We decline to adopt PR 5 to the extent it seeks the same amendments to Rule 31.1 that we adopt for Rule 18-A(2)(a)(ii) in Section 4.2.3.3.2 of today’s Decision. We find that it would be redundant for Rule 31.1 to contain the same text as Rule 18A(2)(a)(ii). We reject the remainder of PR 5 for the same reasons we reject the corresponding parts of PR 3 in Section 4.2.3.3.2 of today’s Decision. Proposed Regulation 6 re: GO 95, Rule 31.5 Summary of Proposal Rule 31.5 of GO 95 requires utilities to consider the joint use of poles when constructing or reconstructing overhead facilities. Rule 31.5 further states that “[n]othing herein shall be construed as... granting authority for the use of any poles without the owner’s consent (see Rule 32.2 and Section IX).” In PR 6, SDG&E proposes to Rule 31.5 to state that all pole attachments in Tiers 2 and 3 of the High Fire-Threat District “must have the consent of a pole owner or granting authority prior to any construction,” and that any attachment without such consent may be reported to the Commission. The text of SDG&E’s proposed revisions to Rule 31.5 is contained in Appendix A of today’s Decision. SDG&E recommends that its proposed revisions take effect upon the Commission’s adoption of PR 6. SDG&E opines that PR 6 should not result in increased costs. Positions of the Parties In support of its PR 6, SDG&E asserts there have been incidents—notably the Malibu Canyon Fire in October 2007—in which poles failed because, in part, unauthorized attachments overloaded the poles. SDG&E posits that obtaining
the minimum vegetation clearances everywhere else in California. The following table lists the minimum vegetation clearances for Case 14 and Case 13: 3a GO 95, Rule 35, Table 1, Case 14 Minimum Radial Clearance Between Lines and Vegetation in High Fire-Threat Areas of Southern California Kilovolts (kV) 0.75 – 2.4 kV 2.4 – 72 kV 72 – 110 kV 110 – 500 kV >500 kV 18 inches 48 inches 72 inches 120 inches 120 inches + 0.4 inch for each kV >500 3b GO 95, Rule 35, Table 1, Case 13 Minimum Radial Clearance Between Power Lines and Vegetation in all other parts of California 0.75 – 300 kV >300 kV 18 – 37.5 inches, depending on voltage 75 inches + 0.2 inch for each kV >300 All Clearances in Tables 3a and 3b for Normal Annual Weather Variations. In PR 7, the FSTP proposes to replace the provisions in Case 14 that pertain specifically to high fire-threat areas in Southern California on the Interim FireThreat Maps with provisions that refer to Tier 3 of the High Fire-Threat District in Southern California. In PR 7/AP-1, SED proposes to amend Case 14 so that the minimum vegetation clearances in Case 14 apply to the entire High Fire-Threat District (Zone 1, Tier 2, and Tier 3) statewide. In PR 7/AP2, PG&E proposes to amend
Assisting one another in preparing for, responding to, and mitigating the effects of wildfires. Creating an Interagency Fire Safety Working Group to vet ideas and develop programmatic solutions to shared goals in the interest of fire safety and resource protection. The MOU identifies several immediate goals, including the following: Developing a shared understanding of the use of fire mapping, including enhanced enforcement of GO 95. Identifying any mitigation measures that the utilities need to take in response to the tree mortality crisis. Working together to (1) identify the requirements of the wildfire prevention plans required by Pub. Util. Code §§ 8386 – 8387 and communication of these requirements to the utilities, and (2) developing a process to review the wildfire prevention plans. Providing complementary resources in the areas of risk and risk management. The MOU states that CAL FIRE will perform specified activities and functions to carry out the intent of the MOU, including the following: Upon request, review wildfire-mitigation plans in accordance with Pub. Util. Code §§ 8385 – 8387, and assist the CPUC in developing criteria and standards to be used in plans. Identify and develop contracting requirements necessary to complete the High Fire-Threat District Map and establish the CPUC Wildfire Mitigation Section in accordance with Pub. Util. Code §§ 8386 8387. This includes: Participate in the Independent Review Team as defined in D.17-01-009. Assess, evaluate, and provide formal feedback via public comments or reports on future
development. The IRT-approved CPUC Fire-Threat Map filed on November 17, 2017, provides a reasonable estimate for the size of the statewide Tier 2 and Tier 3. D.17-01-009 requires that (i) existing fire-safety regulations that apply to high firethreat areas in Southern California on the Interim Fire-Threat Maps be transferred to Tier 3 fire-threat areas in Southern California on the statewide High Fire-Threat District Map; (ii) existing firesafety regulations that apply to high fire-threat areas in Northern California on the Interim Fire-Threat Maps be transferred to Tier 3 fire-threat areas in Northern California on the statewide High Fire-Threat District Map; and (iii) the transfer of existing firesafety regulations be completed no later than September 1, 2018. The Workshop Report filed on July 10, 2017, contains 31 proposed regulations for the High Fire-Threat District. The regulations adopted by today’s Decision will improve the fire safety of overhead power-line facilities and aerial CIP facilities in close proximity to overhead power lines. Any additional costs these new regulations impose on utilities are offset by substantial publicsafety benefits. The proposed regulations that are not adopted by today’s Decision have one or more of the following defects: (i) the proposed regulation provides less public safety relative to existing regulations; (ii) the proposed regulation is not within the scope of this proceeding; (iii) the proposed regulation is contrary to the firesafety goals of this proceeding; (iv) there is no demonstrated need for the proposed regulation; (v) the costs and burdens of the proposed regulation are not adequately known at this time; and/or (vi) existing regulations are sufficient.