4. Responses to the Petition
4.1. Cal ISO
Cal ISO is willing to participate in the proposed rulemaking and states that it may be able to assist in matters regarding how to coordinate disaster management efforts among governmental bodies and utilities.
4.2. CBD/SC, MGRA, and William Adams
CBD/SC, MGRA, and William Adams recommend that the Commission conduct a thorough investigation of the causes and consequences of wildfires ignited by overhead electric lines, particularly the catastrophic wildfires of October 2007. CBD/SC believes the investigation should include large wildfires that were ignited by SDG&E's overhead electric lines in 2003 to assess whether adequate steps were taken to prevent the October 2007 wildfires.
MGRA and CBD/SC urge the Commission to delay the Sunrise Powerlink Transmission Project (STP) and other new transmission lines until the Commission completes its investigation. They contend it would be reckless to build new lines without incorporating the lessons learned from prior fires. They also believe it would be cheaper to integrate new safety features into the design and construction of new transmission lines instead of retrofitting these features after the lines are built. It is also possible that new safety features may be so expensive as to render the STP and other new transmission lines uneconomic.
4.3. PG&E and SCE
PG&E and SCE support the Petition. Both concur with SDG&E's proposal to convene Commission-sponsored workshops to develop regulations and to invite other governmental bodies to participate. On the other hand, PG&E and SCE strongly oppose the suggestion by CBD/SC and MGRA to delay the construction of transmission lines until new safety features that might be developed in this proceeding can be incorporated into the design of the lines.
SCE asks that the scope of the rulemaking include the cost of proposed regulations and their effect on the reliability of utility service. In addition, SCE sees a need for Commission guidance regarding the fair allocation of cost among utilities in situations where two or more utilities share facilities (such as joint poles) that are affected by regulations adopted in the rulemaking.
4.4. CCTA, CPSD, and DRA
SDG&E concedes that its Petition does not include "proposed wording" for new or amended regulations as required by Rule 6.3(b).4 CCTA, CPSD, and DRA argue that because the Petition does not comply with Rule 6.3(b), the Commission must reject it.
CCTA also argues that the Petition does not comply with the Commission's rules for revising GO 95. In particular, Ordering Paragraph 8 of Decision (D.) 05-01-030 requires that prior to filing a petition to revise GO 95, a petitioner must first meet-and-confer with CPSD. SDG&E never did so.
CCTA maintains that the Commission has previously revised GO 95 to incorporate the lessons learned from prior disasters and, therefore, has already addressed most of the issues raised by SDG&E.5 There is no need to revisit these issues, according to CCTA, until SDG&E is able to provide concrete proposals.
CPSD believes that a rulemaking is premature because the causes of the October 2007 wildfires are still being investigated by CPSD and Cal Fire. Furthermore, CPSD contends that SDG&E has authority under GO 95 and § 451 to take steps to reduce wildfire hazards, which obviates any need for a rulemaking while CPSD conducts its investigation.
4 SDG&E Petition, p. 4.
5 See, for example, D.97-01-044, D.97-10-056, and D.05-01-030.
