Proposed Calendar Workshops R Proposed Topics

Transcription

1 Proposed Calendar Workshops R Date Proposed Topics January 15 Protocols Dates/Locations Teleconferencing Data Repository GO 95 18B GO165 V, VI & VII (Reporting) Via asap *Establish mapping subgroup (N. Cal. and S. Cal.) *Establish Pole Loading Rule 48 subgroup ( will not fail v. fiber stress ); Rule 44 pole loading subgroup #February 3-5 Final Vote on GO 95 Rule 18B Note-takers 2/3 - Sunesys Straw vote and discussion on GO 165 (CPSD, 2/4 PG&E PG&E) 2/5 - PacifiCorp Inspections, including: Rule 31.2 (CPSD s PRC-3; CIP PRC) Rule 18A (SDG&E; CIPs *February General/Misc. Rule 11 GO III (POU not transmission issues) Rule 31.1 Rule 12.7 Rule 91.5 Check in on mapping, pole-loading and vegetation management March Vegetation Management Rule 35 Rule 37 Appendi E *March Southern CA? Pole Loading Rule 44 Rule 48 Rule 31.2 Intrusive testing (PG&E s PRC) April 7-9 Transmission Issues GO 165 I, IV + General/Misc. overflow *April Southern CA? Data Collection/Mapping Data Collection Rule 165 V Predictive Maps (wind) Rule 18C (Contingency Planning Etreme Wind) May 5 Clearance Rule 38.2 May 6-7 Undergrounding Tariff Rule 20 *May Cost Recovery * Wednesdays added to workshop calendar 6:52:56 PM 2/4/2010

2 Proposed Calendar Workshops R # Added Feb. 5 6:52:56 PM 2/4/2010

3 CIP COALITION PRC 18-A REDLINED VERSION General Order 95 Rule 18 Part A: Resolution of Safety Hazards And General Order 95 Violations Nonconformance (1)(a) Each company (including utilities and CIPs) is responsible for taking appropriate corrective action to remedy Ssafety hhazards and GO 95 violations nonconformance posed by their its facilitiesy. Upon completion of the corrective action, the company records shall show the nature of the work, the date and identity of persons performing the work. Prior to the work being completed, the company shall document the current status of the safety hazard, including whether the safety hazard is located in an Etreme and Very High Fire Threat Zone in Southern California, and shall include a scheduled date of corrective action. These records shall be preserved by the company for at least five years, and shall be of sufficient detail to allow Commission staff during an audit, if any, to determine that the safety hazard has been remedied. The records shall be made available to Commission staff immediately upon request. Additionally, for any work completed after the initial scheduled date of corrective action, the company shall document the reason or reasons that the work was not completed by the original scheduled date of corrective action. For purposes of this rule, Ssafety hhazard means a condition that poses a significant threat to human life or real property., including, but not limited to, the ignition of a wildland or structure fire. Etreme and Very High Fire Threat Zones are defined in the Commission decision issued in Phase I of R Southern California is defined as the following: Santa Barbara, Ventura, San Bernardino, Riverside, Los Angeles, Orange, and San Diego Counties. Companies that have eisting General Order 165 auditable inspection and maintenance programs that are consistent with the purpose of Rule 18 shall continue to follow their General Order 165 programs. [EDITOR S NOTE: MOVED TO SECTION 2 BELOW.] [EDITOR S NOTE: (b) AND (c) MOVED UP FROM BELOW PRIORITY LEVELS] (3) (b) Upon completion of the corrective action under subsection (1)(a) above or subsection (2) below, the company s records shall show the nature of the work, the date, and the identity of persons performing the work. These records should be preserved by the company for at least five years. (4) The company shall prioritize implementing this maintenance plan within the Etreme and Very High Fire Threat Zones of Southern California. With the eception of a safety hazard or violation requiring immediate correction, a company must correct a violation or safety hazard within 30 days of discovering or being notified of a violation or safety hazard, if the violation or safety hazard violates a clearance requirement listed in columns E, F, or G of Table 1 in this General Order, or violates a pole overloading requirement in Rule 44.2 of this General Order, and is located in an Etreme and Very High Fire Threat Zone in Southern California. The company must correct a violation or safety hazard within 30 days if the utility is notified that the violation must be corrected to alleviate a significant safety risk to any utility s employees. (1) (2) All companies shall establish an auditable maintenance program for their facilities and lines. Companies that have eisting General Order 165 auditable inspection and maintenance programs that are consistent with the purpose of Rule 18 shall continue to follow their General

4 Order 165 programs. Further, all companies must include a timeline for corrective actions to be taken following the identification of a ssafety hhazard or nonconformance withof General Orders 95 or 128 on the companies company s facilities. The auditable maintenance program should be developed and implemented based on the following principles.p assigned priorityies levels shall be assigned based on the specifics of the ssafety hhazard or violation nonconformance as related to direct impact and the probability for impact on safety or reliability. using the following factors: Type of facility or equipment; Location; Accessibility; Climate; Direct or potential impact on operations, customers, electrical company workers, communications workers, and the general public; Whether the safety hazard or violation is located in an Etreme or Very High Fire Threat zone. (2) There will be three priority levels, as follows: (a) Level 1: Immediate safety and/or reliability risk with high probability for significant impact. Take action immediately, either by fully repairing the condition, or by temporarily repairing and reclassifying the condition to a lower priority. (b) Level 2: Variable (non-immediate high to low) safety and/or reliability risk. Take action to correct within specified time period (fully repair, or by temporarily repairing and reclassifying the condition to a lower priority). Time period for correction to be determined at the point time of identification by a qualified company representative, but not to eceed 59 months: Overhead: 0-59 months Where communications company actions result in electric utility GO violations, the electric utility s remedial action will be to transmit a single documented notice of identified violations to the communications company for compliance. Where electric company actions result in communications company GO violations, the communications company s remedial action will be to transmit a single documented notice of identified violations to the electric utility for compliance. (c) Level 3:

