BEFORE THE PUBLIC UTILITIES COMMISSION OF THE STATE OF CALIFORNIA

TABLE OF AUTHORITIES Page(s) CALIFORNIA ADMINISTRATIVE REGULATIONS AND ORDERS Title 20, California Code of Regulations (Rules of Practice and Procedure) Rule 14.3...1 COMMISSION DECISIONS D.04-06-016...1 D.15-07-037...2 39390840.2

Pursuant to Rule 14.3, SCE respectfully submits these Reply Comments on the Alternate Proposed Decision of Commissioner Rechtschaffen ( APD ). SCE responds to the Opening Comments of The Utility Reform Network ( TURN ) on the Alternate Proposed Decision ( APD ). TURN urges the Commission to require SCE to submit individual lease route orders under the Master Dark Fiber Lease Agreement ( MLA ) within 10 days of receipt. 1 TURN also argues that the APD should be revised (1) to require SCE to submit lease route orders to the Energy Division (in addition to the Communications Division) and (2) to provide for a review period halfway through the term of the MLA. 2 TURN s arguments are premised on the parties moving forward with dark fiber leases under the MLA. TURN ignores SCE s Motion to Withdraw the Application, filed on July 5, 2018, prior to the issuance of the APD, which makes clear that the Application is moot because SCE and Verizon no longer plan to enter into any individual lease route orders under the MLA. 3 Since the MLA will not be operative, TURN s arguments that the APD should be modified are irrelevant. TURN s arguments further support SCE s primary recommendation: the Commission should allow SCE to withdraw the Application as moot. The fact that TURN seeks changes to the APD (and the PD) to govern an agreement which will not be performed demonstrates that allowing SCE to withdraw the Application is the proper course of action. TURN requests changes to the APD in order to provide guidance for future applications regarding potential safety and competitive impacts of these types of leases. 4 Yet the APD concludes that these issues are more appropriately considered in [an ongoing] industry-wide rulemaking than in the context of an application seeking approval of an individual carrier lease. 5 Thus there are no matters of public concern 6 uniquely at issue with respect to this Application that would warrant denying SCE s Motion and issuing a final decision. Indeed, the Commission recently granted a 1 2 3 4 5 6 Opening Comments of The Utility Reform Network on the Alternate Proposed Decision at 3 (July 25, 2018) ( TURN Opening Comments ). Id. at 4. Motion of Southern California Edison Company (U 338-E) to Withdraw the Application at 3-5 (July 5, 2018) (the Motion ). TURN Opening Comments at 4. APD at 26. D.04-06-016 at 6 (2004). 39390840.2 1

motion to withdraw under similar circumstances where the application became moot after a proposed decision and an alternate proposed decision had been issued. 7 The Commission should grant SCE s motion to withdraw the Application and reject TURN s irrelevant changes to the APD. Respectfully Submitted, FADIA R. KHOURY GLORIA M. ING HENRY WEISSMANN /s/ Henry Weissman By: Henry Weissmann Attorneys for Date: July 30, 2018 7 D.15-07-037 at 9, 23 (2015). 39390840.2 2

BEFORE THE PUBLIC UTILITIES COMMISSION OF THE STATE OF CALIFORNIA In The Matter of the Application of SOUTHERN CALIFORNIA EDISON COMPANY (U 338-E) for Authority to Lease Certain Fiber Optic Cables to CELLCO PARTNERSHIP D/B/A VERIZON WIRELESS under the Master Dark Fiber Lease Agreement Pursuant to Public Utilities Code Section 851. A.17-02-001 (Filed February 3, 2017) 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 REPLY COMMENTS OF SOUTHERN CALIFORNIA EDISON COMPANY (U 338-E) ON THE ALTERNATE PROPOSED DECISION on all parties identified on the attached service list for A.17-02-001. Service was effected by transmitting copies via e-mail to all parties who have provided an e-mail address and by placing copies in sealed envelopes and causing such envelopes to be delivered via UPS overnight delivery to the office of the ALJ or other addressee(s). ALJ Hallie Yacknin California Public Utilities Commission Division of Administrative Law Judges 505 Van Ness Avenue, Room 5108 San Francisco, CA 94102-3214 Executed on July 30, 2018, at Rosemead, California. /s/ Olivia Gutierrez Olivia Gutierrez 2244 Walnut Grove Avenue Post Office Box 800 Rosemead, California 91770

