X. Response of the Office of Ratepayer Advocates (ORA)

ORA did not file a protest to this application. However, it did file a response to the application in which it states that it does not oppose the application provided that the construction complied with the Overhead Line Safety Requirements in GO 95. ORA recommends that future § 851 applications include engineering studies demonstrating compliance with GO 95, and accepted engineering practices. It also recommends that such applications address the impact on PG&E's ability to expand its transmission capacity. In its reply to ORA's response, PG&E agrees to confirm, in future applications, that the safety and reliability of its system will not be adversely affected, and to address any impact on future expansion of transmission capacity. However, while PG&E agrees to make engineering studies available upon request, it objects to being required to submit them with the application because they are voluminous and contain sensitive information pertaining to facilities and telecommunications equipment agreements.

ORA's recommendations regarding future § 851 filings are more appropriately addressed on a generic basis. Therefore, we will not address them herein.