5 Acceptable safety and/or reliability risk. Take action (re-inspect, re-evaluate, or repair) as appropriate at or before the net detailed inspection. (d3) Eceptions (Levels 2 and 3 only) Correction times may be etended under reasonable circumstances, such as: Third party refusal Customer issue No access Permits required System emergencies (e.g. fires, severe weather conditions)

6 CIP COALITION PRC 18-A REDLINED VERSION General Order 95 Rule 18 For purposes of this rule, Ssafety hhazard means a condition that poses a significant threat to human life or real property. Part A: Resolution of Safety Hazards And General Order 95 Violations Nonconformance (1)(a) Each company (including utilities and CIPs) is responsible for taking appropriate corrective action to remedy Ssafety hhazards and GO 95 violations nonconformance posed by their its facilitiesy. Upon completion of the corrective action, the company records shall show the nature of the work, the date and identity of persons performing the work. Prior to the work being completed, the company shall document the current status of the safety hazard, including whether the safety hazard is located in an Etreme and Very High Fire Threat Zone in Southern California, and shall include a scheduled date of corrective action. These records shall be preserved by the company for at least five years, and shall be of sufficient detail to allow Commission staff during an audit, if any, to determine that the safety hazard has been remedied. The records shall be made available to Commission staff immediately upon request. Additionally, for any work completed after the initial scheduled date of corrective action, the company shall document the reason or reasons that the work was not completed by the original scheduled date of corrective action. For purposes of this rule, Ssafety hhazard means a condition that poses a significant threat to human life or real property., including, but not limited to, the ignition of a wildland or structure fire. Etreme and Very High Fire Threat Zones are defined in the Commission decision issued in Phase I of R Southern California is defined as the following: Santa Barbara, Ventura, San Bernardino, Riverside, Los Angeles, Orange, and San Diego Counties. Companies that have eisting General Order 165 auditable inspection and maintenance programs that are consistent with the purpose of Rule 18 shall continue to follow their General Order 165 programs. [EDITOR S NOTE: MOVED TO SECTION 2 BELOW.] [EDITOR S NOTE: (b) AND (c) MOVED UP FROM BELOW PRIORITY LEVELS] (3) (b) Upon completion of the corrective action under subsection (1)(a) above or subsection (2) below, the company s records shall show, with sufficient detail, the nature of the work, the date, and the identity of persons performing the work. These records should be preserved by the company for at least five years and shall be made available to Commission staff upon 30 days notice. Barbara s Alternative: (4) The company shall prioritize implementing this maintenance plan within the Etreme and Very High Fire Threat Zones of Southern California. With the eception of a safety hazard or violation requiring immediate correction, a company must correct a violation or safety hazard within 30 days of discovering or being notified of a violation or safety hazard, if the violation or safety hazard violates a clearance requirement listed in columns E, F, or G of Table 1 in this General Order, or violates a pole overloading requirement in Rule 44.2 of this General Order, and is located in an Etreme and Very High Fire Threat Zone in Southern California.

7 (1) (2) All companies shall establish an auditable maintenance program for their facilities and lines. Companies that have eisting General Order 165 auditable inspection and maintenance programs that are consistent with the purpose of Rule 18 shall continue to follow their General Order 165 programs. The auditable maintenance program should be developed and implemented based on the following principles.p assigned priorityies levels shall be assigned based on the specifics of the ssafety hhazard or violation nonconformance as related to direct impact and the probability for impact on safety or reliability. using the following factors: Type of facility or equipment; Location; Accessibility; Climate; Direct or potential impact on operations, customers, electrical company workers, communications workers, and the general public; Whether the safety hazard or violation is located in an Etreme or Very High Fire Threat zone. Etreme and Very High Fire Threat Zones are defined in the Commission decision issued in Phase I of R Southern California is defined as the following: Santa Barbara, Ventura, San Bernardino, Riverside, Los Angeles, Orange, and San Diego Counties. The company must correct a violation or safety hazard within 30 days if the utility is notified that the violation must be corrected to alleviate a significant safety risk to any utility s employees. (1) (2) All companies shall establish an auditable maintenance program for their facilities and lines. Companies that have eisting General Order 165 auditable inspection and maintenance programs that are consistent with the purpose of Rule 18 shall continue to follow their General Order 165 programs. Further, all companies must include a timeline for corrective actions to be taken following the identification of a ssafety hhazard or violation nonconformance withof General Orders 95 or 128 on the companies company s facilities. The auditable maintenance program should be developed and implemented based on the following principles.p assigned priorityies levels shall be assigned based on the specifics of the ssafety hhazard or violation nonconformance as related to direct impact and the probability for impact on safety or reliability. using the following factors: Type of facility or equipment; Location; Accessibility; Climate; Direct or potential impact on operations, customers, electrical company workers, communications workers, and the general public; Whether the safety hazard or violation is located in an Etreme or Very High Fire Threat zone.

