Appendix A: Proposed Regulations

Appendix A shows the proposed revisions and additions to General Orders 95 and 165 with strikeout and underline.

Consensus Proposal 1 re: GO 95, Rule 18A

Proposed Revisions to Current Rule 18A Shown with Strikeout and Underline

18 Reporting and Resolution of Safety Hazards Discovered by Utilities A. Resolution of Safety Hazards And General Order 95 Nonconformances Violations Each company (including utilities and CIPs) is responsible for taking appropriate corrective action to remedy safety hazards and GO 95 nonconformances violations posed by their facility. 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 Extreme 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, "safety hazard" means a condition that poses a significant threat to life or property, including, but not limited to, the ignition of a wildland or structure fire. "Extreme and Very High Fire Threat Zones" are defined in the Commission decision issued in Phase I of R.08-11-005. "Southern California" is defined as the following: Santa Barbara, Ventura, San Bernardino, Riverside, Los Angeles, Orange, and San Diego Counties. Companies that have existing 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. All companies shall establish an auditable maintenance program for their facilities and lines. Further, all companies must include a timeline for corrective actions to be taken following the identification of a safety hazard or nonconformance violation of General Orders 95 or 128 on the companies' facilities. The auditable maintenance program should be developed and implemented based on the following principles. (1) Priorities shall be assigned based on the specifics of the safety hazard or nonconformance violation 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 nonconformance violation is located in an Extreme or Very High Fire Threat zone. (2) There will be three priority levels, as follows: (a) Level 1: o Immediate safety and/or reliability risk with high probability for significant impact. o Take action immediately, either by fully repairing the condition, or by temporarily repairing and reclassifying the condition to a lower priority. (b) Level 2: o Variable (non-immediate high to low) safety and/or reliability risk. o Take action to correct within specified time period (fully repair, or by temporarily repairing and reclassifying the condition to a lower priority). o Time period for correction to be determined at the point of identification by a qualified company representative: Overhead: 0-59 months o Where communications company actions result in electric utility GO nonconformances violations, the electric utility's remedial action will be to transmit a single documented notice of identified nonconformances violations to the communications company for compliance. (c) Level 3: o Acceptable safety and/or reliability risk. o Take action (re-inspect, re-evaluate, or repair) at or before the next detailed inspection. (d) Exceptions (Levels 2 and 3 only) - Correction times may be extended under reasonable circumstances, such as: o Third party refusal o Customer issue o No access o Permits required o System emergencies (e.g. fires, severe weather conditions) (3) Upon completion of the corrective action, 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 Extreme and Very High Fire Threat Zones of Southern California. With the exception of a safety hazard or nonconformance violation requiring immediate correction, a company must correct a nonconformance violation or safety hazard within 30 days of discovering or being notified of a nonconformance violation or safety hazard, if the nonconformance violation or safety hazard fails to fully comply with 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 44.3 of this General Order, and is located in an Extreme and Very High Fire Threat Zone in Southern California. The company must correct a nonconformance violation or safety hazard within 30 days if the utility is notified that the nonconformance violation must be corrected to alleviate a significant safety risk to any utility's employees.

Consensus Proposal 2 re: GO 95, Rule 18B

Proposed Revisions to Current Rule 18B Shown with Strikeout and Underline

B. Notification of Safety Hazards If a company, while performing inspections of inspecting its facilities, discovers a safety hazard(s) on or near a communications facility, or transmission or distribution electric facility involving another company, the inspecting company shall notify the other company and/or facility owner of such safety hazard(s) no later than 10 business days after the discovery. The inspecting company shall also provide a copy of the notice to the pole owner(s). The inspecting company shall include in such notice whether the safety hazard which requires corrective action is located in a designated Extreme and Very High Fire Threat Zone in Southern California. To the extent the inspecting company cannot determine the facility owner/operator of other company, it shall contact the pole owner(s), who shall be responsible for promptly notifying the company owning/operating the facility with the safety hazard(s), normally not to exceed five business days after being notified of the safety hazard. The notification shall be in writing documented and such documentation must be preserved by all parties for at least five years. It is the responsibility of each pole owner to know the identity of each entity using or maintaining equipment on its pole. Note: Each pole owner must be able to determine all other pole owners on poles it owns. Each pole owner must be able to determine all authorized entities that attach equipment on its portion of a pole.

Consensus Proposal 3 re: GO 95, Rule 35

Proposed Revisions to Current Rule 35 Shown with Strikeout and Underline

Where overhead conductors traverse trees and vegetation, safety and reliability of service demand that certain vegetation management activities be performed in order to establish necessary and reasonable clearances. The minimum clearances set forth in Table 1, Cases 13 and 14, measured between line conductors and vegetation under normal conditions shall be maintained. (Also see Appendix E for tree trimming guidelines.) These requirements apply to all overhead electrical supply and communication facilities that are covered by this Order, including facilities on lands owned and maintained by California state and local agencies. When a utility supply or communication company has actual knowledge, obtained either through normal operating practices or notification to the utility company, of that dead, rotten or and diseased trees or dead, rotten or and diseased portions there of otherwise healthy trees that overhang or lean toward and may fall into a span of nearby supply or communication lines, said trees or portions thereof should be removed. Communication and electric supply circuits, energized at 750 volts or less, including their service drops, should be kept clear of vegetation in new construction and when circuits are reconstructed or repaired, whenever practicable. When a utility supply or communication company has actual knowledge, obtained either through normal operating practices or notification to the utility company, that any its circuit energized at 750 volts or less shows strain or evidences abrasion from vegetation contact, the condition shall be corrected by reducing conductor tension, rearranging or replacing the conductor, pruning the vegetation, or placing mechanical protection on the conductor(s). For the purpose of this rule, abrasion is defined as damage to the insulation resulting from the friction between the vegetation and conductor. Scuffing or polishing of the insulation or covering is not considered abrasion. Strain is present when deflection causes additional tension beyond the allowable tension of the span vegetation contact significantly compromises the structural integrity of supply or communication facilities. Contact between vegetation and conductors, in and of itself, does not constitute a violation of the rule.

