BEFORE THE PUBLIC UTILITIES COMMISSION OF THE STATE OF CALIFORNIA SOUTHERN CALIFORNIA EDISON COMPANY S (U 338-E) REPLY COMMENTS

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1 BEFORE THE PUBLIC UTILITIES COMMISSION OF THE STATE OF CALIFORNIA Order Instituting Rulemaking Proceeding to Consider Amendments to the Revised Right-Of-Way Rules Adopted by Decision Rulemaking SOUTHERN CALIFORNIA EDISON COMPANY S (U 338-E) REPLY COMMENTS FRANK MCNULTY GLORIA ING Attorneys for SOUTHERN CALIFORNIA EDISON COMPANY 2244 Walnut Grove Avenue Post Office Box 800 Rosemead, California Telephone: (626) Facsimile: (626) Gloria.Ing@sce.com Dated: May 15, 2017

2 BEFORE THE PUBLIC UTILITIES COMMISSION OF THE STATE OF CALIFORNIA Order Instituting Rulemaking Proceeding to Consider Amendments to the Revised Right-Of-Way Rules Adopted by Decision Rulemaking SOUTHERN CALIFORNIA EDISON COMPANY S (U 338-E) REPLY COMMENTS Pursuant to Rule 6.2 of the Rules of Practice and Procedure of the California Public Utilities Commission (Commission or CPUC) and the procedural schedule set forth in the Commission s April 3, 2017 Order Granting Petition and Order Instituting Rulemaking Proceeding to Consider Amendments to the Revised Right-of-Way Rules Adopted by Decision , Southern California Edison Company (SCE) respectfully submits the following reply comments to the May 3, 2017 opening comments. I. THE COMMISSION SHOULD NOT MANDATE A TIMELINE FOR INVESTOR OWNED UTILITIES TO PROCESS POLE ATTACHMENT REQUESTS The California Cable and Telecommunications Association s (CCTA) proposal that the Commission mandate a timeline for investor owned utilities (IOUs) to process pole attachment requests 1 should be rejected. Fundamentally, SCE believes its own application review and response time is reasonable and is aligned with the other California electric utilities. As discussed in more detail below, any efforts to regulate shorter turnaround times could 1 CCTA comments, pp

3 compromise safety and ultimately cause electric utility customers to further subsidize CLEC 2 attachments to utility poles. A. Mandated Turn Around Times Would Create a Safety Risk and Subsidy Mandated turnaround times similar to those for ILECs 3 would divert attention away from other pressing customer matters, require additional staffing, and/or reduce a utility s flexibility to manage incoming requests for attachment. In SCE s experience, pole access applications fluctuate significantly from month to month. Given this fluctuation, to process applications more quickly, SCE would either have to repurpose employees already assigned to serving our electric customers to attend to incoming applications or hire more staff who would have an uneven workload and thus be potentially idle during slow months. Likewise, SCE cannot ask its contractors to keep employees on the payroll to wait for work that may or may not materialize. CCTA s comments fail to recognize that electric utilities operate under cost of service ratemaking. Someone has to pay for this idle capacity and it will likely fall to our customers, creating another inappropriate subsidy. Moreover, CCTA does not appear to appreciate that processing attachment applications is a task that takes significant time and resources, and is a responsibility that SCE takes seriously. SCE has the responsibility to perform pole loading calculations, affirm available pole space and clearances, and otherwise affirm the requested attachment can be installed safely and timely. While SCE supports eliminating barriers to entry, achieving this goal should not be at the expense of safety and reliability. The IOUs need staffing and sufficient time to perform the necessary analysis and reviews, or else there will be negative and serious impacts on safety and reliability not only to SCE s customers and the electric system but also to the ILECs and numerous other communication companies occupying SCE s joint use poles. 2 Competitive Local Exchange Carriers. 3 Incumbent Local Exchange Carriers. 2

4 Further, CCTA s proposal seems to runs counter to the Commission s ongoing engagement in addressing pole safety. The Commission has hosted two large meetings related to pole safety in the past two years, the Utility Pole Safety En Banc on April 28, 2016 and the Pole and Conduit Database Workshop on March 17, The Commission s Safety Enforcement Division s (SED) position is that overloaded poles present a safety risk as noted in Appendix A of Risk and Safety Aspects of Southern California Edison s General Rate Case Application SED reiterates this view in its March 2017 petition to amend General Order 95, which states: Overloaded poles are one of the major causes of incidents involving injuries, fatalities, and property damage. 4 The IOUs must have adequate time to evaluate, respond, and if necessary, remedy by replacing poles. CCTA s proposal to shorten the review/response times is contrary to the Commission and SED s stated concerns of overloaded poles. II. THE UNAUTHORIZED PENALTY MUST BE INCREASED TO $15,000 The unauthorized penalty of $500 per unauthorized attachment was established in R , and has not been updated since. Given the passage of almost 20 years and lucrative nature of communication services, $500 is a paltry amount that needs to be updated or else it no longer serves as a deterrent. The amount should be increased to at least $15,000 per unauthorized attachment or the approximate cost of a distribution pole replacement as this may be different to each of the utilities territories. This amount is large enough to gain the attention of would-be unauthorized attachers and yet small enough not to significantly harm the larger CLECs and Cable TV companies. 4 P , p. 4 (emphasis added). 3