8 (2) There will be three priority levels, as follows: (a) Level 1: Immediate safety and/or reliability risk with high probability for significant impact. Take action immediately, either by fully repairing the condition, or by temporarily repairing and reclassifying the condition to a lower priority. (b) Level 2: Variable (non-immediate high to low) safety and/or reliability risk. Take action to correct within specified time period (fully repair, or by temporarily repairing and reclassifying the condition to a lower priority). Time period for correction to be determined at the point time of identification by a qualified company representative, but not to eceed 59 months: Overhead: 0-59 months Where communications company actions result in electric utility GO violations, the electric utility s remedial action will be to transmit a single documented notice of identified violations to the communications company for compliance. Where electric company actions result in communications company GO violations, the communications company s remedial action will be to transmit a single documented notice of identified violations to the electric utility for compliance. (c) Level 3: Acceptable safety and/or reliability risk. Take action (re-inspect, re-evaluate, or repair) as appropriate at or before the net detailed inspection. (d3) Eceptions (Levels 2 and 3 only) Correction times may be etended under reasonable circumstances, such as: Third party refusal Customer issue No access Permits required System emergencies (e.g. fires, severe weather conditions) Blue = no opposition Yellow = under discussion

9 Green = parking lot

10 PRC-3 Original Version 31.2 Inspection of Lines Lines shall be inspected frequently and thoroughly for the purpose of insuring that they are in good condition so as to conform with these rules. Lines temporarily out of service shall be inspected and maintained in such condition as not to create a hazard Inspection of Lines Strikeout and Underlined Version Lines shall be inspected frequently and thoroughly for the purpose of insuring that they are in good condition so as to conform with these rules. Lines temporarily out of service shall be inspected and maintained in such condition as not to create a hazard. A. Communications Lines (See Rule.): (1) Patrols Inspections (See Rule.) shall be performed on all of overhead communication lines installed on joint use poles with electric distribution or transmission facilities, as well as those facilities that are one pole length away from joint use poles with electric distribution or transmission lines that are located in an Etreme and Very High Fire Hazard zones, as identified in Cal Fire s Fire and Resource Assessment Program Fire Threat Map once each calendar year. Note: The boundaries of the Fire Threat map shall be broadly construed, and CIPs should use their own epertise and judgment to determine if local conditions require them to adjust the boundaries of the map. (2) Detail Inspection (see Rule.) shall be performed on all of overhead communication lines installed on joint use poles with electric distribution or transmission facilities, as well as those facilities that are one pole length away from joint use poles with electric distribution or transmission lines once each 10 calendar years.

11 B. Electric Lines: shall be inspected in compliance with the minimum intervals given in General Order Inspection of Lines Final Version Lines shall be inspected frequently and thoroughly for the purpose of insuring that they are in good condition so as to conform with these rules. Lines temporarily out of service shall be inspected and maintained in such condition as not to create a hazard. A. Communications Lines (See Rule.): (1) Patrols Inspections (See Rule.) shall be performed on all of overhead communication lines installed on joint use poles with electric distribution or transmission facilities, as well as those facilities that are one pole length away from joint use poles with electric distribution or transmission lines that are located in an Etreme and Very High Fire Hazard zones, as identified in Cal Fire s Fire and Resource Assessment Program Fire Threat Map once each calendar year. Note: The boundaries of the Fire Threat map shall be broadly construed, and CIPs should use their own epertise and judgment to determine if local conditions require them to adjust the boundaries of the map. (2) Detail Inspection (see Rule.) shall be performed on all of overhead communication lines installed on joint use poles with electric distribution or transmission facilities, as well as those facilities that are one pole length away from joint use poles with electric distribution or transmission lines once each 10 calendar years. B. Electric Lines: shall be inspected in compliance with the minimum intervals given in General Order 165.

12 Corresponding New Rules. Communications Infrastructure Provider or CIP is defined as any entity that has attached facilities to an electric utility s poles for the purpose of providing communications services.. Patrol inspection is a simple visual inspection, of applicable communications infrastructure equipment and structures that is designed to identify obvious structural problems and hazards. Additionally, may be carried out in the course of other company business.. Detail inspection shall be defined as one where individual pieces of equipment and structures are carefully eamined, visually and through use of routine diagnostic test, as appropriate, and (if practical and if useful information can be so gathered) opened, and the condition of each rated and recorded.