Consensus Proposal 4 re: GO 95, Rule 37, Table 1, Case 14 and Footnotes (fff) - (jjj)

Proposed Revisions to Current Rule Shown with Strikeout and Underline

Consensus Proposal 5 re: GO 95, Rules 23, 44.1, 44.2, and 44.3

Proposed Revisions to Current Rules Shown with Strikeout and Underline

Rule 23.0 Reconstruction means that work which in any way changes the identity of the pole, tower or structure on which it is performed. A change in grade of construction or class of circuit is considered reconstruction. For exceptions see Rule 12.1. 44.1 Installation and Reconstruction Lines and elements of lines upon installation or reconstruction, shall provide as a minimum the safety factors specified in Table 4 for vertical loads and loads transverse to lines and for loads longitudinal to lines except where longitudinal loads are balanced or where there are changes in grade of construction (see Rules 47.3, 47.4 and 47.5). The design shall consider the structural loading and mechanical strength requirements of all supply and communication facilities planned to occupy the structure. For purposes of this rule, the term "planned" applies to the facilities intended to occupy the structure that are actually known to the constructing utility company at the time of design. 44.2 Additional Construction Any utility supply or communication company planning the addition of facilities that materially increase the vertical, transverse or longitudinal loading on a structure shall perform a loading calculation to ensure that the addition of the facilities will not reduce the safety factors below the values specified by Rule 44.3 Section IV. Such utility company shall maintain these pole loading calculations for five years and shall provide such information to authorized joint use pole occupants and the Commission upon request. All other utilities or companies on the subject pole shall cooperate with the utility company performing the load calculations described above including, but not limited to, providing intrusive pole loading test data results and other data necessary to perform those such calculations. Note: Nothing contained in this rule shall be construed as allowing the safety factor of a facility to be reduced below the required values specified in Rules 44.1 and 44.3. 44.3 - Replacement Lines or parts thereof shall be replaced or reinforced before safety factors have been reduced (due to deterioration and/or installation of additional facilities) in Grades "A" and "B" construction to less than two-thirds of the construction safety factors specified in Rule 44.1 and in Grades "C" and "F" construction to less than one-half of the construction safety factors specified in Rule 44.1. Poles in Grade "F" construction shall also conform to the requirements of Rule 81.3-A. In no case shall the application of this be held to permit the use of structures or any member of any structure with a safety factor less than one.

Consensus Proposal 6 re: GO 165, Sections I - IV

Proposed Revisions to GO 165 Shown with Strikeout and Underline

Contested Proposal 1A re: GO 95, Rule 11 (CPSD)

CPSD's Proposed Revisions to Rule 11 Shown with Strikeout and Underline

11 Purpose of Rules The purpose of these rules is to formulate, for the State of California, uniform requirements for overhead electrical line design, construction, and maintenance, the application of which will einsure adequate service and secure safety to persons engaged in the construction, maintenance, operation or use of overhead electrical lines and to the public in general.

Contested Proposal 1B re: GO 95, Rule 11 (CIP Coalition)

CIP Coalitions' Proposed Revisions to Rule 11 Shown with Strikeout and Underline

11 Purpose of Rules The purpose of these rules is to formulate, for the State of California, uniform requirements for overhead electrical line design, construction, and maintenance, the application of which will einsure adequate service and secure safety to persons engaged in the construction, maintenance, operation or use of overhead electrical lines and to the public in general.

Contested Proposal 2 re: GO 95, Rule 12 (CPSD)

CPSD's Proposed Revisions to Rule 12 Shown with Strikeout and Underline

12 Applicability of Rules These rules apply to all overhead electrical supply and communication facilities that come within the jurisdiction of this Commission, located outside of buildings, including facilities that belong to non-electric utilities and publicly-owned utility electric supply facilities, as follows: 12.1 Construction and Reconstruction of Lines 12.2 Maintenance of Lines 12.3 Lines Constructed Prior to This Order 12.4 Reconstruction or Alteration 12.5 Emergency Installation 12.6 Third Party Nonconformance

Contested Proposal 3A re: GO 95, Rule 18 (CIP Coalition)

CIP Coalition's Proposed Revisions to Rule 18 Shown with Strikeout and Underline

The CIP Coalition's proposed revisions to Rule 18 incorporate the consensus revisions to Rule 18 that replace the term "violation" with the term "nonconformance."

