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 to Develop and Adopt Fire-Threat Maps and Fire- Safety Regulations Rulemaking (Filed May 7, 2015) SOUTHERN CALIFORNIA EDISON COMPANY S (U 338-E) COMMENTS ON PROPOSED DECISION OF COMMISSIONER MICHAEL PICKER FRANK A. MCNULTY Attorneys for SOUTHERN CALIFORNIA EDISON COMPANY 2244 Walnut Grove Avenue Post Office Box 800 Rosemead, California Telephone: (626) Facsimile: (626) mcnultfa@sce.com Dated: November 28, 2017

2 Subject Index Restate the interpretation of Rule 48 and related discussion to be consistent with Decision (D) or eliminate the discussion. Use SDG&E s invalid chilling effect argument as the sole justification for determining that PR 13 is out of scope rather than an inconsistent interpretation of Rule 48. Include language in Findings of Fact and/or Conclusions of Law reminding IOUs and CIPs of their obligation to comply with GO 95, as previously directed in D , and indicating Rule 48 will be addressed in coordination with the development and adoption of a statewide fire-wind map, consistent with Ordering Paragraph 8 of the PD.

3 SOUTHERN CALIFORNIA EDISON COMPANY S (U 338-E) COMMENTS ON PROPOSED DECISION OF COMMISSIONER MICHAEL PICKER Table Of Contents Section Page I. II. INTRODUCTION...1 COMMENTS...2 A. B. C. The PD s Interpretation of Rule 48 Conflicts With D The PD s Interpretation Of Rule 48 And Table 7 Are Not Needed To Find The SDG&E Proposal Out-of-Scope...4 Rule 48 should be addressed in coordination with the development and adoption of a statewide fire-wind map as contemplated in Ordering Paragraph III. CONCLUSION...6 Appendix A... i

4 SOUTHERN CALIFORNIA EDISON COMPANY S (U 338-E) COMMENTS ON PROPOSED DECISION OF COMMISSIONER MICHAEL PICKER Table Of Authorities CPUC Decisions Authorities D passim D , 6 CPUC Rulemakings R , 5 R , 5 CPUC General Orders GO , 4, 5, 6 CPUC Rules of Practice and Procedure Rule Page ii

5 BEFORE THE PUBLIC UTILITIES COMMISSION OF THE STATE OF CALIFORNIA Order Instituting Rulemaking to Develop and Adopt Fire-Threat Maps and Fire- Safety Regulations Rulemaking (Filed May 7, 2015) SOUTHERN CALIFORNIA EDISON COMPANY S (U 338-E) COMMENTS ON PROPOSED DECISION OF COMMISSIONER MICHAEL PICKER I. INTRODUCTION Pursuant to Rule 14.3 of the Rules of Practice and Procedure of the California Public Utilities Commission (Commission), Southern California Edison Company (SCE) respectfully files its Opening Comments to the Proposed Decision (PD) of Commissioner Picker issued on November 8, In accordance with Rule 14.3, a Subject Index of Recommended Changes to the PD and an Appendix of Changes to the Findings of Fact and Conclusions of Law are appended to the end of these comments. SCE continues to support the Commission s efforts to improve California safety through this proceeding. The changes SCE proposes in these comments would increase the robustness of the Commission s efforts. SCE urges the Commission to adopt the PD with the changes proposed herein. 1

6 II. COMMENTS A. In Rejecting Proposed Regulation 13 (GO 95, Rule 48) The PD Interprets Rule 48 In A Manner Not Supported By The Record SDG&E introduced Proposed Regulation (PR) 13 to correct an error in Rule 48. The intent of this PR was to resolve a long-running issue arising from a too literal reading of the rule. As written, the rule could be interpreted to require the safety factor to be applied twice, once to the strength of the material and once to the load, which would result in a mathematical squaring of the effective safety factor. 1 Although SDG&E offered an example of how such a doubling affect would impact the design of a wood pole in Grade A construction, SDG&E also correctly states that such a calculation would be inconsistent with other rules in General Order (GO) 95, Section IV, and the loading examples in Appendix F. The PD correctly summarizes SDG&E s proposed revision as designed to eliminate the multiply by provision of GO 95 Rule 48 (Material Strength) and notes that a majority of parties support the proposal. However, the PD incorrectly describes the intent of the proposal and mistakenly relies on an interpretation of Rule 48 from Decision (D) to find PR 13 out-of-scope. The PD also errs by narrowing the focus of Rule 48 to wood poles in a Light Loading District, stating: The core requirement in Rule 48 is that Grade A wood poles must be designed and built so they will not fail at the loads specified in Rule 43 multiplied by the relevant safety factors in Rule By narrowly focusing on one line element (in one particular loading condition), the PD ignores the substantial technical information provided in workshop reports and written comments in Phase 2 and Phase 3 of Rulemaking (R) The information compiled in R amply demonstrates that wood poles are not the focus of parties concerns with Rule 48. That information also shows that doubling the safety factor for any line element listed in Table 4 (of Rule 44) due to a literal reading of 1 R , Fire Safety Workshop Report filed July 10, 2017, page B PD, p R , Ordering Paragraph 6 - The record of Rulemaking is incorporated by reference into the record of the rulemaking proceeding instituted by this order. 2