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14 FIRE SAFETY OIR WORKSHOPS Voting Template DATE: February 3, 2010 RULE: General Order 165, New Section 7 VII. Changes to Requirements Herein If, in a particular case, eemption from or modification of any of the requirements herein is desired, the Commission will consider a request for such eemption or modification when accompanied by a full statement of conditions eisting and the reasons why such eemption or modification is asked and is believed to be justifiable. It is to be understood that, unless otherwise ordered, any eemption or modification so granted shall be limited to the particular case covered by the request. Deleted: n Deleted: application Deleted: application PARTIES AT&T CAISO CALTEL CCTA CFBF CMUA COMCAST CO CPSD CTIA DRA ETENET FACILITIES MANAGEMENT IBEW LA COUNTY LADWP MUSSEY GRADE OSMOSE UTILITIES SERVICES NCPA NETG PACIFICORP PG&E SCE SDG&E SIERRA PACIFIC SMALL LECS SMUD SPRINT NETEL NOT PRESENT YES NEUTRAL NO 1

15 SUNESYS SURE WEST TIMEWARNER CABLE T-MOBILE TURN TW TELECOM VERIZON DAVEY TREE SCRIBE: Josh Davidson 2

16 FIRE SAFETY OIR WORKSHOPS Voting Template DATE: February 3, 2010 RULE: General Order 165 Sections 4, 5 and 6 (with bracketed topics for future discussion) Appendi A Public Utilities Commission of the State of California Inspection Cycles for Electric Distribution Facilities Adopted March 31, 1997 Effective March 1, 1997 (D in I and R ) I. Purpose The purpose of this General Order is to establish minimum requirements for electric distribution facilities, regarding inspection (including maimum allowable inspection cycle lengths), condition rating, scheduling and performance of corrective action, record-keeping, and reporting, in order to ensure safe and high-quality electrical service, and to implement the provisions of Section 364 of Assembly Bill 1890, Chapter 854, Statutes of II. Applicability As of March 31, 1997, this General Order applies to Pacific Gas and Electric Company, PacifiCorp, San Diego Gas and Electric Company, Sierra Pacific Power Company, and Southern California Edison Company. The requirements of this order are in addition to the requirements imposed upon utilities under General Orders 95 and 128 to maintain a safe and reliable electric system. Nothing in this General Order relieves any utility from any requirements or obligations that it has under General Orders 95 and 128. III. Definitions For the purpose of this General Order, A "Urban" shall be defined as those areas with a population of more than 1,000 persons per square mile as determined by the United States Bureau of the Census. B "Rural" shall be defined as those areas with a population of less than 1,000 persons per square mile as determined by the United States Bureau of the Census. C "Patrol" shall be defined as a simple visual inspection, of applicable utility equipment and structures, that is designed to identify obvious structural problems and hazards. Patrols may be carried out in the course of other company business. 1

17 D "Detailed" inspection shall be defined as one where individual pieces of equipment and structures are carefully eamined, visually and through use of routine diagnostic test, as appropriate, and (if practical and if useful information can be so gathered) opened, and the condition of each rated and recorded. E "Intrusive" inspection is defined as one involving movement of soil, taking samples for analysis, and/or using more sophisticated diagnostic tools beyond visual inspections or instrument reading. F "Corrective Action" shall be defined as maintenance, repair, or replacement of utility equipment and structures so that they function properly and safely. IV. Standards for Inspection Record Keeping, and Reporting Each utility subject to this General Order shall conduct inspections of its [ electric facilities], as necessary, to assure reliable, high-quality, and safe operation, but in no case may the period between inspections (measured in years) eceed the time specified in the attached table.table 1. Deleted: distribution Formatted: Highlight Formatted: Highlight V. Record-keeping Each utility subject to this General Order shall submit to the Commission by no later than July 1, 1997, compliance plans for the inspections and record-keeping required by this order. These compliance plans will include the proposed forms and formats for annual reports and source records, as well as the utility's plans for the types of inspections and equipment to be inspected during the coming year. For detailed and intrusive inspections, schedules should be detailed enough (in terms of the months of inspection and the circuit, area, or equipment to be inspected) to allow staff to confirm that schedule inspections are proceeding as planned. For patrol inspections, companies should eplain how all required facilities will be covered during the year. Energy Division or any successor staff divisions may prescribe changes relating to data, definitions, reporting and record-keeping formats and forms when and as necessary. Each utility subject to this General Order shall submit an annual report detailing its compliance with this General Order under penalty of perjury. The first report required under this section shall be filed with the Commission by no later than July 1, Each utility shall file subsequent annual reports for every following year by no later than July 1. The report shall identify the number of facilities, by type which have been inspected during the previous period. It shall identify those facilities which were scheduled for inspection but which were not inspected according to schedule and shall eplain why the inspections were not conducted, and a date certain by which the required inspection will occur. The report shall also present the total and percentage breakdown of equipment rated at each condition rating level, including that equipment determined to be in need of corrective action. Where corrective action was scheduled during the reporting period, the report will present the total and percentage of equipment which was and was not corrected during the reporting period. For the latter, an eplanation will be provided, including a date certain by which required corrective action will occur. The report will also present totals and the percentage of equipment in need of corrective action, but with a 2