18 Reporting and Resolution of Safety Hazards Discovered by Utilities For purposes of this rule, "Safety Hazard" means a condition that poses a significant threat to human life or property. "Extreme and Very High Fire Threat Zones" are defined in the Commission Decision 09-08-029. "Southern California" is defined as the following: Santa Barbara, Ventura, San Bernardino, Riverside, Los Angeles, Orange, and San Diego. Part A: Resolution of Safety Hazards And General Order 95 Violations/Nonconformances (1)(a) Each company (including utilities and CIPs) is responsible for taking appropriate corrective action to remedy Safety Hazards and GO 95 violations/nonconformances posed by their its facilityies. (b) Upon completion of the corrective action, the company's records shall show, with sufficient detail, the nature of the work, the date, and the 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 Extreme 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 made available to Commission staff upon 30 days noticeimmediately 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, "safety hazard" means a condition that poses a significant threat to life or property, including, but not limited to, the ignition of a wildland or structure fire. "Extreme and Very High Fire Threat Zones" are defined in the Commission decision issued in Phase I of R.08- 11-005. "Southern California" is defined as the following: Santa Barbara, Ventura, San Bernardino, Riverside, Los Angeles, Orange, and San Diego Counties. Companies that have existing 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. All companies shall establish an auditable maintenance program for their facilities and lines. Further, all companies must include a timeline for corrective actions to be taken following the identification of a safety hazard or violation of General Orders 95 or 128 on the companies' facilities. The auditable maintenance program should be developed and implemented based on the following principles. (2)(a) All companies shall establish an auditable maintenance program for their facilities and lines. All companies must include a timeline for corrective actions to be taken following the identification of a Safety Hazard or violations/nonconformances with General Order 95 on the company's facilities. The auditable maintenance program shall prioritize corrective actions consistent with the priority levels set forth below and based on (1) Priorities shall be assigned based on the specifics of the safety hazard or violation as related to direct impact and the probability for impact on safety or reliability using the following factors:, as appropriate: · Safety and reliability as specified in the priority levels below; · Type of facility or equipment; · Location;, including whether the Safety Hazard or violation/nonconformance is located in an Extreme or Very High Fire Threat zone in Southern California; · Accessibility; · Climate; · Direct or potential impact on operations, customers, electrical company workers, communications workers, and the general public; o Whether the safety hazard or violation is located in an Extreme or Very High Fire Threat Zone (2) There willshall be three 3 priority levels, as follows. (a) (i) 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) (ii) 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 pointtime of identification by a qualified company representative, but not to exceed 59 months:. · Overhead: 0-59 months o 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. (c) (iii) Level 3: · Acceptable safety and/or reliability risk. · Take action (re-inspect, re-evaluate, or repair) at or before the next detailed inspection as appropriate. (b) (d) Exceptions (Levels 2 and 3 only) -Correction times may be extended under reasonable circumstances, such as: · Third party refusal · Customer issue · No access · Permits required · System emergencies (e.g. fires, severe weather conditions) (3) Companies that have existing General Order 165 auditable inspection and maintenance programs that are consistent with the purpose of Rule 18A shall continue to follow their General Order 165 programs. (3) Upon completion of the corrective action, 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 Extreme and Very High Fire Threat Zones of Southern California. With the exception 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 44.3 of this General Order, and is located in an Extreme 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.

Contested Proposal 3B re: GO 95, Rule 18 (SDG&E)

SDG&E's Proposed Revisions to Rule 18A Shown with Strikeout and Underline

SDG&E's proposed revisions to Rule 18 incorporate the consensus revisions to Rule 18 that replace the term "violation" with the term "nonconformance."

18 Reporting and Resolution of Safety Hazards Discovered by Utilities For purposes of this rule, "Safety Hazard" means a condition that poses a significant threat to human life or property. "Extreme and Very High Fire Threat Zones" are defined in the Commission Decision 09-08-029. "Southern California" is defined as the following: Santa Barbara, Ventura, San Bernardino, Riverside, Los Angeles, Orange, and San Diego Counties. Part A: Resolution of Safety Hazards And General Order 95 Violations/ Nonconformances (1)(a) Each company (including utilities and CIPs) is responsible for taking appropriate corrective action to remedy Safety Hazards and GO 95 violations/nonconformances posed by their its facilityies. (b) Upon completion of the corrective action, the company's records shall show the date and with sufficient detail, the nature of the work, the date, and the 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 Extreme 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, in any, to determine that the safety hazard has been remedied made available to Commission staff upon 30 days notice. The records shall be made available to Commission staff immediately upon request. Additinally, for any work completed after 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 correction action. For purposes of this rule, "safety hazard" means a condition that poses a significant threat to life or property, including, but not limited to, the ignition of a wildland or structure fire. "Extreme and Very High Fire Threat Zones" are defined in the Commission decision issued in Phase I of R.08-11-005. "Southern California" is defined as the following: Santa Barbara, Ventura, San Bernardino, Riverside, Los Angeles, Orange, and San Diego Counties. Companies that have existing 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. (2)(a) All companies shall establish an auditable maintenance program for their facilities and lines. Further, All companies must include a timeline for corrective actions to be taken following the identification of a Safety Hazard or violations/nonconformances of with General Orders 95 or 128 on the companies'company's facilities. The auditable maintenance program should be developed and implementedshall prioritize corrective actions consistent with the priority levels set forth below and based on the following principles.factors, as appropriate: (1) Priorities shall be assigned based on the specifics of the safety hazard or violation as related to direct impact and the probability for impact on safety or reliability using the following factors: · Safety and reliability as specified in the priority levels below; · Type of facility or equipment; · Location;, including whether the Safety Hazard or nonconformance is located in an Extreme or Very High Fire Threat Zone in Southern California; · 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 Extreme or Very High Fire Threat zone. (2) There willshall be three3 priority levels, as follows:. (ai) 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. (bii) 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 pointtime of identification by a qualified company representative:, but not to exceed; (1) 12 months for violations/nonconformances that compromise worker safety, (2) 12 months for violations/nonconformances that create a fire risk and are located in an Extreme or Very High Fire Threat Zone in Southern California, and (3) 59 months for all other Level 2 violations/nonconformances. o 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.: (ciii) Level 3: · Acceptable safety and/or reliability risk. · Take action (re-inspect, re-evaluate, or repair) at or before the next detailed inspection.as appropriate. (d) Exceptions (Levels 2 and 3 only) -b) Correction times may be extended under reasonable circumstances, such as: · Third party refusal · Customer issue · No access · Permits required · System emergencies (e.g. fires, severe weather conditions) (3) Upon completion of the corrective action, 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. (3) Companies that have existing General Order 165 auditable inspection and maintenance programs that are consistent with the purpose of Rule 18A shall continue to follow their General Order 165 programs. (4) The company shall prioritize implementing this maintenance plan within the Extreme and Very High Fire Threat Zones of Southern California. With the exception 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 44.3 of this General Order, and is located in an Extreme 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.