7 the rule would be counter to other GO 95 rules and appendices that clearly explain how safety factors are to be applied when designing overhead electric supply and communication lines. B. The PD s Interpretation of Rule 48 Conflicts With D In response to an application for rehearing filed by SDG&E, the Commission issued D , which clarified that adopting a consensus-based revision to GO 95, Rule 48, implied no intent to adopt any new standard with regard to the instant rule. 4 With respect to the various proposals to revise the multiply by verbiage in Rule 48 and how utilities are expected to apply said rule, the Commission stated: We decided to defer consideration of any proposals to revise the multiply by provision of Rule 48, as well as proposals regarding how the safety factors should be applied throughout Rule 48 and its subparts, to Phase 3, Track 3 of the proceeding. (D , pp. 95 [Conclusions of Law 7] & [Ordering Paragraph ( OP ) 5].) In Phase 3, Track 3, we intend to develop, adopt, and implement statewide fire-threat maps that accurately designate geographic areas where power-line fires are more likely to ignite and spread rapidly. (D , p. 68.) We expect that the fire-threat maps will allow the development of a more granular and cost-effective wind-load standard and that a blanket requirement that all facilities should be built to the same wind-load standard may not be necessary or appropriate. 5 The investor-owned utilities ( IOUs ) and the communications infrastructure providers ( CIPs ) have represented that they currently design and construct their facilities based on a standard of 56 mph (or higher based on known local conditions ). We acknowledge that statements in the Decision may have caused confusion about whether the IOUs and CIPs are now expected to replace, redesign, or reconstruct their facilities based on a standard of 112/92 mph while Phase 3, Track 3 of the proceeding is pending, and therefore, modify the Decision to provide clarification. The proposed decision ( PD ) that led to the Decision had stated that all entities subject to GO 95 were expected to design and construct their facilities based on a standard of 112/92 mph and that each CIP and electric utility shall implement this standard as soon as practical and with all due haste with respect to facilities that are installed or reconstructed going forward. (PD, pp ; see also PD, p. 102 [OP 4].) But we deleted this and similar language from the PD before adopting the Decision, and decided to defer consideration of issues regarding Rule 48 to Track 3, Phase 3 of the proceeding. Instead, the Decision instructed that: Until new standards for the design and construction of overhead facilities in high fire-threat areas are adopted in Track 3, electric utilities and CIPs shall continue to comply with the Rule 31.1 requirement to design 4 D , page 4 5 D , p

8 and construct their facilities based on known local conditions, including Santa Ana windstorms. 6 Although we made significant modifications to the PD with regard to Rule 48 prior to adopting the Decision, it appears that modifications were not consistently made throughout the PD. With the exception of the adoption of Consensus Proposal 13, we intended to defer all consideration of issues regarding Rule 48 that are within the scope of this proceeding to Track 3, Phase 3 of the proceeding. We modify the Decision, as set forth in the ordering paragraphs below, to clarify this point. As stated in the Decision, the IOUs and CIPs shall continue to comply with Rule 31.1 during the pendency of Track 3, Phase 3. We note that under this rule, a wind load standard of 56 mph would not be adequate in areas where the known local conditions may exceed winds of 56 mph. We also remind the IOUs and CIPs that they must also continue to comply with the other provisions of GO 95, including Rules 43 and 44. Under the law, the IOUs and CIPs are responsible for ensuring that their facilities are designed, constructed, and maintained to enable the furnishing of safe, proper, and adequate service. The modifications we make today are consistent with the modifications we made to the PD prior to adopting the Decision and do not affect any of the findings of fact, conclusions of law, or ordering paragraphs of the Decision. With these modifications, SDG&E s rehearing application is denied. SDG&E s request for oral argument is also denied. C. The PD s Interpretation Of Rule 48 And Table 7 Are Not Needed To Find The SDG&E Proposal Out-of-Scope Per the comments above, the Commission determined that consideration of the multiply verbiage in Rule 48 should be deferred to Track 3 in R The Commission also determined that any proposed changes to Rule 48 must be consistent with the primary purpose of the instant proceeding enhancing fire safety. Rule 48 and remaining Track 3 items were extended to R and the scope of the new proceeding reaffirmed the intent that revised regulations must serve goal of enhancing fire safety. In its workshop report justification statement for PR 13, SDG&E states: It is imperative that these errors, inconsistencies and ambiguities be corrected. Failure to adopt this revised rule will rightfully have a chilling effect on electric utilities and CIPs willingness to objectively and proactively pursue other enhancements related to mechanical strength requirements that may aid in mitigating fire ignition risks as well as any other future enhancements, and will perpetuate known errors. SDG&E s proposal to correct errors, inconsistencies, and ambiguities driven by the current version of Rule 48 is well intended, technically sound, and needed. However, the notion that failure to 6 D , p. 70 (emphasis added). 4