18 scheduled date beyond the reporting period, classified by the amount of time remaining before the scheduled action. All of the above information shall be presented for each type of facility identified in the attached table and shall be aggregated by district. The companyutility shall maintain records of inspection activities which shall be made available to parties or pursuant to Commission rules upon 30 days notice. Commission staff shall be permitted to inspect such records consistent with Public Utilities Code Section 314 (a). For all inspections, within a reasonable period, company records shall specify the circuit, area, facility or equipment inspected, the name of the inspector, the date of the inspection, and any problems (or items requiring corrective action) identified during each inspection, as well as the scheduled date of corrective action. For detailed and intrusive inspections, companies shall also rate the condition of inspected equipment. Upon completion of corrective action, company records will show the nature of the work, the date, and the identity of persons performing the work. VI. Reporting By July 1 st each utility subject to this General Order shall submit an annual report for the previous year under penalty of perjury. The report shall list four categorical types of inspections: Patrols, Overhead Detailed, Underground Detailed and Wood Pole Intrusive. The report shall denote the total units of work by inspection type for the reporting period and the number of outstanding (not completed) inspections within the same reporting period for each of the four categories. Deleted: CPSD or any successor staff divisions may prescribe changes relating to data, definitions, reporting and recordkeeping formats and forms when and as necessary. Sample Report Template: Type of Inspections (1) Due (2) Outstanding (3) Patrols OH Detailed UG Detailed Wood Pole Intrusive Notes: (1) Each utility will define their reporting unit basis (e.g., circuit, grid, facility / equipment). (2) Total inspections due in the reporting period. (Does not include outstanding inspections from prior years.) (3) Total inspections required that were not completed in the reporting period. (Does not include outstanding inspections from prior years.) Dated March 31, 1997, at San Francisco, California /s/ Wesley M. Franklin /s/ Paul Clanon Wesley M. Franlin Paul Clanon Eecutive Director 3

19 (This space Intentionally Left Blank) Appendi A Table 1 Electric Company System Inspection Cycles (Maimum Intervals in Years) Patrol Detailed Intrusive Urban Rural Urban Rural Urban Rural Transformers Overhead 1 2¹ 5 5 Underground Padmounted Switching/Protective Devices Overhead 1 2¹ 5 5 Underground Padmounted Regulators/Capacitors Overhead Underground 1 2¹ Padmounted Overhead Conductors and Cables 1 2¹ 5 5 Streetlighting 1 2 Wood Poles under 15 years 1 2 Wood Poles over 15 years which have not been subject to intrusive inspection Wood Poles which passed intrusive inspection (1) Patrol inspections in rural areas shall be increased to once per year in Etreme and Very High Fire Threat Zones in the following counties: Santa Barbara, Ventura, Los Angeles, San Bernardino, Orange, Riverside, and San Diego. Etreme and Very High Fire Threat Zones are defined by California Department of Forestry and Fire Protection s Fire and Resource Assessment Program (FRAP) Fire Threat Map. The FRAP Fire Threat Map is to be used to establish approimate boundaries and Utilities should use their own epertise and judgment to determine if local conditions require them to adjust the boundaries of the map. 4

20 Final Proposed Rule or Rule Change: I. Purpose Appendi A Public Utilities Commission of the State of California Inspection Cycles for Electric Distribution Facilities The purpose of this General Order is to establish minimum requirements for electric distribution facilities, regarding inspection (including maimum allowable inspection cycle lengths), condition rating, scheduling and performance of corrective action, record-keeping, and reporting, in order to ensure safe and high-quality electrical service, and to implement the provisions of Section 364 of Assembly Bill 1890, Chapter 854, Statutes of II. Applicability As of March 31, 1997, this General Order applies to Pacific Gas and Electric Company, PacifiCorp, San Diego Gas and Electric Company, Sierra Pacific Power Company, and Southern California Edison Company. The requirements of this order are in addition to the requirements imposed upon utilities under General Orders 95 and 128 to maintain a safe and reliable electric system. Nothing in this General Order relieves any utility from any requirements or obligations that it has under General Orders 95 and 128. III. Definitions For the purpose of this General Order, A Urban shall be defined as those areas with a population of more than 1,000 persons per square mile as determined by the United States Bureau of the Census. B Rural shall be defined as those areas with a population of less than 1,000 persons per square mile as determined by the United States Bureau of the Census. C Patrol shall be defined as a simple visual inspection, of applicable utility equipment and structures, that is designed to identify obvious structural problems and hazards. Patrols may be carried out in the course of other company business. D Detailed inspection shall be defined as one where individual pieces of equipment and structures are carefully eamined, visually and through use of routine diagnostic test, as appropriate, and (if practical and if useful information can be so gathered) opened, and the condition of each rated and recorded. 5

21 E Intrusive inspection is defined as one involving movement of soil, taking samples for analysis, and/or using more sophisticated diagnostic tools beyond visual inspections or instrument reading. F Corrective Action shall be defined as maintenance, repair, or replacement of utility equipment and structures so that they function properly and safely. IV. Standards for Inspection Each utility subject to this General Order shall conduct inspections of its distribution facilities, as necessary, to assure reliable, high quality, and safe operation, but in no case may the period between inspections (measured in years) eceed the time specified in Table 1. V. Record-keeping The utility shall maintain records of inspection activities which shall be made available to parties or pursuant to Commission rules upon 30 days notice. Commission staff shall be permitted to inspect such records consistent with Public Utilities Code Section 314 (a). For all inspections records shall specify the circuit, area, facility or equipment inspected, the inspector, the date of the inspection, and any problems (or items requiring corrective action) identified during each inspection, as well as the scheduled date of corrective action. CPSD or any successor staff divisions may prescribe changes relating to data, definitions, reporting and record-keeping formats and forms when and as necessary. VI. Reporting By July 1 st each utility subject to this General Order shall submit an annual report for the previous year under penalty of perjury. The report shall list four categorical types of inspections: Patrols, Overhead Detailed, Underground Detailed and Wood Pole Intrusive. The report shall denote the total units of work by inspection type for the reporting period and the number of outstanding (not completed) inspections within the same reporting period for each of the four categories. Sample Report Template: Type of Inspections (1) Due (2) Outstanding (3) Patrols OH Detailed UG Detailed Wood Pole Intrusive Notes: (1) Each utility will define their reporting unit basis (e.g., circuit, grid, facility / equipment). (2) Total inspections due in the reporting period. (Does not include outstanding inspections from prior years.) 6

