V. Complainant's Position

In its July 8 opposition to SDG&E's proposed pole attachment fee, Complainants determined the annual charge to be $21.88 per wood transmission pole and $239.33 per steel transmission pole. Complainants spread total pole costs over all poles, incorporate an appurtenance adjustment factor of 15% for both wood and steel poles, calculate a 9.33% ROW overhead factor and base maintenance and A&G expense factors on recorded 2000 information.