9 correct the rule will have a chilling effect on electric utility and CIP efforts to mitigate fire ignition risks is tenuous and seems to rely on facts not in evidence. In D , the Commission admonished IOUs and CIPs that a wind load standard of 56 mph would not be adequate in areas where the known local conditions may exceed winds of 56 mph and that they must also continue to comply with the other provisions of GO 95, including Rules 43 and 44. Under the law, the IOUs and CIPs are responsible for ensuring that their facilities are designed, constructed, and maintained to enable the furnishing of safe, proper, and adequate service. Thus, SDG&E s assertion that failure to revise Rule 48 will have a chilling effect, which is the crux of their justification, is not persuasive, and should be sufficient grounds for finding PR 13 out-of-scope. Finding PR 13 to be out of scope on these grounds is sound and does not rely on an interpretation of Rule 48 from D that the Commission later determined was not intended to be applied by IOUs and CIPs or enforced by its Safety Enforcement Division. D. Rule 48 should be addressed in coordination with the development and adoption of a statewide fire-wind map as contemplated in Ordering Paragraph 8. Like SDG&E, PG&E, and the other utilities, SCE is committed to designing, constructing, inspecting, maintaining, and operating overhead lines in a safe and reliable manner. Finding PR 13 to be out-of-scope without prejudice, for the reasons stated in Section II.C above, will not relieve either IOUs or CIPs of their responsibilities or regulatory obligations, and no party has yet claimed otherwise. Electric utilities and CIPs should be reminded of their obligation to comply with GO 95 as previously directed in D until such time as the Commission adopts revised GO 95 rules and a (presumed) new wind-map following a thorough technical vetting. Additionally, the Commission should also provide clarity with respect to how and when Rule 48 is to be addressed. Both of these items could be appropriately addressed as a Findings of Fact or a Conclusions of Law. Recommended edits to Findings of Fact 22 are included in Appendix A. 5

10 III. CONCLUSION SCE appreciates the opportunity to provide comments in this important proceeding and agrees with the Commission s finding that PR 13 is outside of the scope for the reasons noted above. However, SCE is concerned that using Rule 48 as a justification for the Finding goes beyond the record established in the proceeding and creates inconsistences with prior Commission efforts. As such, SCE recommends that the Commission either restate the Rule 48 discussion to ensure it is consistent with prior Commission efforts or eliminate that discussion, since it is not needed to justify the Finding. Additionally, SCE recommends that the Commission remind IOUs and CIPs of their obligations pursuant to D Finally, SCE recommends that the Commission address Rule 48 in conjunction with the development and adoption of a statewide fire-wind map as contemplated in Ordering Paragraph 8. For the reasons stated above, SCE asks the PD to be modified consistent with these comments. FRANK A. MCNULTY /s/ Frank A. McNulty By: Frank A. McNulty Attorneys for SOUTHERN CALIFORNIA EDISON COMPANY 2244 Walnut Grove Avenue Post Office Box 800 Rosemead, California Telephone: (626) Facsimile: (626) mcnultfa@sce.com November 28,

11 Appendix A

12 Findings of Fact 22 Proposed Revised Text (Strikeout/Underline) 22. Removing the multiply by provision in Rule 48 would reduce fire safety by reducing the minimum wind speed that poles must withstand, or will not fail, from 112 mph (new poles) and 92 mph (poles to be reinforced or replaced) to 56 mph (all poles). does not enhance fire-safety and is outside the scope of this proceeding to the extent it applies to utility facilities located outside the High Fire-Threat District. A-1

