Details for: PGE Reply to Protest to AL 5948-E.pdf


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Erik Jacobson
Director
Regulatory Relations

Pacific Gas and Electric Company
77 Beale St., Mail Code B23A
P.O. Box 770000
San Francisco, CA 94177
Fax: 415-973-1448

October 12, 2020
California Public Utilities Commission - Energy Division
Tariff Unit
505 Van Ness Avenue, 4th Floor
San Francisco, CA 94102
Subject:

Pacific Gas and Electric Company’s Reply to the Protest from the
Public Advocates Office Protest of Advice Letter 5948-E

Dear Energy Division Tariff Unit:
Pacific Gas and Electric Company (PG&E) hereby responds to the protest from the
Public Advocates Office (PAO) to Advice 5948-E which submitted PG&E’s revise Track
1 Workplan regarding the development of a pole data base being considered in I.17-06027.
PG&E respectfully requests that the Commission reject the PAO’s protest and approve
Advice 5948-E as filed.
PAO disputes PG&E’s interpretation of an obvious typographical error in Decision (D.)
20-07-004 which would require PG&E’s pole data base to be able to allow for the
selection of “1,00” poles at one time within two years.
PG&E acknowledges that PAO introduced the concept of requiring access to the data
regarding “1,000” poles during the workshops. However, that goal was not supported
by the other parties.
In its comments on the Proposed Decision (PD) PAO
recommended that the Commission include the requirement of access to the data for
“1,000” poles in the required revisions to the utilities’’ Track 1 Workplans. In reply
comments, PG&E pointed out that its JUMP system’s current limit is 25 poles, but that
PG&E would be open to discussion regarding increasing the number of poles that could
be queried.
PG&E could not support PAO’s workshop position because there is great uncertainty
that the PG&E’s system could be scaled up to allow a 4,000 percent increase in the
number of poles the system is able to query. Aside from issues related to downloading
that volume of data, it is not clear how a user could identify a 1,000 pole population.
The attached file shows screen shots, centered on the same pole, of a population of 25





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PG&E Reply to Protest of Advice Letter 5948-E -2- October 12, 2020 poles, 100 poles and 1,000 poles. At the 1,000 pole scale, the identity of the individual poles is lost. Although the final decision did add the language proposed by POA as item 2(k), given that PAO’s position for access to data for 1,000 poles was not the parties’ consensus, that PG&E’s commented as being open to discussing an increase to the number of poles that could be accessed at one time, that it would be unreasonable for the Commission to adopt a mandate that may well be technically infeasible, PG&E’s belief that the Commission intended an expanded population of “100” is reasonable. Accordingly, PG&E respectfully requests that the Commission reject the PAO’s protest and approve Advice 5948-E as filed. Sincerely, /S/ Erik Jacobson Director, Regulatory Relations cc: Edward Randolph, Director & Deputy Executive Director, CPUC Energy Division Robert Osborn, Director, Communications Division Alan Bach, Public Advocates Office Cameron Reed, Public Advocates Office Candace Choe, Public Advocates Office Tim Drew, Public Advocates Office Chloe Lukins, Public Advocates Office Kimberly Loo, PG&E, KELM@pge.com Service List I.17-06-027.
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Attachment 1 Windows of Poles 25, 100, and 1,000
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Windows of Poles 25, 100, and 1,000 1. Approximately 25 poles in JUMP (Max is 25 for selecting for Data) SAP ID# 100907116 is the Center Pole 2. Approximately 100 Poles in JUMP. SAP ID# 100907116 is the Center Pole
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3. Approximately 1000 Poles. SAP ID# 100907116 is the Center Pole
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