BACKGROUND

SCE's Schedule Experimental WTR (Wireless Technology Rate) became first effective November 1999. It allows devices rated up to 700 watts (W) to be mounted on SCE facilities, and applies to "single phase service for wireless technology industries that require electric service to operate radio repeaters or similar devices that are mounted on existing SCE facilities ...and are unmetered". SCE reported that in practice however, it was not applying Schedule WTR to WiFi Internet (WiFi) devices.

Cities, counties and commercial WiFi service providers have approached SCE regarding the attachment of WiFi devices to SCE's streetlights and the powering of these devices with unmetered electric energy so that these entities can make wireless Internet service available within the communities they serve.

SCE conducted a pilot study to evaluate the feasibility of allowing the attachment of WiFi devices to SCE's streetlights. Of concern was (1) the "power quality" served to streetlights when WiFi devices were attached, (2) potential for radio frequency interference (RFI) with radios used in operating SCE's electrical system, and (3) interference with operation of other utility equipment or impact on the service to customers.

The pilot study was necessary because SCE's primary obligation is to operate and maintain its electric system, including the 615,000 owned streetlights out of a total of 780,000 in their service territory. Seventy percent of the owned streetlights are stand alone, loop fed by 120 volt circuits, where the power quality concern is greatest. The pilot was performed over a two-month period on 36 streetlights and five streetlight circuits on a 0.2 square mile area.

The results of the pilot showed that 35 watts of additional load on 50% of the streetlights, (on every other adjacent streetlight) can be accommodated without adverse impact.

Since the pilot was not inclusive of every type of WiFi equipment available on the market, SCE reserves the right to test or have tested by third parties, devices not included in the pilot, at the WiFi provider's cost. Both parties must be satisfied with the test results of a pre-service test of the devices.

Installation of WiFi devices located adjacent to any SCE private WiFi (radio frequency) network must reflect consideration of the following design options to minimize the radio frequency interference between them:

· Configure the WiFi radios to operate in different non-overlapping WiFi channels.

· Use directional antennas where applicable to direct WiFi signals away from neighboring WiFi radios.

· Deploy interference-reduction schemes.

Furthermore,

· The WiFi pilot was utility-focused and did not evaluate any customer-related issues (i.e. in-the-home Internet service). SCE does not guarantee or warrant any degree of geographical coverage or adequacy of Internet service itself.

· There is no guarantee that any next-generation technology will meet SCE's technical requirements to receive electric service from streetlights.

· There is no guarantee, depending on the network architecture and density of devices, that multiple service providers can obtain service from the same streetlight circuits.

SCE's proposal

SCE proposes to offer unmetered electric service to cities, counties and commercial providers of WiFi Internet service, if qualified (per Schedule Wi-Fi-1 and SCE), under the following salient conditions:

· Signed agreement and payment of charges. These are:

¬ Fixed Energy charges for 25 kWh/month/device at the Schedule TC-1 (Traffic Control) rate

¬ Customer Charge of $3.70/month

¬ Inventory/Maintenance Charge of $2.30/month/device

¬ Initialization of Service Charge of $ 8.50/device

· Maximum of 35 watts per device on every other adjacent pole.

· No WiFi devices are allowed on "nostalgic" or "ornamental" streetlights.

· WiFi devices are allowed in communication spaces of SCE's distribution poles provided SCE has exclusive right to the space. If space is owned by another utility, then a city/county or commercial WiFi provider must either establish a license agreement with the pole owner of record or join the Southern California Joint Pole Committee.

· Only SCE approved WiFi devices are allowed (interference-reduction schemes where required, power requirement).

· WiFi provider bears all costs and labor for installation of WiFi devices and modifications for continuous electric service.

· Testing of the customer's WiFi devices and associated equipment may be required to SCE's satisfaction at customer's expense.

· For devices attached to streetlights fed directly from SCE's distribution system (not "loop-fed"), General Order (G.O.) 95 applies, requiring device owners to absorb the cost of maintaining clearances around the device and of moving, removing or modifying them due to G.O. changes.

· Customer bears costs for streetlight circuit upgrade or repairs due to WiFi device installation.

· Rule 2 minimum customer service voltage is not applicable.

· All attendant upgrades to existing SCE streetlight facilities shall not be subject to Rules 15 and 16 (Distribution line and Service extensions).

· Attachments and services under Schedule Wi-Fi-1 must be permitted under existing franchise or other agreement between SCE and local jurisdiction.

SCE requested that a resolution be approved by the Commission, mainly to confirm that attachment of WiFi Internet devices to SCE's streetlights where unmetered service is provided, does not constitute a "service" for purpose of applying the provisions of Rules 15 and 16. These line and service extension rules create utility ownership and obligate the utility to maintain them. An allowance is also granted to customers of new extensions, the cost of which is placed into ratebase.

A resolution would also settle whether PUC Section 851 issues of transfer or encumbrance of utility property were involved with attaching WiFi devices.