13 BEFORE THE PUBLIC UTILITIES COMMISSION OF THE STATE OF CALIFORNIA Order Instituting Rulemaking to Develop and Adopt Fire-Threat Maps and Fire- Safety Regulations Rulemaking (Filed May 7, 2015) 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 SOUTHERN CALIFORNIA EDISON COMPANY S (U 338-E) COMMENTS ON PROPOSED DECISION OF COMMISSIONER MICHAEL PICKER on all parties identified on the attached service list for: R Service was effected by one or more means indicated below: Transmitting the copies via to all parties who have provided an address. Placing the copies in sealed envelopes and causing such envelopes to be delivered by hand or by U.S. Mail to the offices of the Assigned ALJ(s) or other addressee(s). ALJ Timothy Kenney ALJ Valerie Kao CPUC 505 Van Ness Ave. San Francisco, CA Executed November 28, 2017, at Rosemead, California. /s/laura Velarde Laura Velarde Legal Administrative Assistant SOUTHERN CALIFORNIA EDISON COMPANY 2244 Walnut Grove Avenue Post Office Box 800 Rosemead, California 91770

14 CPUC - Service Lists - R Page 1 of 9 11/28/2017 CPUC Home CALIFORNIA PUBLIC UTILITIES COMMISSION Service Lists PROCEEDING: R CPUC - OIR TO DEVELO FILER: CPUC LIST NAME: LIST LAST CHANGED: NOVEMBER 21, 2017 Download the Comma-delimited File About Comma-delimited Files Back to Service Lists Index Parties VIDHYA PRABHAKARAN SYNDI DRISCOLL DEPUTY CITY DAVIS WRIGHT & TREMAINE, LLP LOS ANGELES DEPT. OF WATER & POWER 111 N. HOPE ST., RM. 340, CA LOS ANGELES, CA FOR: LIBERTY UTILITIES (CALPECO FOR: LOS ANGELES DEPARTMENT OF WATER & ELECTRIC) LLC POWER JOHN R. TODD FRANK A. MCNULTY DEP. CHIEF-PREVENTION SVCS. BUREAU DIR & MANAGING COUNTY OF LOS ANGELES FIRE DEPT. SOUTHERN CALIFORNIA EDISON COMPANY 1320 N. EASTERN AVENUE, RM WALNUT GROVE AVE., / PO BOX 800 LOS ANGLELES, CA ROSEMEAD, CA FOR: COUNTY OF LOS ANGELES, COUNTY OF FOR: SOUTHERN CALIFORNIA EDISON COMPANY LOS ANGELES FIRE DEPARTMENT DIANE CONKLIN KEITH MELVILLE SPOKESPERSON SR. COUNSEL MUSSEY GRADE ROAD ALLIANCE SAN DIEGO GAS & ELECTIRIC COMPANY PO BOX CENTURY PARK CT., CP-32D RAMONA, CA SAN DIEGO, CA FOR: MUSSEY GRADE ROAD ALLIANCE (MGRA) FOR: KEITH MELVILLE REBECCA W. GILES REGULATORY CASE MGR. SAN DIEGO GAS & ELECTRIC COMPANY JESUS G. ROMAN ASSISTANT GENERAL COUNSEL VERIZON

