VIII. Response of the Office of Ratepayer Advocates (ORA)

ORA did not file a protest to this application. However, in its response to the application, ORA stated that it did not oppose the application provided that the construction complied with the Overhead Line Safety Requirements in GO 95. ORA recommended that future § 851 applications include engineering studies demonstrating compliance with GO 95, and accepted engineering practices. It also recommended that such applications address the impact on PG&E's ability to expand its transmission capacity. In its reply, PG&E agreed to confirm, in future applications, that the safety and reliability of its system would not be adversely affected, and to address any impact on future expansion of transmission capacity. However, while PG&E agreed to make engineering studies available upon request, it objected to being required to submit them with the application because they are voluminous and contain sensitive information pertaining to facilities and telecommunications equipment agreements. We will require that future applications confirm that the safety and reliability of PG&E's system will not be adversely affected, and address any impact on future expansion of transmission capacity. Because they may be voluminous, we see no need to require that related engineering studies be included with the applications. However, we will require that a detailed description of any proposed construction be included with the application, and that related engineering studies be made available upon request, subject to confidential treatment if appropriate.