Details for: SDGE Protest Reply - AL 3595-E.pdf

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Clay Faber - Director
CA & Federal Regulatory
8330 Century Park Ct
San Diego, CA 92123

October 12, 2020

ED Tariff Unit
California Public Utilities Commission
505 Van Ness Avenue
San Francisco, California 94102



In accordance with Section 7.4.3 of General Order 96-B, San Diego Gas & Electric Company (“SDG&E”)
hereby replies to the Protest filed by the Public Advocates Office at the California Public Utilities
Commission (“Cal Advocates”) to SDG&E Advice Letter (“AL”) 3595-E, San Diego Gas & Electric Track 1
Workplans Demonstrating Compliance with Decision 20-07-004 submitted on September 14, 2020.
SDG&E submitted AL 3595-E to the California Public Utilities Commission (“CPUC” or “Commission”),
pursuant to Ordering Paragraph (OP) 3 of Decision (D.) 20-07-004 (Decision) which directs SDG&E to file
and serve Track 1 Workplans to demonstrate compliance with the Decision’s ordered modifications.
SDG&E respectfully disagrees with the discussion points in the Cal Advocates protest of AL 3595-E on
October 5, 2020t. Cal Advocates asserts that SDG&E’s interpretation of the “1,00” typo in D.20-07-004
is incorrect and suggests the database would be “reduced in usefulness” 1 if not given the 1,000-pole
selection. SDG&E does not agree and believes that D.20-07-004 reasonably determined that 100 poles
was sufficient, based on the record in Track 1 of this proceeding.
The Record Supports SDG&E’s Interpretation
Cal Advocates states that the “100 poles interpretation is not supported by the record” 2. SDG&E believes
this is inaccurate and, to the contrary, the record does not contain support for requiring the 1,000 pole
selection other than Cal Advocates’ assertion that it is necessary for “statistical analysis”.3 SDG&E
submitted Reply Comments to the Track 1 Proposed Decision on June 8, 2020 pointing out that the
The Public Advocates Office’s Protest Letter of San Diego Gas & Electric Advice Letter 3595-E to CPUC
Energy Division and Communication Division (October 5, 2020) at 2.
2 Id.
3 Investigation (I.) 17-06-027, Opening Comments of the Public Advocates Office on the May 11, 2020
Proposed Decision Approving Track 1 Workshop Report Work Plans (June 1, 2020) at 6 (citing to Public
Advocates Office Track 1 Workshop Report Opening Comments, p. 4).


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Public Utilities Commission October 12, 2020 1,000-pole limit was out of scope and without justification. 4 SDG&E’s Reply Comments go on to argue that the ability to select more than 100 poles is not necessary. Toward that end SDG&E’s Reply Comments state, “SDG&E’s application process has a maximum 100 pole limit, per application. Attaching parties have never expressed the need to submit applications for more than the 100-pole limit, 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.”5 Given SDG&E’s Reply Comments on the Track 1 Proposed Decision, responding to Cal Advocate’s comments, it is reasonable to conclude that the Commission considered how unnecessary the 1,000-pole limit was and the typo is actually the inadvertent addition of the comma to “1,00”. Use of 100 Poles Would Not Reduce Usefulness SDG&E does not believe that its interpretation would reduce the usefulness of the database. Having the ability to select, view and export data on 100 poles is effective for the purpose of providing information required by the relevant stakeholders to submit pole attachment applications or other related purposes. 6 The use cases for the database were vetted and discussed during the Track 1 workshops and they did not include a discussion of any required statistical analysis, nor the need to select 1,000 poles, which is reflected in the Track 1 Workshop Report.7 Furthermore, as the data is exportable, an entity such as Cal Advocates can simply conduct multiple searches and compile and analyze the data once it has been extracted. Use of 1,000 Poles Was Not Vetted Among Relevant Stakeholders Lastly, SDG&E would like to reiterate that this limit was not properly discussed in workshops or properly vetted among parties. After a preliminary feasibility review, we are finding that if this 1,000-pole limit is enforced it will be extremely difficult to achieve. To get to 100 poles will be a challenge, let alone 1,000. Some of the preliminary issues we are facing with just 100 are: how to make it viewable on screen with a clear resolution, capacity issues on a screen, and functionality concerns with polygonal selection of 100 poles. To achieve 10x that amount will be even more burdensome. Further, both AT&T, Frontier and Pacific Gas and Electric Company (PG&E) noted that a requirement that over extends the searchability of the database could overwhelm the systems or cause declining performance of the system 8 I.17-06-027, Reply Comments of SDG&E on the Proposed Decision Approving Track 1 Workshop Report Work Plans for San Diego Gas & Electric Company, Southern California Gas Company, Pacific Gas and Electric Company, AT&T, and Frontier Communications of California (June 8, 2020) (SDGE Reply Comments) at 4. 5 Id. 6 See I.17-06-027, Order Instituting Investigation into the Creation of a Shared Database or Statewide Census of Utility Poles and Conduit (July 10, 2017). 7 See I.17-06-027, Track 1 Workshop Report for Workshops Held on August 13-14, 2019 and September 6, 2019 filed by Southern California Edison Company (October 2, 2019), available at 8 I.17-06-027, SDG&E Reply Comments at 4, Opening Comments of AT&T and Frontier on Proposed Decision (June 1, 2020) at 11, Reply Comments of AT&T and Frontier on Proposed Decision (June 8, 2020) at 5, and Reply Comments of PG&E on Proposed Decision Approving Track 1 Workshop Report Work Plans (June 8, 2020) at 2. 4 2
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Public Utilities Commission October 12, 2020 CONCLUSION SDG&E respectfully requests that the protests be rejected for the reasons stated above and SDG&E’s Advice Letter 3595-E is approved as written. Sincerely, ________________________ CLAY FABER Director – CA & Federal Regulatory cc: Edward Randolph – Energy Division Director Chloe Lukins – Cal Advocates Service List I.17-06-027 3
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