22 (3) Total inspections required that were not completed in the reporting period. (Does not include outstanding inspections from prior years.) Appendi A Table 1 Electric Company System Inspection Cycles (Maimum Intervals in Years) Patrol Detailed Intrusive Urban Rural Urban Rural Urban Rural Transformers Overhead 1 2¹ 5 5 Underground Padmounted Switching/Protective Devices Overhead 1 2¹ 5 5 Underground Padmounted Regulators/Capacitors Overhead Underground 1 2¹ Padmounted Overhead Conductors and Cables 1 2¹ 5 5 Streetlighting 1 2 Wood Poles under 15 years 1 2 Wood Poles over 15 years which have not been subject to intrusive inspection Wood Poles which passed intrusive inspection (1) Patrol inspections in rural areas shall be increased to once per year in Etreme and Very High Fire Threat Zones in the following counties: Santa Barbara, Ventura, Los Angeles, San Bernardino, Orange, Riverside, and San Diego. Etreme and Very High Fire Threat Zones are defined by California Department of Forestry and Fire Protection s Fire and Resource Assessment Program (FRAP) Fire Threat Map. The FRAP Fire Threat Map is to be used to establish approimate boundaries and Utilities should use their own epertise and judgment to determine if local conditions require them to adjust the boundaries of the map. 7

23 PARTIES AT&T CAISO CALTEL CCTA CFBF CMUA COMCAST CO CPSD CTIA DRA ETENET FACILITIES MANAGEMENT IBEW LA COUNTY LADWP MUSSEY GRADE OSMOSE UTILITIES SERVICES NCPA NETG PACIFICORP PG&E SCE SDG&E SIERRA PACIFIC SMALL LECS SMUD SPRINT NETEL SUNESYS SURE WEST TIMEWARNER CABLE T-MOBILE TURN TW TELECOM VERIZON DAVEY TREE Scribe: Josh Davidson NOT PRESENT YES NEUTRAL NO 8

24 NOTES WORKSHOP FEBRUARY 3, 2010 HOUSEKEEPING / PROCESS MATTERS Updated Voting Template Scoping memo sets party participation and voting rules Data repository update Rules Committee can post documents to website. Sign-in sheet posted on website. SCE volunteered to host southern California workshop meeting; looking for April Southern California host Proposal by CIP Coalition to take up Rule 18-A before Rule 31.2 to allow documentation issues to be discussed in sequence tentatively approved depending on timing and staffing Discussion of Proposed Revision to Protocol Rules and 6.4. Subgroup to consider changes and develop proposal RULE 18-B Discussion of CPSD s and other parties proposed changes to Rule 18-B distributed after last workshop. Parties discussed difficulties in always knowing and keeping updated on the identities of other joint pole owners tenants, costs of procuring data, and whether requirement to know identities of other joint pole owners tenants furthers the purposes of the rule. CPSD to discuss revisions with upper management this afternoon. Rationale in workshop report to inform interpretation of Rule 18-B needs to be attached to decision. PROTOCOL DISCUSSION Discussion of methods of resolving MAPs; original proposal to amend 6.4 withdrawn; change to 6.17 approved. GO 165 Discussion of General Order 165 IV, V, and VI. Straw vote on 4 of General Order 165 passes; item should be placed on confirmation agenda for net workshop meeting (subject to discussion on bracketed language). Straw vote on 5, as modified during discussions, also passes and should be placed on confirmation agenda for net workshop. Section 6 of GO 165 straw vote passes. A formal vote was taken on Sections 4, 5, and 6. PG&E presented the Joint Electrics proposal to add a new section (Section 7) to General Order 165 regarding requests for eemptions or modifications to General Order 165 s rules and requirements. Parties discussed also modifying General Order 95 Rule 15.1 and General Order 128 Rule 15.1 (among others) to reflect the choice of words used in the revised General Order 165 Section 7. A formal vote was taken on the Joint Electrics proposed Section 7. RULE 18-A