Contested Proposal 4 re: GO 95, Rule 18C (MGRA)

MGRA's Proposed New Rule 18C Shown with Underline

18C - Contingency Planning Electric utilities shall have in place contingency plans for predicting and identifying hazard conditions that exceed wind loadings of Rule 43 in areas designated as having high fire risk during periods of high fire danger. These plans shall include measures to prevent ignitions of wildland fires by equipment that meets GO 95 wind loading and vegetation management requirements.

Contested Proposal 5 re: GO 95, Rule 31.1 (Joint Utilities)

Joint Utilities' Proposed Revisions to Rule 31.1 Shown with Underline

31.1 Design, Construction and Maintenance Electrical supply and communication systems shall be designed, constructed, and maintained for their intended use, regard being given to the conditions under which they are to be operated, to enable the furnishing of safe, proper, and adequate service. For all particulars not specified in these rules, design, construction, and maintenance should be done in accordance with accepted good practice for the given local conditions known at the time by those responsible for the design, construction, or maintenance of [the] communication or supply lines and equipment. For all particulars specified in this Order, a supply or communications company is in compliance with this rule if it designs, constructs and maintains a facility in accordance with such particulars. For all particulars not specified in this Order, a supply or communications company is in compliance with this rule if it designs, constructs and maintains a facility in accordance with accepted good practice. All work performed on public streets and highways shall be done in such a manner that the operations of other utilities and the convenience of the public will be interfered with as little as possible and no conditions unusually dangerous to workmen, pedestrians or others shall be established at any time. Note: The standard of accepted good practice should be applied on a case by case basis. For example, the application of "accepted good practice" may be aided by reference to any of the practices, methods, and acts engaged in or approved by a significant portion of the relevant industry, or which may be expected to accomplish the desired result with regard to safety and reliability at a reasonable cost.

Contested Proposal 6A re: GO 95, Rule 31.2 (CIP-1)

Proposed Revisions to Rule 31.2 Shown with Underline

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. A. Communications Lines In Specified Fire Areas: Communication lines shall be inspected in Specified Fire Areas, as follows: (1) Patrols shall be performed not less often than once every three (3) years on overhead communications lines installed on joint use poles with electric distribution or transmission facilities, as well as on communication lines one span away. Patrol means a simple visual inspection of communications 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. (2) Detail Inspections shall be performed not less often than once every nine (9) years on overhead communications lines installed on joint use poles with electric distribution or transmission facilities, as well as on communication lines one span away. Detail Inspection means a careful visual inspection of communications equipment and structures using inspection tools such as binoculars and measuring devices, as appropriate. Detail Inspections may be carried out in the course of other company business. For all patrols and details, records shall specify the 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. Records of Patrols and Details shall be made available to Commission staff upon 30 days notice. Note: Specified Fire Areas shall be defined as [in Southern California - FRAP Maps; in Central and Northern California - to be worked out in workshops]. Electric Lines: shall be inspected in compliance with the minimum intervals set forth in General Order 165.

Contested Proposal 6B re: GO 95, Rule 31.2 (CIP-2)

Proposed Revisions to Rule 31.2 Shown with Strikeout and Underline

31.2 Inspection of Lines A. Lines shall be inspected frequently and thoroughly for the purpose of einsuring 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. For the purpose of the remaining subsections of this Rule: "Patrol" means a simple visual inspection designed to identify obvious structural problems and hazards. Patrols may be carried out in the course of other company business. "Specified Fire Areas" shall be defined as: for Southern California, the Extreme and Very High Threat Zones on the California Department of Forestry and Fire Protection's Fire and Resource Assessment Program's map in Santa Barbara, Ventura, Los Angeles, Orange, San Diego, Riverside, and San Bernardino; for Central and Northern California, [to be determined in the workshops.] B. Patrols shall encompass overhead communication lines installed on joint use poles with electric distribution facilities, as well as those facilities that are one span away in the Specified Fire Areas. Each Specified Fire Area shall be inspected not less than once every five (5) years. C. Records demonstrating compliance with subsection (B) of this Rule shall be maintained. Company records shall specify the plant, area or equipment inspected, the name of the inspector and the date of the inspection. Such documentation shall be retained for five (5) years.