15 CPUC - Service Lists - R Page 2 of 9 11/28/ CENTRUY PARK COURT - CP31F SAND CANYON AVE. D201 SAN DIEGO, CA IRVINE, CA FOR: SAN DIEGO GAS & ELECTRIC COMPANY FOR: VERIZON CALIFORNIA, INC. KRISTIN L. JACOBSON RASHID A. RASHID SPRINT / NEXTEL 201 MISSION STREET, SUITE 1500 LEGAL DIVISION SAN FRANCISCO, CA ROOM 5131 FOR: SPRINT / NEXTEL 505 VAN NESS AVENUE SAN FRANCISCO, CA FOR: SED ROBERT FINKELSTEIN CHARLES R. LEWIS IV GENERAL COUNSEL THE UTILITY REFORM NETWORK PACIFIC GAS AND ELECTRIC COMPANY 785 MARKET ST., STE BEALE ST., B30A SAN FRANCISCO, CA SAN FRANCISCO, CA FOR: THE UTILITY REFORM NETWORK (TURN) FOR: PACIFIC GAS AND ELECTRIC COMPANY DAVID L. HUARD JEANNE B. ARMSTRONG AT LAW MANATT, PHELPS & PHILLIPS GOODIN, MACBRIDE, SQUERI & DAY, LLP ONE EMBARCADERO CTR., 30TH FLR. 505 SANSOME ST., STE. 900 SAN FRANCISCO, CA SAN FRANCISCO, CA FOR: CITY OF LAGUNA BEACH FOR: CTIA-THE WIRELESS ASSOCIATION. COMMUNICATIONS INFRASTRUCTURE PROVIDERS CIP COALITION: AT&T CALIFORNIA AND NEW CINGULAR WIRELESS PCS, LLC (AT&T), THE CALIF. CABLE AND TELECOMMUNICATIONS ASSOC., COMCAST PHONE OF CALIF., LLC, CONSOLIDATED COMMUNICATIONS OF CALIF. COMPANY, COX COMMUNICATIONS CALIF., LLC, CROWN CASTLE NG WEST LLC, CTIA, FRONTIER COMMUNICATIONS, THE SMALL LEC'S, SPRINT COMMUNICATIONS, T-MOBILE WEST LLC DBA T-MOBILE. MARK P. SCHREIBER ZEB ZANKEL AT LAW COOPER, WHITE & COOPER, LLP DAVIS WRIGHT TREMAINE LLP 201 CALIFORNIA STREET, 17TH FLOOR 505 MONTGOMERY STREET, STE. 800 SAN FRANCISCO, CA SAN FRANCISCO, CA FOR: CONSOLIDATED COMMUNICATIONS OF FOR: COX COMMUNICATIONS CALIFORNIA COMPANY (FORMERLY SUREWEST TELEPHONE) AND THE SMALL LECS SUZANNE TOLLER SUZANNE TOLLER DAVIS WRIGHT TREMAINE LLP DAVIS WRIGHT TREMAINE LLP 505 MONTGOMERY STREET, SUITE MONTGOMERY STREET, STE. 800 SAN FRANCISCO, CA SAN FRANCISCO, CA FOR: TIME WARNER CABLE INFORMATION FOR: CHARTER FIBERLINK CA-CCA, LLC SERVICES (CALIFORNIA), LLC

16 CPUC - Service Lists - R Page 3 of 9 11/28/2017 SUZANNE TOLLER LEON M. BLOOMFIELD DAVIS WRIGHT TREMAINE LLP 505 MONTGOMERY STREET, STE. 800 LAW OFFICES OF LEON M. BLOOMFIELD SAN FRANCISCO, CA HARRISON ST., STE FOR: SUNESYS, LLC / COMCAST PHONE OF OAKLAND, CA CALIFORNIA, LLC / CROWN CASTLE NG WEST, FOR: T-MOBILE WEST LLC DBA T-MOBILE INC. WALID ABDUL-RAHIM CHARLIE BORN GENERAL COUNSEL FRONTIER COMMUNICATIONS AT&T SERVICES, INC. PO BOX WEBSTER STREET, 8TH FL. ELK GROVE, CA OAKLAND, CA FOR: FRONTIER COMMUNICATIONS FOR: AT&T CALIFORNIA & NEW CINGULAR WIRELESS PCS, LLC JUSTIN WYNNE JEROME F. CANDELARIA CAL. CABLE & TELECOMMUNICATIONS ASSN. BRAUN BLAISING MCLAUGHLIN & SMITH, P.C. 100 K STREET, 2ND FL. 915 L STREET, SUITE 1480 SACRAMENTO, CA SACRAMENTO, CA FOR: CALIFORNIA CABLE & FOR: CALIFORNIA MUNICIPAL UTILITIES TELECOMMUNICATIONS ASSOCIATION ASSOCIATION (CMUC) JEDEDIAH J. GIBSON JOSEPH SCHOFIELD AT LAW SENIOR ELLISON SCHNEIDER HARRIS & DONLAN LLP SACRAMENTO MUNICIPAL UTILITIY DISTRICT 2600 CAPITOL AVENUE, SUITE S STREET, MS B406 SACRAMENTO, CA SACRAMENTO, CA FOR: BEAR VALLEY ELECTRIC SERVICE FOR: SACRAMENTO MUNICIPAL UTILITY DISTRICT (SMUD) KAREN NORENE MILLS CYNTHIA MIFSUD SENIOR CALIFORNIA FARM BUREAU FEDERATION PACIFICORP 2300 RIVER PLAZA DRIVE 825 NE MULTNOMAH ST., STE SACRAMENTO, CA PORTLAND, OR FOR: CALIFORNIA FARM BUREAU FEDERATION FOR: PACIFICORP Information Only CASE COORDINATION ESTHER NORTHRUP PACIFIC GAS AND ELECTRIC COMPANY COX COMMUNICATIONS, CA 00000, CA IGOR GRINBERG JIM TOMLINSON REGULATORY AFFAIRS DAVIS WRIGHT TREMAINE, LLP PACIFIC GAS AND ELECTRIC COMPANY, CA 00000

