3. SDG&E's Petition

The catastrophic wildfires in October 2007 prompted SDG&E to file Petition (P.) 07-11-007 on November 6, 2007, pursuant to § 1708.5 and Rule 6.3 of the Commission's Rules of Practice and Procedure (Rules). The Petition asks the Commission to open a rulemaking proceeding to consider the following matters:

· Operations -- Whether overhead electric lines in rural areas should be operated differently when extreme fire conditions are present;

· Facilities -- Whether some overhead electric lines in rural areas should be placed underground; whether steel poles should be used in rural, fire-prone areas as opposed to wood; and whether the design of overhead electric lines should be changed to reduce wildfire hazards, such as shortening line span lengths;

· Vegetation Management -- Whether all rights-of-way for overhead electric lines in rural, fire-prone areas should be cleared of vegetation for a certain minimum width;

· Interface Among Agencies -- How to best coordinate the efforts of agencies, municipalities, local jurisdictions, and utilities to ensure efficient and effective disaster management practices; and

· Disaster Management Plan -- Whether a statewide disaster management plan is needed and how to fund the plan.

SDG&E's Petition does not propose specific regulations. Rather, the Petition identifies in broad terms the issues that should be explored. The proposed rulemaking would focus on General Order (GO) 95 because it governs many aspects of the construction, operation, and maintenance of overhead electric lines. It would also encompass any other General Orders, decisions, rules, or regulations that may be affected by the above-listed matters, as well as the adoption of entirely new regulations.

SDG&E does not seek retroactive relief in its Petition. SDG&E also asks that any issues regarding its culpability in the October 2007 wildfires be excluded from the rulemaking and addressed, if at all, in a utility-specific investigation.

SDG&E believes the rulemaking will dissuade other State and local jurisdictions from adopting a patchwork of inconsistent requirements. To encourage a collaborative approach, SDG&E recommends that other agencies be invited to participate in facilitated workshops where proposals of statewide applicability would be submitted and considered.

Notice of P.07-11-007 appeared in the Daily Calendar on November 14, 2007. The Petition was also served on Cal Fire; the California Independent System Operator (Cal ISO); the Governor's Office of Emergency Services; all municipal and county governments within the service territories of SDG&E and Southern California Gas Company (an affiliate of SDG&E); and the service lists for Rulemaking (R.) 01-10-001 (re:  revisions to GOs 95 and 128), R.05-02-023 (re: revisions to GO 95), and Application 06-08-010 (re: Sunrise Powerlink Transmission Project).

Timely responses were filed by the California Cable Television Association (CCTA); Cal ISO; the Center for Biological Diversity and the Sierra Club (CBD/SC); CPSD; the Commission's Division of Ratepayer Advocates (DRA); the Mussey Grade Road Alliance (MGRA); Pacific Gas and Electric Company (PG&E); Southern California Edison Company (SCE); and William Adams.