Details for: SCE's Reply to Public Advocates Office Protest to Advice 4292-E.pdf

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Gary A. Stern, Ph.D.
Managing Director, State Regulatory Operations

October 12, 2020

Energy Division
Attention: Tariff Unit
California Public Utilities Commission
505 Van Ness Avenue
San Francisco, CA 94102

Southern California Edison Company’s Reply to the Public
Advocates Office’s Protest to Advice Letter 4292-E

Dear Energy Division Tariff Unit:
Pursuant to Rule 7.4.3 of General Order 96-B, Southern California Edison
Company (SCE) submits the following reply to the October 5, 2020 protest by the Public
Advocates Office (Cal Advocates) to SCE’s September 14, 2020 Advice Letter 4292-E,
which contained SCE’s modified Track I work plan demonstrating compliance with
California Public Utilities Commission (CPUC or Commission) Decision (D.) 20-07-004.


SCE respectfully requests that the Commission affirm its intent to require pole
owners to make available for viewing and export (as machine readable data) at least 10
poles by July 21, 2021, and 100 poles (vs. 1,000 poles, as advocated by Cal Advocates
in its protest) by July 21, 2022 as set forth in D.20-07-004.1 For the reasons stated
below, SCE believes that Cal Advocates’ interpretation of D. 20-07-004 is incorrect.

Response to the Protest

As a threshold matter, SCE continues to disagree with Cal Advocates’ eleventh
hour recommendation that the utilities export pole data2 because this recommendation
was not thoroughly vetted in publicly noticed workshops and was first proffered in Cal
Advocates’ June 1, 2020 Opening Comments to the Commission’s May 11, 2020


D.20-07-004, Ordering Paragraph 2(k), pp. 33-34.
Reply Comments of SCE on Proposed Decision Approving Track 1 Workshop Report Work
Plans, filed June 8, 2020, pp. 3-4.

P.O. Box 800

8631 Rush Street

Rosemead, California 91770

(626) 302-9645

Fax (626) 302-6396


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Energy Division Tariff Unit Page 2 October 12, 2020 Proposed Decision (PD).3 Significantly, the PD included no mention of exporting data sets for poles. Thus, it was and remains SCE’s belief that because Cal Advocates was the only party specifically requesting a research and export capability of data sets for 1000 poles in its Opening Comments,4 and after giving due consideration to the Opening and Reply Comments filed by AT&T California (AT&T)/Frontier of the Southwest (Frontier), San Diego Gas & Electric Company (SDG&E), Pacific Gas and Electric Company (PG&E), and SCE on the PD, that the Commission determined that exporting data sets for up to 100 poles was more reasonable than exporting data sets for 1,000 poles. Specifically, SCE calls attention to the following opening and reply comments on the PD filed by other pole owners that expressed concerns regarding search capability requirements in Track 1, took issue with Cal Advocates’ proposed 1,000 pole selection criteria, or specifically advocated to have a 100 pole limit: • • 3 4 5 6 In its Reply Comments,5 SDG&E pointed out that Cal Advocates’ 1,000 pole selection criteria seemed irrelevant and arbitrary, that such a large number is unnecessary for carrying out specific use cases considered in Track 1, that SDG&E’s Telecommunications Equipment Attachment Management System (TEAMS) application has a maximum 100 pole limit, per application, and that attaching parties have never expressed the need to submit applications for more than the 100 pole nor have past incident data requests issued to SDG&E regarding pole data been more than a few dozen at most at any given time. In their joint Opening Comments,6 AT&T and Frontier pointed out the precise contours of searchability were not determined by the stakeholders in the workshops, and unlimited searching raises issues that are not considered by the PD. For example, if search capabilities are available to all users and are unlimited, searches of all the Data Points for the millions of poles in California could risk overwhelming the systems. In addition, allowing competitors to search for each other’s attachments (e.g., all “Sonic” attachments), and export the results would facilitate the creation of service maps that could be A clear reading of the Track 1 Workshop Report filed by SCE on October 2, 2019 includes no references to a discussion or vetting by parties on the topic of data export during the August 13-14, 2019, and September 6, 2019, workshops. Opening Comments of the Public Advocates Office on the May 11, 2020 Proposed Decision Approving Track 1 Workshop Report Work Plans, filed June 1, 2020, pp. 5-6. Reply Comments of San Diego Gas & Electric (U 902E) on Proposed Decision Approving Track 1 Workshop Report Work Plans for San Diego Gas & Electric Company, Southern California Edison, Pacific Gas and Electric Company, AT&T, and Frontier Communications of California, filed June 8, 2020, p. 4. Opening Comments of AT&T and Frontier on Proposed Decision filed June 1, 2020, p. 11.
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Energy Division Tariff Unit Page 3 October 12, 2020 used for anticompetitive purposes. For these reasons, AT&T and Frontier requested that the establishment of appropriate search capabilities be addressed in the working groups required by the PD. • In its Reply Comments,7 PG&E affirmed that it was open to discussing potential increases to the number of poles to query. However, PG&E’s Joint Use Map Portal (JUMP) has a current limit of 25 poles, which aligns with the maximum number of poles for a single intent in the Northern California Joint Pole Association (NCJPA). Significantly, PG&E found that performance of the tool declines beyond 25 poles because the JUMP portal also allows successive queries at 25 pole increments. In summary, SCE believes the Commission took into account parties’ comments that requiring utilities to export an excessive number of poles within one year of July 1, 2020 is unreasonable, impractical, and unnecessary, and, specifically, that Cal Advocates’ proposal to increase the number from 10 poles to 1000 poles is arbitrary and irrelevant.8 In contrast, requiring utilities to increase the number of poles to be exported from 10 poles by July 21, 2021 to 100 poles by July 22, 2022 is a more reasoned and feasible requirement than increasing the number of poles from 10 to 1,000 in one year as advocated by Cal Advocates. III. Conclusion Based on the well-reasoned comments submitted by poles owners and given the limitations and constraint on the pole owners’ databases to correlate and export large volumes of pole data, SCE respectfully requests that the Commission dismiss the Cal Advocates’ protest of SCE’s Track 1 Work Plan and affirm the Commission’s intent to require pole owners make available for viewing and export (as machine readable data) at least 10 poles by July 21, 2021, and 100 poles (vs. 1,000 poles, as advocated by Cal Advocates) by July 21, 2022, as set forth in D.20-07-004. 7 8 Reply Comments of Pacific Gas and Electric Company (U39) on Proposed Decision Approving Track 1 Workshop Report Work Plans, filed June 8, 2020, pp. 1-2. In D.20-07-004, the Commission did not include a discussion in the body of the decision that specifically addressed the increased number of poles from 10 to 100 or 1000.
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Energy Division Tariff Unit Page 4 October 12, 2020 Should you have any questions, please contact June Bote at (714) 895-0585 or by electronic mail at Sincerely, /s/ Gary A. Stern, Ph.D. Gary A. Stern, Ph.D. GAS:jb/gi:jm cc: Edward Randolph, Director, CPUC Energy Division Chloe Lukins, Public Advocates Office Robert Osborn, Director, Communications Division Alan Bach, Public Advocates Office Cameron Reed, Public Advocates Office Tim Drew, Public Advocates Office Service List I.17-06-027
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