XI. Utility Workshop Standardizing Design Guidelines
280 Citizens recommends that the Commission require utilities to amend their design guidelines to include measures which may be listed in the guidelines of one utility but not another. 280 Citizens also recommends expansion of design guidelines to include less typical mitigation measures such as those applied or ordered in A.02-09-043. While Edison supports standardization of field reduction techniques,28 Edison notes that new mitigation techniques must not compromise safety and other standards and regulations as required in the Commission's General Orders (GO) 95 and 128.29
We agree with 280 Citizens and Edison that some standardization of design guidelines would be a useful tool in evaluating EMF mitigation measures, provide common approaches and procedures, and lead to improvements in implementing our low-cost/no-cost policy. Accordingly, we will order the utilities to convene a workshop to consider changes, modifications and additions to current utility design guidelines. As other parties have already submitted comments on the design guidelines for PG&E, Edison and SDG&E, we will direct the utilities to meet and consider design guideline changes without further input. We have stated our EMF mitigation policies in this decision and we expect the utilities to implement these policies in revised design guidelines including engaging CDE to develop consistent mitigation measures. We will require that the proposed design guidelines be submitted within six months as an advice letter, subject to review and approval by our Energy Division.30
In ordering a utility workshop, we are mindful that changes in design guidelines should not compromise safety, reliability, or the requirements of GOs 95 and 128. Furthermore, we do not request that utilities include non-routine mitigation measures, or other mitigation measures that are based on numeric values of EMF exposure, in revised design guidelines or apply mitigation measures to reconfigurations or relocations of less than 2,000 feet, the distance under which exemptions apply under GO 131-D. Non-routine mitigation measures should only be considered under unique circumstances.
28 PG&E believes that its design guidelines include the same options available under Edison and SDG&E's guidelines.
29 GO 95 addresses overhead electric line construction requirements. GO 128 addresses underground electric and communication systems construction requirements.
30 We note that this process is similar to the development of design guidelines ordered in D.93-11-013. (OP 10.)