17 CPUC - Service Lists - R Page 4 of 9 11/28/2017, CA KATIE JORRIE MASON WITHERS DAVIS WRIGHT TREMAINE, LLP SAN DIEGO GAS & ELECTRIC COMPANY, CA 00000, CA MATTHEW PLUMMER RAHMA SAEED STATE AGENCY REGULATIONS SR. ELECTRIC STANDARDS ENGINEER PACIFIC GAS AND ELECTRIC COMPANY PACIFIC GAS AND ELECTRIC COMPANY, CA 00000, CA RYAN APPEL SPENCER OLINEK DAVIS WRIGHT TREMAINE LLP PACIFIC GAS AND ELECTRIC COMPANY, DC 00000, CA THOMAS VARGHESE DAVIS WRIGHT TREMAINE LLP PACIFIC GAS & ELECTRIC COMPANY, CA 00000, CA JEAN HAWLEY LINDA C. STINAR FRIEND, HUDAK& HARRIS, LLP DIR - REGULATORY AFFAIRS 3 RAVINIA DRIVE, SUITE CENTURYLINK ATLANTA, GA VIA AUSTI PARKWAY LAS VEGAS, NV BETH A. FOX DAN MARSH MANATT, PHELPS & PHILLIPS, LLP MGR, RATES AND REGULATORY AFFAIRS W. OLYMPIC BLVD. LIBERTY UTILITIES (CALIFORNIA) LOS ANGELES, CA WASHBURN ROAD DOWNEY, CA EDWARD JACKSON JOSEPH PARK DIR - REVENUE REQUIREMENTS DIRECTOR OF LEGAL SERVICES LIBERTY UTILITIES (CALIFORNIA) LIBERTY UTILITIES (CALIFORNIA) 9750 WASHBURN ROAD / PO BOX WASHBURN ROAD DOWNEY, CA DOWNEY, CA ASIA POWELL CHARLES CARRATHERS, III STATE REGULATORY AFFAIRS FRONTIER CALIFORNIA INC. FRONTIER COMMUNICATIONS 2535 W. HILLCREST DRIVE 2535 W. HILLCREST DR THOUSAND OAKS, CA THOUSAND OAKS, CA CASE ADMINISTRATION LAW DEPARTMENT MARISSA BLUNSCHI REGULATORY POLICY

18 CPUC - Service Lists - R Page 5 of 9 11/28/2017 SOUTHERN CALIFORNIA EDISON COMPANY SOUTHERN CALIFORNIA EDISON COMPANY 2244 WALNUT GROVE AVE., PO BOX WALNUT GROVE AVE / PO BOX 800 ROSEMEAD, CA ROSEMEAD, CA NGUYEN QUAN STACIE ATKINSON REGULATORY AFFAIRS REGULATORY CASE ANALYST BEAR VALLEY ELECTRIC SERVICE SAN DIEGO GAS & ELECTRIC COMPANY 630 EAST FOOTHILL BLVD CENTURY PARK COURT SAN DIMAS, CA SAN DIEGO, CA FOR: BEAR VALLEY ELECTRIC SERVICE JOSPEH W. MITCHELL, PH.D RANDY LYLE M-BAR TECHNOLOGIES AND CONSULTING, LLC SAN DIEGO GAS & ELECTRIC COMPANY KIMBALL VALLEY ROAD CONSTRUCTION SERVICE - CP22C RAMONA, CA CENTURY PARK COURT FOR: MUSSEY GRADE ROAD ALLIANCE SAN DIEGO, CA CENTRAL FILES ANNE B. BEAUMONT SAN DIEGO GAS & ELECTRIC COMPANY PERKINS COIE LLP 8330 CENTURY PARK CT, CP31-E EL CAMINO REAL, SUITE 350 SAN DIEGO, CA SAN DIEGO, CA PAUL MARCONI JEFF LATENDRESSE BEAR VALLEY ELECTRIC SERVICE FIRE CHIEF GARSTIN DRIVE CITY OF LAGUNA BEACH BIG BEAR LAKE, CA FOREST AVE. LAGUNA BEACH, CA JOHN PIETIG CATHERINE BERTE CITY MANAGER PERKINS COIE LLP CITY OF LAGUNA BEACH 505 HOWARD STREET, SUITE FOREST AVENUE SAN FRANICSCO, CA LAGUNA BEACH, CA JOE LOYA MAGGIE CHAN PACIFIC GAS AND ELECTRIC COMPANY REGULATORY AFFAIRS 77 BEALE ST., RM MAIL CODE B10C PACIFIC GAS AND ELECTRIC COMPANY SAN FRANCISCO, CA BEALE ST., MC B9A / PO BOX SAN FRANCISCO, CA PATRICK J. GEOFFREY TY MCCARTNEY PACIFIC GAS & ELECTRIC COMPANY PACIFIC GAS AND ELECTRIC COMPANY MAIL CODE H12A 123 MISSION STREET, ROOM 1266, CA SAN FRANCISCO, CA MARGARET L. TOBIAS FASSIL T. FENIKILE DIR. - REGULATORY TOBIAS LAW OFFICE AT&T SERVICES, INC 460 PENNSYLVANIA AVE 430 BUSH STREET, RM. 1925