Contested Proposal 6C re: GO 95, Rule 31.2 and Rule 80.1 (CPSD)

Proposed Revisions to Rule 31.2 Shown with Strikeout and Underline

	31.2 Inspection of Lines Lines shall be inspected frequently and thoroughly for the purpose of einsuring 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. Communication Lines (See Rule 80.1) B. Supply Lines shall be inspected in compliance with the requirements of General Order 165. 80.1 Inspection Requirements for Communication Lines: A. Each company shall prepare, follow and modify as necessary procedures for conducting inspections for all Communication Lines. The procedures at a minimum shall contain the following: · Maximum allowable intervals between inspections. The intervals between inspections shall be based upon the following factors: · Proximity to electric facilities · Terrain · Accessibility · Location In no case may the period between inspections (measured in calendar years) for Communication Lines located on Joint Use Poles (See Rule 21.8) that support Supply Lines, as well as those Communication Lines attached to a pole that are one span away from Joint Use Poles that support Supply Lines, exceed the time specified in the below Table. Patrol Detailed Urban Rural 1 21 10 (1) Patrol inspections in rural areas shall be increased to once per year in Extreme and Very High Fire Threat Zones in the following counties: Santa Barbara, Ventura, Los Angeles, San Bernardino, Orange, Riverside, and San Diego. Extreme 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 approximate boundaries and Utilities should use their own expertise and judgment to determine if local conditions require them to adjust the boundaries of the map. · Methodology to ensure that all lines are subjected to: · Detailed Inspections Note: For the purpose of this rule Detailed Inspection shall be defined as a careful visual inspection of Communication facilities and structures using inspection tools such as binoculars and measuring devices, as appropriate. · Patrol Inspections Note: For the purpose of this rule Patrol Inspection shall be defined as a simple visual inspection, of applicable communications facilities equipment and structures that is designed to identify obvious structural problems and hazards. Patrol inspections may be carried out in the course of other company business. · Procedures specifying what problems shall be identified. Each company shall maintain records of inspections. Commission staff shall be permitted to inspect records and procedures consistent with Public Utilities Code Section 314 (a).

Contested Proposal 6D re: GO 95, Rule 31.2 and Rule 80.1 (SDG&E)

Proposed Revisions Shown in with Strikeout and Underline

	31.2 Inspection of Lines Lines shall be inspected frequently and thoroughly for the purpose of einsuring 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. Communication Lines (See Rule 80.1) B. Supply Lines shall be inspected in compliance with the requirements of General Order 165. 80.1 Inspection Requirements for Communication Lines: Each company shall prepare, follow and modify as necessary procedures for conducting inspections for all Communication Lines. The procedures at a minimum shall contain the following: · Maximum allowable intervals between inspections. The intervals between inspections shall be based upon the following factors: · Proximity to electric facilities · Terrain · Accessibility · Location In no case may the period between inspections (measured in years) for Communication Lines located on Joint Use Poles (See Rule 21.8) that contain Supply Circuits (See Rule 20.6-D), as well as those Communication Lines attached to a pole that are within three spans of Joint Use Poles that contain Supply Circuits, exceed the time specified in the below Table. Patrol Detailed Urban Rural 1 21 101 (1) Patrol inspections in rural areas shall be increased to once per year, and detailed inspections shall be increased to once every five years, in Extreme and Very High Fire Threat Zones in the following counties: Santa Barbara, Ventura, Los Angeles, San Bernardino, Orange, Riverside, and San Diego. Extreme 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 approximate boundaries and Utilities should use their own expertise and judgment to determine if local conditions require them to adjust the boundaries of the map. · Methodology to ensure that all lines are subjected to: · Detailed Inspections Note: For the purpose of this rule Detailed Inspection shall be defined as a careful visual inspection of Communication facilities and structures using inspection tools such as binoculars and measuring devices, as appropriate. · Patrol Inspections Note: For the purpose of this rule Patrol Inspection shall be defined as a simple visual inspection, of applicable communications facilities equipment and structures that is designed to identify obvious structural problems and hazards. Patrol inspections may be carried out in the course of other company business. · Procedures specifying what problems shall be identified. Each company shall maintain records of inspections. Commission staff shall be permitted to inspect records and procedures consistent with Public Utilities Code Section 314 (a).

Contested Proposal 6E re: GO 95, Rule 31.2 and Rule 80.1B (CPSD)

Proposed New Rule 80.1B Shown with Underline

80.1 Inspection Requirements for Communication Lines: B. Intrusive Inspections Wood poles supporting only Communication Lines or equipment, that are: Located in Extreme or Very High Fire Threat Zones in Southern California and inter-set between joint use poles supporting Supply Lines, Or, Located in Extreme or Very High Fire Threat Zones in Southern California and extend up to three spans from a joint use pole supporting Supply Lines, Or, Located in areas outside Extreme or Very High Fire Threat Zones in Southern California and extend one span from a joint use pole supporting Supply Lines, shall be intrusively inspected accordance with the schedule established in General Order 165 for wood poles that support Supply Lines. Note: For the purpose of this rule Intrusive Inspections shall be defined as an inspection involving movement of soil, and/or using more sophisticated diagnostic tools beyond visual inspections or instrument reading.