25 Parties net turned to consideration of the CIP Coalition s and SDG&E s proposals to modify General Order 95 Rule 18-A. Jesus and Greg made presentations. Discussion of whether Rule 18-A is applicable to the Electrics. PG&E, SDG&E assert that 18-A does not apply to them because they do have General Order 165 auditable inspection and maintenance programs that are consistent with the purpose of Rule 18. Some discussion about whether some of the rules/tables referenced in Rule 18-A apply to communication facilities CPSD notes that if lashing wire went up would cite a Rule 38 violation and if it went down would cite a Rule 31 violation. RULE 18-B DISCUSSION RESUMES CPSD brings an Alternative for last sentence: Each pole owner is responsible for knowing the identity of all other joint pole owners on its poles. Each pole owner is responsible for knowing the identity of each authorized entity with attachments to its portion of the pole and shall be able to determine the identity of all authorized entities attached to that pole in order to meet the notification requirements of this rule. Lengthy discussion ensued on purpose of and concerns regarding this requirement. Needing to know the identity still creates heartburn for some of the utilities. This information may not be in files they have; they may have to consult with third parties to obtain -- e.g. with JPA to identify all other JPA owners and with other owners to get information regarding their tenants. Concerns epressed regarding potential liability/fines for not knowing identity of other pole owners / tenants even if required safety violation notification under Rule 18B is made. Parties also raised concerns about liability if 3 rd party owners do not promptly provide other tenant identities. Concern regarding definition of pole owner. It must be some management level person. CPSD does not disagree; no need for a person in field to know. Concern regarding retroactive implementation: Does Rule 12.3 apply? CPSD: 12.3 is limited to construction; thinks requirement would apply to all poles. Further probing at underlying safety rationale/need for information. CPSD wants utilities to have access to all owner/tenant information through JPA or other agreements as quickly as possible to prevent delay in notification. CPSD wants to make sure that the systems are in place so the information regarding pole attachers is available to folks who need it because if there is a safety hazard it will be important. Some discussion of whether CPSD would be willing to include the last sentence(s) in a Note as opposed to a rule. CPSD management would prefer an enforceable obligation but may be open to a Note depending on the language Does putting it into a decision rather than a rule help? Not if a requirement. LADWP concerned that in order to know a company must have ownership information in documents / database in company s control which must be up to date at all times. Practically very challenging. A number of alternatives for language for the last sentence were discussed including the following: Note no consensus was achieved on any of these alternatives CPSD s 2/2 MAP: It is the responsibility of each pole owner to know the identity of each authorized entity with attachments on its pole. Deleted: using or maintaining equipment

26 CIP/ELECTRICS: Note: A pole owner is epected to be able to determine the identity of all authorized entities that have equipment on its respective portion of a pole. CPSD Alternative 1: Each pole owner is responsible for knowing the identity of all other joint pole owners on its poles. Each pole owner is responsible for knowing the identity of each authorized entity with attachments to its portion of the pole and shall be able to determine the identity of all authorized entities attached to that pole in order to meet the notification requirements of this rule. CPSD Alternative 2: Each pole owner is responsible for knowing the identity of all other joint pole owners on its poles. Each pole owner is responsible for knowing the identity of each authorized entity with attachments to its portion of the pole and shall provide that information to other joint pole owners upon request [promptly / in order to meet the notification requirements of this rule]. CPSD Alternative 3: Each pole owner is responsible for knowing [determining within days] the identity of all other joint pole owners on its poles. Each pole owner is responsible for knowing [determining within days??] the identity of each authorized entity with attachments to its portion of the pole. Note: Each pole owner shall be able to determine the identity of all authorized entities attached to that pole in order to meet the notification requirements of this rule. Landis/Jim Proposal: Pole owner must provide the identity of violating attachee in [10] days to requesting party. LA County: Each pole owner is responsible for knowing the identity of all other joint pole owners on its poles. Each pole owner is responsible for knowing the identity of each authorized entity with attachments to its portion of the pole. In the end the parties agreed to continue working on the last sentence of Rule 18-B and to take a vote on the remaining portions of Rule 18-B on which there appeared to be agreement. WRAP UP Tomorrow: start with questions regarding 18A PRCs Jerome requested a copy of Greg s presentation

27 lhj2 Page 1 2/10/2010 Notes for 2/4: Suggestion to organize discussion by topics, rather than by PRC 18A is broader than just maintenance, so can be discussed holistically Proposal from CMUA that parties address Rule 12 and GO165 II (POU not transmission issues) in briefs, and take them off agenda. No one opposed this proposal. Background discussion perhaps start with objective of inspection and maintenance program o CPSD s objective of Rule 18A wants to be sure conditions are found and fied. Inspections to find violations. Once find violations, what do you need to do. 18A is there to be sure the work is done, and to be auditable. CPSD understands conditions need to be prioritized. o Discussion around eemption from Rule 18A for entities who have GO 165 inspection programs. Rule 18A has 30 day requirement that utilities are not currently required to include in their GO 165 programs. o Fleibility around correction of maintenance conditions is that something that can be considered? o There may be disagreement on fleibility issue 18A was put in place to address problem that some entities didn t have any inspection/maintenance program in place. 18A was intended to remedy that problem. CPSD considers Rule 18A provides adequate fleibility. Rule 18A applies to all entities, and the eemption 4 applies to southern California. o Fleibility issue is around fiing conditions, but there is no fleibility re: inspection cycles. o Definition of Safety Hazard was discussed. CIP s consider definition to refer to Level 1 conditions. Worked through CIP Coalition proposal o Violation changed to nonconformance for Rule 18A purposes. o Discussion of D how the Commission viewed the state of utilities compliance with the Commission s rules. o Suggestion to put issues of violation vs. nonconformance in parking lot and address it after conferring to D o Should also consider other provisions in GO 95 that refer to nonconformances. o Will come back to Prior to work language in first paragraph. [Prior to the work being completed, the company shall document the current status of the safety hazard] o CPSD is o.k. with taking out the reference to the Fire Threat Zone language o Parking lot item inspection component of identification of Fire Threat Zone in S. California SDG&E doesn t want to take out language. Need to discuss further. o Fire Threat Zones needs to be revisited with Mapping working group o Discussed sufficient detail language in rule need to understand what is required, so that parties know will be held to.

