Comments

The ALJ issued his proposed decision (PD) on August 25, 1997. Comments were submitted by SDG&E, SCE, USB, and Adams. SDG&E, PG&E, and Adams submitted reply comments. We have incorporated various editorial and nonsubstantive revisions in this final decision in response to those comments.

USB's comments suggest that it would be erroneous to grant an exemption to the minimum clearance requirements for established and directionally pruned trees, because such an exemption would conflict with our objectives of improving visibility and maneuverability. However, USB's contention overlooks the fact that the exemption is based upon the reduced need for visibility and maneuverability because of the relationships which exist between the conductor and the trunk or major limbs, and the fact that other concerns outweigh the desirability of maintaining a uniform minimum clearance. We have therefore retained the exemption.

SDG&E contends that the parties' workshop proposal to adopt a two-year compliance deadline was predicated upon the assumption that we would also adopt a six-inch minimum clearance. The PD characterizes the difference between that minimum and the adopted eighteen-inch minimum as immaterial. SDG&E has offered no cogent reason why the trimming cycle would be materially affected if the extent of the actual trimming is adjusted to compensate for the increased minimum standard. We will not extend the compliance deadline on these grounds.