Contested Proposal 7A re: GO 95, Rule 35, Paragraph 4 (Joint Utilities)

Proposed New Paragraph Shown with Underline

35 Vegetation Management Insert new fourth Paragraph as follows: Whenever a property owner obstructs access to, or fails to make accessible, overhead facilities for vegetation management activities, such that the supply company cannot inspect its facilities or there is an imminent threat of violation of required regulatory or statutory clearances, the supply company, at its discretion and with proper notice, may discontinue electric service the property owner is receiving at any location where the owner may receive the supply company's electric service. "Proper notice" shall, at a minimum, consist of five days written notice, unless the condition poses an imminent safety hazard to the public.

Contested Proposal 7B re: GO 95, Rule 35, Exception 3 (Joint Utilities)

Proposed New Exception Shown with Strikeout and Underline

35 Vegetation Management Where overhead conductors traverse trees and vegetation, safety and reliability of service demand that certain vegetation management activities be performed in order to establish necessary and reasonable clearances. The minimum clearances established in Table 1, Cases 13 and 14, measured between line conductors and vegetation under normal conditions, shall be maintained. (Also see Appendix E for tree trimming guidelines). When a utility has actual knowledge, obtained either through normal operating practices or notification to the utility, dead, rotten and diseased trees or portions thereof, that overhang or lean toward and may fall into a span, should be removed. Communication and electric supply circuits, energized at 750 volts or less, including their service drops, should be kept clear of vegetation in new construction and when circuits are reconstructed or repaired, whenever practicable. When a utility has actual knowledge, obtained either through normal operating practices or notification to the utility, that any circuit energized at 750 volts or less shows strain or evidences abrasion from vegetation contact, the condition shall be corrected by reducing conductor tension rearranging or replacing the conductor, pruning the vegetation or placing mechanical protection on the conductor(s). For the purpose of this rule, abrasion is defined as damage to the insulation resulting from the friction between the tree and conductor. Scuffing or polishing of the insulating covering is not considered abrasion. Strain on a conductor is present when there is additional tension causing a deflection of the conductor beyond the slack of the span. Contact between vegetation and conductors, in and of itself, does not constitute a violation of the rule. EXCEPTIONS: 1. Rule 35 requirements do not apply to conductors, or aerial cable that complies with Rule 57.4-C, energized at less than 60,000 volts, where trimming or removal is not practicable and the conductor is separated from the tree with suitable materials or devices to avoid conductor damage by abrasion and grounding of the circuit through the tree. 2. Rule 35 requirements do not apply where the utility supply or communication company has made a "good faith" effort to obtain permission to trim or remove vegetation but permission was refused or unobtainable. A "good faith" effort shall consist of current documentation of a minimum of an attempted personal contact and a written communication, including documentation of mailing or delivery. However, this does not preclude other action or actions from demonstrating "good faith". If permission to trim or remove vegetation is unobtainable and requirements of exception 2 are met, the utility company is not compelled to comply with the requirements of exception 1. 3. Whenever a property owner obstructs access to, or fails to make accessible, overhead facilities for vegetation management activities, the supply or communication company shall not be responsible for the consequences of failing to trim or remove such vegetation so long as the supply or communication company can document (1) at least one attempted personal contact with the owner, (2) at least one written communication to the owner, including documentation of mailing or delivery, and (3) notification to Commission Staff. 3. 4. The Commission recognizes that unusual circumstances beyond the control of the utility may result in nonconformance with the rules. In such cases, the utility may be directed by the Commission to take prompt remedial action to come into conformance, whether or not the nonconformance gives rise to penalties or is alleged to fall within permitted exceptions or phase-in requirements.

Contested Proposal 8A re: GO 95, Rule 35, Appendix E, Table (Joint Utilities)

Proposed Revisions Shown with Strikeout and Underline

Contested Proposal 8B re: GO 95, Rule 35, Guidelines (Joint Utilities)

Proposed Revisions Shown with Strikeout and Underline

The following are guidelines to Rule 35. The radial clearances shown below are recommended minimum clearances that should be established, at time of trimming, between the vegetation and the energized conductors and associated live parts where practicable. Reasonable vegetation management practices may make it advantageous to obtain greater clearances than those listed below: to ensure compliance until the next scheduled maintenance. Each utility may determine and apply additional appropriate clearances beyond clearances listed below, which take into consideration various factors, including: line operating voltage, length of span, line sag, planned maintenance cycles, location of vegetation within the span, species type, experience with particular species, vegetation growth rate and characteristics, vegetation management standards and best practices, local climate, elevation, and fire risk.

