREET, 2ND FL HARRISON ST., STE SACRAMENTO, CA OAKLAND, CA FOR: GO 95/128 RULES COMMITTEE FOR: T-MOBILE WEST LLC DBA T-MOBILE LAURA TAYLOR JEROME F. CANDELARIA VP & COUNSEL - REGULATORY AFFAIRS BRAUN BLAISING SMITH WYNNE, P.C. CALIFORNIA CABLE & TELECOMMUNICATIONS 915 L STREET, STE K STREET, 2ND FL. SACRAMENTO, CA SACRAMENTO, CA FOR: CALIFORNIA MUNICIPAL UTILITIES FOR: CALIFORNIA CABLE & ASSOCIATION TELECOMMUNICATIONS ASSOCIATION JEDEDIAH J. GIBSON ELLISON SCHNEIDER HARRIS & DONLAN LLP JOY MASTACHE SR. - OFF. OF GEN. COUNSEL SACRAMENTO MUNICIPAL UTILITY DISTRICT

8 Page 3 of CAPITOL AVENUE, SUITE S STREET, MS A311 SACRAMENTO, CA SACRAMENTO, CA FOR: BEAR VALLEY ELECTRIC SERVICE, A FOR: SACRAMENTO MUNICIPAL UTILITY DIV. OF GOLDEN STATE WATER CO. DISTRICT (SMUD) CYNTHIA HANSEN MIFSUD SR PACIFICORP 825 NE MULTNOMAH, SUITE 1800 PORTLAND, OR FOR: PACIFICORP Information Only AMY WARSHAUER BRUCE SMITH GOV'T AFFAIRS ANALYST GRC & REGULATORY SUPPORT FRONTIER COMMUNICATIONS PACIFIC GAS & ELECTRIC COMPANY, CA 00000, CA CHARLIE BORN IGOR GRINBERG ANALYST, GOV'T. & EXTERNAL AFFAIRS REGULATORY AFFAIRS FRONTIER COMMUNICATIONS, CA 00000, CA JIM TOMLINSON DAVIS WRIGHT TREMAINE LLP, CA MATTHEW PLUMMER STATE AGENCY REGULATIONS, CA RAHMA SAEED RYAN APPEL SR. ELECTRIC STANDARDS ENGINEER DAVIS WRIGHT TREMAINE LLP, DC 00000, CA DAVIS WRIGHT TREMAINE LLP, CA MARK DINUNZIO COX COMMUNICATIONS, INC., AZ LINDA C. STINAR ELLIOTT S. HENRY DIR - REGULATORY AFFAIRS SR. COUNSEL CENTURYLINK SOUTHERN CALIFORNIA GAS COMPANY 6700 VIA AUSTI PARKWAY 555 WEST FIFTH STREET, GT14E7 LAS VEGAS, NV LOS ANGELES, CA RAFFY STEPANIAN GREGORY HEALY REGULATORY CASE MGR. ELECTRIC SAFETY AND RELIABILITY BRANCH SOUTHERN CALIFORNIA GAS COMPANY 320 West 4th Street Suite WEST FIFTH STREET, GT14D6

9 Page 4 of 6 Los Angeles, CA LOS ANGELES, CA DAN MARSH ASIA POWELL MGR, RATES AND REGULATORY AFFAIRS STATE REGULATORY AFFAIRS LIBERTY UTILITIES (CALIFORNIA) FRONTIER COMMUNICATIONS 9750 WASHBURN ROAD 2535 W. HILLCREST DR DOWNEY, CA THOUSAND OAKS, CA FELICIA HUDSON SAMUEL B. STONEROCK GOVERNMENT & EXTERNAL AFFAIRS CORPORATE REP. FRONTIER COMMUNICATIONS SOUTHERN CALIFORNIA EDISON 2560 TELLER ROAD 3 INNOVATION WAY NEWBURY PARK, CA POMONA, CA CASE ADMINISTRATION KAREN CHUNG SOUTHERN CALIFORNIA EDISON COMPANY MANAGER PROGRAM/PORJECT 8631 RUSH STREET SOUTHERN CALIFORNIA EDISON COMPANY ROSEMEAD, CA RUSH STREET ROSEMEAD, CA KEITH W. MELVILLE REBECCA W. GILES SR. COUNSEL REGULATORY CASE MANAGER SAN DIEGO GAS & ELECTRIC COMPANY SAN DIEGO GAS & ELECTRIC COMPANY 8330 CENTURY PARK CT., CP32D 8330 CENTURY PARK COURT, CP32-F SAN DIEGO, CA SAN DIEGO, CA PAUL MARCONI ELIZABETH PODOLINSKY DIR BEAR VALLEY ELECTRIC SERVICE PRESIDENT PICKER GARSTIN DRIVE, PO BOX 1547 ROOM 5306 BIG BEAR LAKE, CA VAN NESS AVENUE SAN FRANCISCO, CA AICHI N. DANIEL JANE WHANG STAFF COUNSEL VERIZON 77 BEALE STREET B30A 201 SPEAR STREET, 7TH FL. SAN FRANCISCO, CA SAN FRANCISCO, CA RX UY FASSIL FENIKILE DIR - REGULATORY AT&T SERVICES, INC. 77 BEALE STREET, B30A 430 BUSH STREET, 5TH FLOOR SAN FRANCISCO, CA SAN FRANCISCO, CA FOR: AT&T CALIFORNIA (U 1001 C) AND NEW CINGULAR WIRELESS PCS, LLC (U 3060 C) GWEN JOHNSON HUGH OSBORNE CONSULTANT FOR AT&T SERVICES, INC. LEGAL ASSISTANT 430 BUSH STREET, 5TH FLOOR AT&T SERVICES, INC. SAN FRANCISCO, CA BUSH STREET, 3RD FL. NO. 17 FOR: AT&T CALIFORNIA (U 1001 C) AND NEW SAN FRANCISCO, CA CINGULAR WIRELESS PCS, LLC (U 3060 C) FOR: AT&T CALIFORNIA (U 1001 C) AND NEW CINGULAR WIRELESS PCS, LLC (U 3060 C)