CPUC - Service Lists - A1702001 https://ia.cpuc.ca.gov/servicelists/a1702001_84103.htm Page 1 of 3 7/30/2018 CPUC Home CALIFORNIA PUBLIC UTILITIES COMMISSION Service Lists PROCEEDING: A1702001 - EDISON - TO LEASE CE FILER: LIST NAME: LIST LAST CHANGED: JULY 26, 2018 Download the Comma-delimited File About Comma-delimited Files Back to Service Lists Index Parties GLORIA M. ING DAVID CHENG STAFF ATTORNEY PO BOX 800 THE UTILITY REFORM NETWORK 2244 WALNUT GROVE AVENUE 1620 5TH AVENUE, SUITE 810 ROSEMEAD, CA 91770 SAN DIEGO, CA 92101 FOR: FOR: THE UTILITY REFORM NETWORK (TURN) JESUS G. ROMAN LESLA LEHTONEN ASSIST GEN. COUNSEL SENIOR VP & GENERAL COUNSEL VERIZON WIRELESS, LLC CALIFORNIA CABLE & TELECOM ASSOCIATION 15505 SAND CANYON AVE. D201 1001 K STREET, 2ND FLOOR IRVINE, CA 92618 SACRAMENTO, CA 95814-3832 FOR: CELLCO PARTNERSHIP DBA VERIZON FOR: CALIFORNIA CABLE AND WIRELESS TELECOMMUNICATION ASSOCIATION (CCTA) Information Only CASE COORDINATION PACIFIC GAS AND ELECTRIC COMPANY EMAIL ONLY EMAIL ONLY, CA 00000 MARK A. DINUNZIO DIR. REGULATORY AFFAIRS COX CALIFORNIA TELCOM, LLC SOUTHWEST REGION 1550 W. DEER VALLEY ROAD PHOENIX, AZ 85027 JASIN M. GLASNER EDISON CARRIER SOLUTIONS CASE ADMINISTRATION 8631 RUSH STREET

CPUC - Service Lists - A1702001 https://ia.cpuc.ca.gov/servicelists/a1702001_84103.htm Page 2 of 3 7/30/2018 2 INNOVATION WAY, 1ST FL. ROSEMEAD, CA 91770 POMONA, CA 91768 ESTHER NORTHRUP STEPHEN A. BLUM STATE REGULATORY AFFAIRS TELLUS VENTURE ASSOCIATES COX CALIFORNIA TELCOM, LLC 3138 LAKE DRIVE 5887 COPLEY DRIVE, STE. 300 MARINA, CA 93933 SAN DIEGO, CA 92111 DAWN ANAISCOURT CHRISTINE MAILLOUX ATTORNEY STAFF ATTORNEY THE UTILITY REFORM NETWORK 601 VAN NESS AVENUE 785 MARKET STR., STE. 1400 SAN FRANCISCO, CA 94102 SAN FRANCISCO, CA 94103 CATHERINE BUCKLEY SARAH DEYOUNG REGULATORY AFFAIRS EXECUTIVE DIRECTOR PACIFIC GAS AND ELECTRIC COMPANY CALTEL 77 BEALE STREET, B10A 50 CALIFORNIA ST., STE. 1500 SAN FRANCISCO, CA 94105 SAN FRANCISCO, CA 94111 LISA-MARIE CLARK LEGAL DIVISION 300 Capitol Mall Sacramento, CA 95814 State Service ALEXANDER J. ABRAMSON CHRIS WITTEMAN BROADBAND, POLICY & ANALYSIS BRANCH LEGAL DIVISION AREA ROOM 5028 505 VAN NESS AVENUE 505 VAN NESS AVENUE SAN FRANCISCO, CA 94102-3214 SAN FRANCISCO, CA 94102-3214 ELIZABETH PODOLINSKY GLENN SEMOW PRESIDENT PICKER BROADBAND, POLICY & ANALYSIS BRANCH ROOM 5306 AREA 3-F 505 VAN NESS AVENUE 505 VAN NESS AVENUE SAN FRANCISCO, CA 94102-3214 SAN FRANCISCO, CA 94102-3214 HALLIE YACKNIN MICHAEL MINKUS DIVISION OF ADMINISTRATIVE LAW JUDGES COMMISSIONER GUZMAN ACEVES ROOM 5108 AREA 505 VAN NESS AVENUE 505 VAN NESS AVENUE SAN FRANCISCO, CA 94102-3214 SAN FRANCISCO, CA 94102-3214 MICHAEL MORRIS BROADBAND, POLICY & ANALYSIS BRANCH SEAN A. SIMON COMMISSIONER RECHTSCHAFFEN

CPUC - Service Lists - A1702001 https://ia.cpuc.ca.gov/servicelists/a1702001_84103.htm Page 3 of 3 7/30/2018 ROOM 3-F AREA 4-A 505 VAN NESS AVENUE 505 VAN NESS AVENUE SAN FRANCISCO, CA 94102-3214 SAN FRANCISCO, CA 94102-3214 TRAVIS FOSS ROBERT B. OSBORN LEGAL DIVISION BROADBAND, POLICY & ANALYSIS BRANCH ROOM 5026 770 L Street, Suite 1250 505 VAN NESS AVENUE Sacramento, CA 95814 SAN FRANCISCO, CA 94102-3214 TOP OF PAGE BACK TO INDEX OF SERVICE LISTS