19 CPUC - Service Lists - R Page 6 of 9 11/28/2017 SAN FRANCISCO, CA SAN FRANCISCO, CA GWEN JOHNSON THOMAS SELHORST CONSULTANT FOR AT&T SERVICES, INC. SENIOR PARALEGAL 430 BUSH STREET, 1ST FLOOR AT&T SERVICES, INC. SAN FRANCISCO, CA BUSH STREET, 3RD FL, NO. 14 SAN FRANCISCO, CA HUGH OSBORNE DEMETRIO MARQUEZ ASSISTANT REGULATORY SPECIALIST AT&T SERVICES, INC. MANATT, PHELPS & PHILLIPS, LLP 430 BUSH STREET, 3RD FL. NO. 17 ONE EMBARCADERO CENTER, 30TH FL. SAN FRANCISCO, CA SAN FRANCISCO, CA LILLY B. MCKENNA PATRICK M. ROSVALL MANATT PHELPS & PHILLIPS, LLP ONE EMBARCADERO CENTER, 30TH FL. COOPER, WHITE & COOPER LLP SAN FRANCISICO, CA CALIFORNIA STREET, 17TH FL. FOR: CITY OF LAGUNA BEACH SAN FRANCISCO, CA FOR: SMALL LEC'S: CALAVERAS TELEPHONE CO., CAL-ORE TELEPHONE CO., DUCOR TELEPHONE CO., FORESTHILL TELEPHONE CO., HAPPY VALLEY TELEPHONE CO., HORNITOS TELEPHONE CO., KERMAN TELEPHONE CO., PINNACLES TELEPHONE CO., THE PONDEROSA TELEPHONE CO., SIERRA TELEPHONE CO., INC. THE SISKIYOU TELEPHONE CO., VOLCANO TELEPHONE CO., WINTERHAVEN TELEPHONE CO.; CONSOLIDATED COMMUNICATIONS OF CALIFORNIA COMPANY (FORMERLY SUREWEST TELEPHONE) EDITORIAL ASSISTANT ANITA TAFF-RICE CALIFORNIA ENERGY MARKETS 425 DIVISADERO ST STE 303 ICOMMLAW SAN FRANCISCO, CA PALOS VERDES, NO. 298 WALNUT CREEK, CA STEPHEN P. BOWEN JAMES WEIL AT LAW DIRECTOR BOWEN LAW GROUP AGLET CONSUMER ALLIANCE 5811 SCARBOROUGH DR., STE. 201 PO BOX 866 OAKLAND, CA NOVATO, CA FOR: THE UTILITY REFORM NETWORK (TURN) C. SUSIE BERLIN KENNETH SWAIN LAW OFFICES OF SUSIE BERLIN MANAGING CONSULTANT - ENERGY 1346 THE ALAMEDA, STE. 7, NO. 141 NAVIGANT CONSULTING, INC. SAN JOSE, CA IRON POINT CIRCLE, STE. 225 FOLSOM, CA 95630

