VI. The General Orders

A. GO95

The purpose of GO 95 is to formulate uniform requirements for overhead electrical line construction so as to ensure adequate service and secure safety to persons engaged in the construction, maintenance, operation or use of overhead electrical lines, as well as to the general public.¹

Edison argues that GO 95 (and GO 128, discussed below) were never intended to set maintenance standards, as opposed to construction standards, except where explicitly stated. We disagree.

Section 12.2 of GO 95 makes clear that the utilities are to maintain, as well as construct, their systems in conformity with the GO.

"All lines and portions of lines shall be maintained in such condition as to provide safety factors not less than those specified in Rule 44.2 ines and portions of lines constructed or reconstructed on or after the effective date of this Order shall be kept in conformity with the requirements of this Order."²

B. GO 128

The purpose of GO 128, which has been effective since 1967, is to formulate uniform requirements for underground electrical supply and communication systems so as to ensure adequate service and secure safety to all persons engaged in the construction, maintenance, operation or use of underground systems, as well as to the general public. Like GO 95, GO 128 sets both construction and maintenance standards. (See § 12.2.)³

C. GO 165

The need for basic maintenance schedules underlies the inspection schedules developed in GO 165. This GO, enacted in 1997, establishes minimum requirements for electric distribution facilities regarding inspection, condition rating, scheduling and performance of corrective action, record-keeping, and reporting, so as to ensure safe and high quality electric service. After considering points raised by staff and evaluating the expected safe lifespan information the utilities submitted, the Commission established several sets of minimum maintenance inspection intervals.

¹ GO 95 § 11. ² GO 95 became effective July 1, 1942, superseding GO 64 and GO 64-A, which had been in effect since 1922 and 1928, respectively. The sections of GO 95 addressing line construction and reconstruction apply to lines and extensions of lines constructed after the effective date of the order, and to any portion of a line constructed prior to GO 95's effective date if reconstructed. In this proceeding, Edison does not argue that GO 95 or GO 128 is inapplicable to any of the alleged violations because the lines in question were constructed or reconstructed prior to the effective date of GO 95. ³ Section 12.2 provides that utility systems "shall be maintained in such condition as to secure safety to workmen and the public in general. Systems and portions thereof constructed, reconstructed, or replaced on or after the effective date of these rules shall be kept in conformity with the requirement of these rules."