5 III. CONCLUSION In addition to these Reply Comments, SCE reaffirms its request for workshops for the reasons stated by SCE, CCTA, Pacific Gas & Electric Company, San Diego Gas & Electric Company, the Wireless Infrastructure Association, and Cox Communications provided in our respective Combined Opening Comments and Prehearing Conference Statements. Respectfully submitted, FRANK MCNULTY GLORIA ING May 15, 2017 /s/ Gloria Ing By: Gloria Ing Attorneys for SOUTHERN CALIFORNIA EDISON COMPANY 2244 Walnut Grove Avenue Post Office Box 800 Rosemead, California Telephone: (626) Facsimile: (626)

6 BEFORE THE PUBLIC UTILITIES COMMISSION OF THE STATE OF CALIFORNIA Order Instituting Rulemaking Proceeding to Consider Amendments to the Revised Right-Of-Way Rules Adopted by Decision Rulemaking CERTIFICATE OF SERVICE I hereby certify that, pursuant to the Commission s Rules of Practice and Procedure, I have this day served a true copy of SOUTHERN CALIFORNIA EDISON COMPANY S (U 338-E) REPLY COMMENTS on all parties identified on the attached service list for R Service was effected by transmitting copies via to all parties who have provided an address and by placing copies in sealed envelopes and causing such envelopes to be delivered by hand or by overnight courier to the offices of the Assigned ALJ(s) or other addressee(s). ALJ Timothy Kenney CPUC 505 Van Ness Avenue San Francisco, CA Executed on May 15, 2017, at Rosemead, California. /s/ Olivia Gutierrez Olivia Gutierrez Legal Administrative Assistant SOUTHERN CALIFORNIA EDISON COMPANY 2244 Walnut Grove Avenue Post Office Box 800 Rosemead, California 91770

7 CPUC - Service Lists - R Page 1 of 4 5/15/2017 CPUC Home CALIFORNIA PUBLIC UTILITIES COMMISSION Service Lists PROCEEDING: R CPUC - ORDER GRANTIN FILER: CPUC LIST NAME: LIST LAST CHANGED: MAY 15, 2017 DOWNLOAD THE COMMA-DELIMITED FILE ABOUT COMMA-DELIMITED FILES Back to Service Lists Index Parties SUZANNE TOLLER ATTORNEY DAVIS WRIGHT TREMAINE LLP 505 MONTGOMERY STREET, SUITE 800 SAN FRANCISCO, CA FOR: WIRELESS INFRASTRUCTURE ASSOCIATION (WIA) FORMERLY PCIA Information Only BRUCE SMITH IGOR GRINBERG GRC & REGULATORY SUPPORT REGULATORY AFFAIRS PACIFIC GAS & ELECTRIC COMPANY PACIFIC GAS AND ELECTRIC COMPANY ONLY ONLY ONLY, CA ONLY, CA INNA VINOGRADOV ICOMMLAW ONLY ONLY, CA MARIA BROWNE ATTORNEY DAVIS WRIGHT TREMAINE LLP ONLY ONLY, DC DAVIS WRIGHT TREMAINE LLP ONLY DARAH FRANKLIN GOOGLE INC.