28 lhj2 Page 2 2/10/2010 o Discussed provision of records to CPSD staff o Discussed interpretation of what is required regarding scheduling corrective actions within the Levels as set forth in Rule 18A o CPSD will consider internal standards, and will hold company to that internal standard, but understands that deviations will happen they apply a reasonable approach o Request for each electric utility to describe program, how deal with scheduling corrective actions, and what they do if they miss a scheduled date. o Each IOU prefers having broad requirements and being held to their own programs by CPSD o Rule 18A was in part to provide guidance to the CIPs to develop their programs o Discussed at length whether section 4 of Rule 18A should be retained. Is it intended to address safety hazards or something a little less? Does having a 30-day requirement make sense when taking a programmatic approach? o Perhaps we should apply the factors for how to evaluate a condition (in section 1 originally) rather than apply a 30 day requirement regardless of these factors (which include climate, accessibility, location, etc.)

29 Proposed Rule or Rule Change Party: SDG&E PRC No. 4 Short Title: GO 95, Rule 18 A Proposed Rule Change Rationale: The proposed rule change would add the wire-to-wire clearances in Rule 38 Table 2 Cases 8-13 to Rule 18 A Part 4, such that violations of these wire-to-wire clearance requirements would need to be corrected within 30 days, just like violations of the ground clearance requirements already referenced in Rule 18 A Part 4. Violations of wire-to-wire clearance requirements have at least as much potential to create fire safety hazards as violations of ground clearance requirements. Both types of clearance violations should be repaired within 30 days. The term Rule 37 is added to the eisting ground clearance requirement reference to clarify which Table 1 is being referenced. Original, Strikeout/Underline, and Final Proposed Rule Change: Original Rule with Strikeout / Underline General Order 95 Rule 18 A: Resolution of Safety Hazards and General Order 95 Violations (4) The company shall prioritize implementing this maintenance plan within the Etreme and Very High Fire Threat Zones of Southern California. With the eception of a safety hazard or violation requiring immediate correction, a company must correct a violation or safety hazard within 30 days of discovering or being notified of a violation or safety hazard, if the violation or safety hazard violates a clearance requirement listed in columns E, F, or G of Rule 37 Table 1 and Rule 38 Table 2 Cases 8 13 in this General Order, or violates a pole overloading requirement in Rule 44.2 of this General Order, and is located in an Etreme and Very High Fire Threat Zone in Southern California. Final Proposed Rule or Rule Change (4) The company shall prioritize implementing this maintenance plan within the Etreme and Very High Fire Threat Zones of Southern California. With the eception of a safety hazard or violation requiring immediate correction, a company must correct a violation or safety hazard within 30 days of discovering or being notified of a violation or safety hazard, if the violation or safety hazard violates a clearance requirement listed in columns E, F, or G of Rule 37 Table 1 and Rule 38 Table 2 Cases 8 13 in this General Order, or violates a pole overloading requirement in Rule 44.2 of this General Order, and is located in an Etreme and Very High Fire Threat Zone in Southern California. In Scope: Phase 2 Scoping Memo Issue 4 (mitigating hazards posed by high wind speeds)

30 Justifications: Item: 1. The specific electric utilities, CIPs, and others affected by the proposed rule. 2. Why the PRC is within the scope of Phase New and/or revised tet for the affected General Order(s), if applicable. 4. The specific fire hazard(s) addressed by the PRC and/or other reason(s) for the PRC. 5. How the proposed rule reduces or otherwise addresses the identified fire hazard(s) and/or achieves other intended purposes. 6. The anticipated costs and benefits of the PRC. 7. Whether and how costs will be recovered from customers. 8. Whether and how costs will be shared among electric utilities, CIPs, and others. 9. Why it is in the public interest to adopt the PRC. 10. If the PRC applies to electric transmission, why the PRC does not duplicate or conflict with other federal or state regulations. 11. Whether the adoption and implementation of the PRC is eempt from the California Environmental Quality Act (CEQA) and/or the National Environmental Policy Act (NEPA) and, if so, why. If not, what steps need to occur under CEQA or NEPA before the PRC can be adopted Justification: Electric utilities and communication entities subject to CPUC jurisdiction. See above. See above. Fire hazards caused by wire-to-wire clearance violations. The proposed rule would require correction of a wire-to-wire clearance violation or safety hazard within 30 days of discovering or being notified of such violation or safety hazard. The only anticipated costs would be the additional costs, if any, of correcting wire-to-wire clearance violations more quickly than might otherwise be the case. The benefits would be an increase in fire safety as a result of faster corrections of wire-towire clearance violations. N/A The additional costs, if any, of correcting wire-to-wire clearance violations more quickly would be incurred by the entity responsible for making the correction. See rationale. N/A Nothing in this proposal will trigger CEQA or NEPA review