10 Page 5 of 6 PETER HAYES THOMAS SELHORST AVP - REGULATORY SENIOR PARALEGAL AT&T SERVICES, INC. AT&T CALIFORNIA, INC. 430 BUSH STREET, 5TH FLOOR 430 BUSH STREET, 3RD FL, RM. 326 SAN FRANCISCO, CA SAN FRANCISCO, CA FOR: AT&T CALIFORNIA (U1001 C) AND NEW FOR: AT&T CALIFORNIA (U 1001 C) AND NEW CINGULAR WIRELESS PCS, LLC (U3060 C) CINGULAR WIRELESS PCS, LLC (U 3060 C) CASE COORDINATION C. SUSIE BERLIN LAW OFFICES OF SUSIE BERLIN 1346 THE ALAMEDA, STE. 7, NO. 141, CA SAN JOSE, CA JUSTIN WYNNE ANN L. TROWBRIDGE AT LAW BRAUN BLAISING SMITH WYNNE, P.C. DAY CARTER & MURPHY LLP 915 L STREET, STE AMERICAN RIVER DRIVE, STE. 205 SACRAMENTO, CA SACRAMENTO, CA FOR: CALIFORNIA MUNICIPAL UTILITIES ASSOCIATION CATHIE ALLEN HEIDE CASWELL REGULATORY AFFAIRS MGR. PACIFICORP PACIFICORP 825 NE MULTNOMAH STREET, SUITE NE MULTNOMAH ST., STE 300 PORTLAND, OR PORTLAND, OR State Service ELIZAVETA I. MALASHENKO FADI DAYE SAFETY AND ENFORCEMENT DIVISION ELECTRIC SAFETY AND RELIABILITY BRANCH 320 West 4th Street Suite West 4th Street Suite 500 Los Angeles, CA Los Angeles, CA ALAN BACH ALEXANDER J. ABRAMSON ENERGY SAFETY & INFRASTRUCTURE BRANCH BROADBAND, POLICY & ANALYSIS BRANCH AREA AREA AROCLES AGUILAR CHARLES MEE LEGAL DIVISION ELECTRIC SAFETY AND RELIABILITY BRANCH ROOM 5138 ROOM 4102 CHARLOTTE TERKEURST ELECTRIC SAFETY AND RELIABILITY BRANCH CHLOE LUKINS ENERGY SAFETY & INFRASTRUCTURE BRANCH

11 Page 6 of 6 ROOM 2201 ROOM 4102 EDWARD F. RANDOLPH KELLY C. LEE ENERGY DIVISION ENERGY SAFETY & INFRASTRUCTURE BRANCH ROOM 4004 ROOM 4108 NATHANIEL SKINNER NUSRAT MOLLA ENERGY SAFETY & INFRASTRUCTURE BRANCH ENERGY SAFETY & INFRASTRUCTURE BRANCH AREA 4-A AREA FOR: ORA QUANG PHAM ROBERT MASON ELECTRIC SAFETY AND RELIABILITY BRANCH DIVISION OF ADMINISTRATIVE LAW JUDGES AREA 2-D ROOM 5016 TIMOTHY KENNEY LAURA MCWILLIAMS STATE SENATOR JERRY HILL DIVISION OF ADMINISTRATIVE LAW JUDGES STATE CAPITOL ROOM 5015 SACRAMENTO, CA VAN NESS AVENUE SAN FRANCISCO, CA ROBERT B. OSBORN BROADBAND, POLICY & ANALYSIS BRANCH 770 L Street, Suite 1250 Sacramento, CA TOP OF PAGE BACK TO INDEX OF SERVICE LISTS