Contested Proposal 8C re: GO 95, Rule 35, Guidelines (CFBF and MGRA)

Proposed Revisions Shown with Strikeout and Underline

The following are guidelines to Rule 35. The radial clearances shown below are recommended minimum clearances that should be established, at time of trimming, between the vegetation and the energized conductors and associated live parts where practicable. Reasonable vegetation management practices may make it advantageous for the purposes of public safety, reliability or tree health to obtain greater clearances than those listed below: to ensure compliance until the next scheduled maintenance. Each utility may determine and apply additional appropriate clearances beyond clearances listed below, which take into consideration various factors, including: line operating voltage, length of span, line sag, planned maintenance cycles, location of vegetation within the span, species type, experience with particular species, vegetation growth rate and characteristics, vegetation management standards and best practices (including when feasible appropriate tree crop production manuals), local climate, elevation, and fire risk.

Contested Proposal 9 re: GO 95, Rule 38, Table 2, Footnote (aaa) (Joint Utilities)

Proposed New Footnote Shown with Underline

New Footnote "aaa" to clearances specified in Rule 38, Table 2, Cases 1-13: (aaa) The vertical separation requirement between conductors in the adjoining mid-span may or may not require increased vertical separation at the pole based on the sag characteristics of the conductors.

Contested Proposal 10A re: GO 95, Rule 44.4 (CIP Coalition)

Proposed New Rule 44.4 Shown with Underline

44.4 Cooperation All entities with facilities on the subject pole shall cooperate with the company performing the load calculations necessitated by the provisions of Rule 44.1, 44.2 or 44.3, including, but not limited to, promptly providing or making reasonably available, upon request and to the extent it exists, the following: (a) The most recent intrusive pole test data; (b) Any information regarding its facilities necessary to perform a pole loading calculation that is not readily available to the company performing the pole loading calculations through a field visit; and (c) A table of standard input values used by the Responding Company in pole loading calculations (e.g., standard conductor or cable sizes, tension values, and equipment sizes and weights). In the event a pole attachment application or a joint pole application submitted to a pole owner is rejected, the pole owner shall provide the applicant with the reason(s) for the rejection with the returned application. In the event a pole attachment application or a joint pole application is rejected by a pole owner because it has failed to meet the pole loading limitations established by the pole owner (consistent with General Order 95 or any subsequent regulation), the pole owner should also provide the applicant with sufficient information to determine how the pole loading limitations were exceeded with the returned application. Note: "Promptly" means as soon as practicable but, absent exigent circumstances or mutual agreement, no more than fifteen (15) business days from the date of the request. (Exigent circumstances include requests for intrusive data or other necessary information on transmission poles, or requests for information on a large number of poles in a limited time period.)

Contested Proposal 10B re: GO 95, Rule 44.2, Rule 44.4, and Appendix I (Joint Utilities)

Proposed Revisions to Rules 44.2 and 44.4 Shown with Strikeout and Underline.

Proposed Revisions to Rule 44.2 and Addition of New Rule 44.4 44.2 Additional Construction Any utility entity planning the addition of facilities that materially increase the load on a structure shall perform a loading calculation to ensure that the addition of the facilities will not reduce the safety factors below the values specified by Section IV. Such utility entity shall maintain these pole loading calculations and shall provide such information to authorized joint use pole occupants and the Commission upon request. All other utilities or on the subject pole shall cooperate with the utility performing the load calculations described above including, but not limited to, providing intrusive pole loading data and other data necessary to perform those calculations. Note: Nothing contained in this rule shall be construed as allowing the safety factor of a facility to be reduced below the required values specified in Rules 44.1 and 44.3. 44.4 Cooperation Entities with facilities on a pole shall cooperate with entities performing pole load calculations necessitated by Rules 44.1, 44.2 and 44.3 including, but not limited to, providing upon request intrusive pole test results and other data necessary to perform those calculations. (See Appendix I) General Order 95 Appendix I Guidelines to Rule 44.4 ________________________________________________________________ The following are guidelines to Rule 44.4 Entities with facilities on a pole should cooperate with the entity performing the load calculations necessitated by the provisions of Rule 44.1, 44.2 or 44.3, including, but not limited to, promptly providing, upon request and if available, the following: (a) The most recent intrusive pole test data; (b) Any information regarding its facilities necessary to perform a pole loading calculation that is not readily available to the company performing the pole loading calculations through a field visit; and (c) A table of standard input values used by the responding entity in pole loading calculations (e.g., standard conductor or cable sizes, tension values, and equipment sizes and weights). "Promptly providing" means as soon as practicable but, absent exigent circumstances or mutual agreement, no more than fifteen (15) business days from the date of the request. (Exigent circumstances include requests for intrusive data or other necessary information on transmission poles, or requests for information on a large number of poles in a limited time period.) In the event a pole attachment application or a joint pole application submitted to a pole owner is rejected, the pole owner should provide the applicant with an explanation of the reason(s) for the rejection with the returned application. In the event a pole attachment application or a joint pole application is rejected by a pole owner because it has failed to meet the pole loading limitations established by the pole owner (consistent with General Order 95 or any subsequent regulation), the pole owner should also provide the applicant with, sufficient information to determine how the pole loading limitations were exceeded.

Contested Proposal 11A re: GO 95, Rule 48 (Joint Utilities)

Proposed Revisions to Rule 48 Shown with Strikeout and Underline.

48 Ultimate Strength of Materials Structural members, and their connections, and other elements of overhead lines shall be designed and constructed in accordance with the loading criteria specified in Rule 43 so that the structures and parts thereof will not fail or be seriously distorted at any load less than their maximum working loads (developed under the current construction arrangements with loadings as specified in Rule 43) and the safety factors specified in Rule 44. Values used for the ultimate strength of material shall comply with the safety factors specified in Rule 44.

