Comments to the California Public Utilities Regarding the Order Instituting Rulemaking to Revise and Clarify Commission Regulations Relating to the Safety of Electric Utility and Communications Infrastructure

San Diego
March 17, 2009

I would like to thank the Commission for holding this public participation hearing in San Diego County. It’s important to hear directly from ratepayers and I appreciate your willingness to travel to our county.

It is difficult for me to have confidence that a majority of the Commission is committed to better fire protection for San Diego. The approval of the Sunrise Powerlink in December 2008 was a dangerous and deadly decision that will increase the chance of wildfire in fire prone areas in our County.

The project’s environmental document contained overwhelming evidence which showed that Sunrise will greatly impede the ability of firefighters to snuff out fires in our Backcountry. Sadly and foolishly, the Commission ignored these findings and approved the line anyway.

With that out of the way, I will briefly discuss several of the issues on the table for Phase One of this proceeding: 1. Data collection 2. Maintenance and Inspection Requirements 3. Vegetation Management and 4. High Winds.

First, I agree with the Consumer Protection and Safety Division that utilities be required to more aggressively report emergency fire-related incidents to the Commission and other vested parties immediately. This includes notifying tenants of joint-use lines.

The transparent reporting of incident data will help us learn more about the exact causes of such incidents so that we can prevent future incidents. Please prioritize this rule change.

Second, I support increased inspection and maintenance schedules for all electric transmission facilities.

It’s true that the utilities are already obligated to inspect and maintain their infrastructure in a safe manner. It’s also true that after-action fire reports have concluded that this is not always done.

The time is now for the Commission to put in place more stringent inspection guidelines, including reporting guidelines. Please consider how fire agencies and even community volunteer groups can be called upon to optimize limited funding.

Third: vegetation management. I am not a fire expert, but the County has fire experts. Unfortunately, as of late last week, they were not contacted by SDG&E to give input into improved vegetation management practices.

This is a problem given that the County coordinates fire protection for more than half the geographic area of the county, including its most fire-prone corners.

The utility must not be allowed to unilaterally decide what brush and vegetation management practices are the most effective. Instead, the utility must be ordered to work with regional fire emergency officials to develop plans tailored to communities and the region.

San Diego is among few places on the planet that experience a unique and deadly type of Santa Ana winds conditions. Vegetation management plans cannot be approached with a cookie cutter philosophy. After living through two of the worst firestorms in state history, I can tell you that every region is unique unto itself and must be approached that way.

Fourth, I support greater spacing between electric poles and swapping wooden poles for steel poles to mitigate high winds. SDG&E was encouraged after the Cedar Fire of 2003 to replace wood poles with steel poles. Six years later, I commend the utility for greatly stepping up its pole replacement efforts over the last few weeks. I wish it had been done sooner and believe the Commission should have taken a stronger regulatory role long before now.

Finally, I emphatically disagree with the decision to make SDG&E’s controversial high-wind “de-energization plan” a separate proceeding from the one before us tonight. It is not efficient, nor wise, to review the high-wind plan independent of the more comprehensive proceeding before us tonight.

Before the Commission considers such a radical proposal— which has failed to garner any sizeable community support— it should determine whether existing rules and proposed rules are adequate. Thank you for the opportunity to speak tonight.