I. Underlying Policy Dispute Between the Parties

The parties dispute many factual, legal and policy issues. However, the fundamental underlying dispute between them is this: CPSD believes that failure to comply with any provision of any of the Commission's GOs at issue is a violation that can subject Edison to penalties. Edison believes that failure to comply with the GOs in the first instance is only a "nonconformance" or "variance" with the GOs. According to Edison, if a utility has a reasonable maintenance program that prioritizes the correction of a nonconformance, and performs such corrective action according to its priority schedule, it is complying with the GOs.