8 CPUC - Service Lists - R Page 2 of 4 5/15/2017 ONLY, CA MASSACHUSETTS AVE., STE. 900 WASHINGTON, DC D. ZACHARY CHAMP RICHARD T. CHIP HOWELL WIRELESS INFRASTRUCTURE ASSOCIATION AREA MGR - REGULATORY RELATIONS 500 MONTGOMERY STREET, STE. 500 AT&T ALEXANDRIA, VA S. AKARD ST., RM FOR: WIA (FORMERLY PCIA) DALLAS, TX GLORIA M. ING KAREN CHUNG SR ATTORNEY MGR - PROJECT SOUTHERN CALIFORNIA EDISON COMPANY SOUTHERN CALIFORNIA EDISON COMPANY 2244 WALNUT GROVE AVE 2244 WALNUT GROVE AVENUE ROSEMEAD, CA ROSEMEAD, CA FOR: SOUTHERN CALIFORNIA EDISON COMPANY CASE ADMINISTRATION STACIE ATKINSON SOUTHERN CALIFORNIA EDISON COMPANY REGULATORY CASE ANALYST 8631 RUSH STREET SAN DIEGO GAS & ELECTRIC COMPANY ROSEMEAD, CA CENTURY PARK COURT SAN DIEGO, CA REBECCA W. GILES JESUS.G ROMAN REGULATORY CASE MANAGER VERIZON SAN DIEGO GAS & ELECTRIC COMPANY SAND CANYON AVE. D CENTURY PARK COURT, CP32-F IRVINE, CA SAN DIEGO, CA WILLIAM K. SANDERS MARGARET TOBIAS DEPUTY CITY ATTORNEY ATTORNEY AT LAW CITY AND COUNTY OF SAN FRANCISCO TOBIAS LAW OFFICE CITY HALL RM PENNSYLVANIA AVE 1 DR. CARLTON B. GOODLETT PLACE SAN FRANCISCO, CA SAN FRANCISCO, CA FOR: CITY AND COUNTY OF SAN FRANCISCO (SAN FRANCISCO) DAVID J. MILLER FASSIL T. FENIKILE AVP - SR. LEGAL COUNSEL DIR. - REGULATORY AT&T SERVICES, INC. AT&T SERVICES, INC 430 BUSH STREET, ROOM BUSH STREET, 5TH FL SAN FRANCISCO, CA SAN FRANCISCO, CA MICHELLE CHOO THOMAS SELHORST ASSISTANT SENIOR PARALEGAL AT&T SERVICES, INC. AT&T CALIFORNIA, INC. 430 BUSH STREET, 3ND FL. NO BUSH STREET, 3RD FL, NO. 14 SAN FRANCISCO, CA SAN FRANCISCO, CA JAMES W. TOMLINSON SARAH DEYOUNG DAVIS WRIGHT TREMAINE, LLP EXECUTIVE DIRECTOR 505 MONTGOMERY STREET, SUITE 800 CALTEL SAN FRANCISCO, CA CALIFORNIA ST., STE SAN FRANCISCO, CA 94111

9 CPUC - Service Lists - R Page 3 of 4 5/15/2017 ZEB ZANKEL ANITA TAFF-RICE ATTORNEY ATTORNEY DAVIS WRIGHT TREMAINE LLP ICOMMLAW 505 MONTGOMERY STREET, STE PALOS VERDES, NO. 298 SAN FRANCISCO, CA WALNUT CREEK, CA State Service ADAM CLARK ALEXANDER J. ABRAMSON OFFICE OF RATEPAYER ADVOCATES BROADBAND, POLICY & ANALYSIS BRANCH AREA 2-D AREA AROCLES AGUILAR CAMERON REED LEGAL DIVISION COMMUNICATIONS AND WATER POLICY BRANCH ROOM 5138 AREA FOR: ORA CAROLINA CONTRERAS CHARLOTTE TERKEURST OFFICE OF THE SAFETY ADVOCATE ELECTRIC SAFETY AND RELIABILITY BRANCH AREA AREA FOR: OSA CHRIS WITTEMAN DOROTHY DUDA LEGAL DIVISION EXECUTIVE DIVISION ROOM 5028 ROOM 5116 ELIZABETH PODOLINSKY GLENN SEMOW PRESIDENT PICKER BROADBAND, POLICY & ANALYSIS BRANCH ROOM 5306 AREA 3-F MICHAEL C. AMATO MICHAEL MORRIS COMMUNICATIONS DIVISION BROADBAND, POLICY & ANALYSIS BRANCH ROOM 3211 ROOM 3-F

10 CPUC - Service Lists - R Page 4 of 4 5/15/2017 TIMOTHY KENNEY TOVAH TRIMMING DIVISION OF ADMINISTRATIVE LAW JUDGES LEGAL DIVISION ROOM 5015 ROOM 4107 TOP OF PAGE BACK TO INDEX OF SERVICE LISTS

BEFORE THE PUBLIC UTILITIES COMMISSION OF THE STATE OF CALIFORNIA

BEFORE THE PUBLIC UTILITIES COMMISSION OF THE STATE OF CALIFORNIA Order Instituting Rulemaking Proceeding to Consider Amendments to the Revised Right-Of-Way Rules Adopted by Decision 16-01-046. Rulemaking