20 CPUC - Service Lists - R Page 7 of 9 11/28/2017 DAN GRIFFITHS JACQUELINE KINNEY FRONTIER COMMUNICATIONS BRAUN BLAISING MCLAUGHLIN & SMITH, P.C K STREET, SUITE L STREET, SUITE 1480 SACRAMENTO, CA SACRAMENTO, CA / MASTACHE LAURA TAYLOR SR. ATTY - OFF. OF GEN. COUNSEL SACRAMENTO MUNICIPAL UTILITY DISTRICT BRAUN BLAISING MCLAUGHLIN & SMITH, P.C S STREET, MS A L STREET, STE SACRAMENTO, CA SACRAMENTO, CA CATHIE ALLEN HEIDEMARIE C. CASWELL REGULATORY AFFAIRS MGR. DIRECTOR-TRANSMISSION & DIST. ASSET PERF PACIFICORP PACIFICORP 825 NE MULTNOMAH ST., STE NE MULTNOMAH, SUITE 1500 PORTLAND, OR PORTLAND, OR State Service DAVID SAPSIS TOBY MCCARTT WILDLAND FIRE SCIENTIST STAFF COUNSEL CAL FIRE (FRAP) CAL FIRE, CA 00000, CA TONY MARINO FADI DAYE OFFICE OF SENATOR JERRY HILL ELECTRIC SAFETY AND RELIABILITY BRANCH, CA West 4th Street Suite 500 Los Angeles, CA KOKO M. TOMASSIAN RAFFY STEPANIAN ELECTRIC SAFETY AND RELIABILITY BRANCH ELECTRIC SAFETY AND RELIABILITY BRANCH 320 West 4th Street Suite West 4th Street Suite 500 Los Angeles, CA Los Angeles, CA CAROLINA CONTRERAS CHARLOTTE TERKEURST OFFICE OF THE SAFETY ADVOCATE ELECTRIC SAFETY AND RELIABILITY BRANCH AREA AREA 505 VAN NESS AVENUE 505 VAN NESS AVENUE SAN FRANCISCO, CA SAN FRANCISCO, CA FOR: OSA CHRISTOPHER MYERS ELECTRICITY PLANNING & POLICY BRANCH ROOM 4104 CODY NAYLOR UTILITY & PAYPHONE ENFORCEMENT BRANCH AREA

21 CPUC - Service Lists - R Page 8 of 9 11/28/ VAN NESS AVENUE 505 VAN NESS AVENUE SAN FRANCISCO, CA SAN FRANCISCO, CA DAVID PECK JUNAID RAHMAN PRESIDENT PICKER RISK ASSESSMENT AND ENFORCEMENT ROOM 4108 AREA 505 VAN NESS AVENUE 505 VAN NESS AVENUE SAN FRANCISCO, CA SAN FRANCISCO, CA KELLY C. LEE MARTIN KURTOVICH ENERGY SAFETY & INFRASTRUCTURE BRANCH RISK ASSESSMENT AND ENFORCEMENT ROOM 4108 AREA 505 VAN NESS AVENUE 505 VAN NESS AVENUE SAN FRANCISCO, CA SAN FRANCISCO, CA MICHAEL MINKUS MINA BOTROS COMMISSIONER GUZMAN ACEVES ENERGY SAFETY & INFRASTRUCTURE BRANCH AREA AREA 505 VAN NESS AVENUE 505 VAN NESS AVENUE SAN FRANCISCO, CA SAN FRANCISCO, CA NATHANIEL SKINNER NILS STANNIK ENERGY SAFETY & INFRASTRUCTURE BRANCH ENERGY SAFETY & INFRASTRUCTURE BRANCH AREA 4-A AREA 505 VAN NESS AVENUE 505 VAN NESS AVENUE SAN FRANCISCO, CA SAN FRANCISCO, CA QUANG PHAM TIMOTHY KENNEY COMMUNICATIONS AND WATER POLICY BRANCH DIVISION OF ADMINISTRATIVE LAW JUDGES AREA 2-D ROOM VAN NESS AVENUE 505 VAN NESS AVENUE SAN FRANCISCO, CA SAN FRANCISCO, CA FOR: ORA VALERIE KAO MATTHEW LEE DEPUTY CHIEF DIVISION OF ADMINISTRATIVE LAW JUDGES CAL-FIRE FIRE PREVENTION ENGINEERING AREA 1131 S STREET 505 VAN NESS AVENUE SACRAMENTO, CA SAN FRANCISCO, CA LAURA MCWILLIAMS STATE SENATOR JERRY HILL STATE CAPITOL SACRAMENTO, CA 95814

22 CPUC - Service Lists - R Page 9 of 9 11/28/2017 TOP OF PAGE BACK TO INDEX OF SERVICE LISTS