Contested Proposal 11B re: GO 95, Section IV, Proposed Ordering Paragraph (CPSD)

Proposed Ordering Paragraph Shown with Underline.

Proposed Ordering Paragraph: The Consumer Protection and Safety Division shall establish a technical working group to address possible changes to Section IV of General Order 95. The technical working group shall consider appropriate revisions, if any, to Section IV of General Order 95 to update the section to incorporate modern materials and practices. CPSD shall report back to the Commission within 12 months.

Contested Proposal 12 re: GO 95, Proposed Rule 91.5 (SDG&E)

Proposed Rule 91.5 Shown with Underline.

91.5 Marking Communication cables and conductors shall be marked as to ownership to facilitate identification.

Contested Proposal 13A re: GO 165, Section V (CPSD and MGRA)

Proposed New Section V of GO 165 Shown with Underline.

V. Fire Incident Reporting and Data Collection Requirements California investor-owned electric utilities shall collect information on all fire incidents which are attributable or allegedly attributable to their overhead electric distribution lines or transmission lines. Data to be collected per incident shall include date, time, general location, specific geographical coordinates, equipment, voltage, fire agencies involved, weather conditions, vegetation conditions, and apparent cause. Collected data shall be provided electronically under General Order 66-C and Section 583 of the Public Utilities Code annually to the Director of CPSD or its successor. Summaries of collected data shall be provided electronically annually to the Director of CPSD or its successor, which may be made available to the public and state or local fire agencies.

Contested Proposal 13B re: Proposed Ordering Paragraph on Data Collection (PG&E)

Proposed Ordering Paragraph Shown with Underline.

Proposed Ordering Paragraph: Within 6 months of the effective date of this decision, the electric utilities and CPSD shall meet and confer regarding electric utility collection and utilization of fire-related data. Such discussions shall consider whether CPSD is receiving the fire-related data it needs from the electric utilities, and whether it would be useful for the electric utilities to collect different and/or additional data that would be provided to CPSD and/or fire agencies such as Cal Fire. Within 9 months of the effective date of this decision, the electric utilities and CPSD shall submit a report to the Executive Director of the Commission regarding the results of such discussions. State fire agencies shall be invited to participate in the discussions and report. These discussions shall be conducted in such a manner as to protect the confidentiality of the utilities' data.

Contested Proposal 14A re: Proposed Ordering Paragraph Regarding Fire Maps (CPSD and MGRA)

Proposed Ordering Paragraph Shown with Underline.

Proposed Ordering Paragraph Investor-owned electric utilities (IOUs) and communication infrastructure providers (CIPs) shall provide funding to support the development of a working plan to determine how to create utility-specific high-resolution maps combining wind and vegetation data that identify areas at the greatest risk of catastrophic power line wildland fire ignitions. Within 60 days of the issuance of this decision, or at a time mutually agreed to by the participating parties, investor-owned electric utilities (IOUs) and communication infrastructure providers (CIPs) shall meet and confer with CAL FIRE and CPSD staff in order to discuss how to create utility-specific high-resolution maps combining wind and vegetation data that identify areas at the greatest risk of catastrophic power line wildland fire ignitions. The purpose of the maps will be for determining inspection and maintenance cycles in all cases where geographic locations and maps are referred to in General Orders 95 and 165, and the maps may be used in the future to determine geography-specific construction, maintenance, and operational standards. The IOUs and CIPs shall cooperate with CAL FIRE and CPSD staff to develop a working plan to determine the process by which the maps would be produced, estimate the time and costs required to produce and maintain maps, devise a proposed revision cycle under which subsequent updates to the maps would be undertaken to incorporate changes to the underlying data or improvements or changes to analysis techniques, and any other actions that the Commission would need to take to enable the creation of utility-specific maps, including the use of funding provided by IOUs and CIPs. IOUs and CIPs shall further meet and confer with CAL FIRE to determine what funding may be required to produce such a working plan. Within six months after the issuance of this decision, IOUs and CIPs shall report back to the Commission and CPSD staff on the status of the working plan. Upon completion of the working plan, the Commission will decide whether to order the investor-owned electric utilities and communication infrastructure providers to fund the creation and maintenance of utility-specific high-resolution maps. Maps adopted in Phase 1 or Phase 2 of this OIR shall remain applicable until further order by the Commission.

Contested Proposals 14A and 14B re: GO 95, Rule 31.2, Fire Maps for CIP Inspections

Proposed Additions to GO 95, Rule 31.2, Shown with Underline.

31.2 Inspection of Lines Note: For the following Southern California counties: Santa Barbara, Ventura, Los Angeles, Orange, San Diego, Riverside, and San Bernardino, Specified Fire Areas shall be defined as the Extreme and Very High Fire Threat Zones as identified in Cal Fire's Fire and Resource Assessment Program Fire Threat Map. For the remaining counties in the State of California, Specified Fire Areas are defined as the areas designated as Threat Class 3 and 4 identified on Threat Class 3 and 4 Map attached as Appendix G, Figure 90. Communication Infrastructure Providers shall have the discretion to use their own expertise and judgment to determine if local conditions require them to adjust the boundaries of the maps. APPENDIX G Figure 90

(END OF APPENDIX A)