BEFORE THE PUBLIC UTILITIES COMMISSION
OF THE
STATE OF CALIFORNIA
PRESIDENT MICHAEL PICKER,
COMMISSIONER CLIFFORD RECHTSCHAFFEN,
ADMINISTRATIVE LAW JUDGES PETER V. ALLEN and
SARAH R. THOMAS, co-presiding

Order Instituting Rulemaking to
Implement Electric Utility Wildfire
Mitigation Plans Pursuant to Senate
Bill 901 (2018).

)
)
)
)
)
)
)
)
)
)

PREHEARING
CONFERENCE

Rulemaking
18-10-007

REPORTER'S TRANSCRIPT
San Francisco, California
November 14, 2018
Pages 1 - 69
PHC

Reported by:

Carol A. Mendez, CSR No. 4330
Shannon Ross, CSR No. 8916

PUBLIC UTILITIES COMMISSION, STATE OF CALIFORNIA
SAN FRANCISCO, CALIFORNIA

 2

1

SAN FRANCISCO, CALIFORNIA

2

NOVEMBER 14, 2018 - 10:30 A.M.

3
4
5

*

*

*

*

*

ADMINISTRATIVE LAW JUDGE ALLEN:
record.

6

On the

Good morning.
This is the time and place for the

7

Prehearing Conference and the Order

8

Instituting Rulemaking to Implement Electric

9

Utility Wildfire Mitigation Plans, Pursuant

10

to Senate Bill 901, Rulemaking 18-10-007.

11

Before we get started with this, I

12

would like to take one minute of silence for

13

the victims in the current wildfires.

14

(Moment of silence held for

15

current wildfire victims.)

16

ALJ ALLEN:

17

Thank you.

With me today is Administrative Law

18

Judge Sarah Thomas, Commissioner

19

Rechtschaffen, and President Picker.

20

So this is going to be, essentially,

21

time for housekeeping.

22

webcast; so when you speak, please try to

23

speak towards one of the microphones.

24

sure the green light is on and that way,

25

people on webcast can hear what you're

26

saying.

27
28

This is being

Make

With that, what I would like to do
is turn it over to President Picker and

PUBLIC UTILITIES COMMISSION, STATE OF CALIFORNIA
SAN FRANCISCO, CALIFORNIA

 3

1

Commissioner Rechtschaffen if they have any

2

words to say.

3

PRESIDENT PICKER:

Thank you.

4

The horribly tragic events of last

5

week are still unfolding and the details are

6

just beginning to be investigated, but it's

7

very evident that the loss of life and

8

property due to the wildfires in northern

9

California and in southern California, and at

10

the end of this year, exceed historical marks

11

by any measure.

12

those families and to those communities who

13

have been affected.

14

I extend my condolences to

We are one of several government

15

agencies, including our colleagues at

16

Cal Fire and the Office of Emergency Services

17

who are tasked with ensuring that the

18

utilities, both investor-owned and

19

publicly-owned, operate a safe and reliable

20

grid.

21

In this proceeding, we'll look at

22

the wildfire mitigation plans of the

23

utilities.

24

some of the requirements as part of our

25

overall work with Cal Fire on vegetation and

26

setting new standards for vegetation

27

management.

28

We have previously established

I encourage local communities who

PUBLIC UTILITIES COMMISSION, STATE OF CALIFORNIA
SAN FRANCISCO, CALIFORNIA

 4

1

are active participants in this, even if

2

they've never thought of themselves as that,

3

first responders and others to participate in

4

the proceedings and to contact us if you have

5

questions about the best way to do that.

6

Now, we're operating on a fairly

7

tight timeline.

The legislature created a

8

whole series of new requirements.

9

going to focus on those preexisting wildfire

This is

10

management plans, but there are a range of

11

other issues that we'll have to address on a

12

fairly expedited basis.

13

will be working closely with Commissioner

14

Rechtschaffen to make sure that all these

15

different proceedings are coordinated and

16

that they're coherent together as a universe

17

of actions at the end.

18
19
20

Because of that, I

I'll turn it over to Commissioner
Rechtschaffen at this point.
COMMISSIONER RECHTSCHAFFEN:

I'll say a

21

couple of things.

22

week underscore - not that we needed any

23

underscoring - that the threat of wildfires

24

is one of the most pressing threats facing

25

the state right now.

26

of life and the tragedy is almost

27

unimaginable.

28

The events of the last

The scope of the loss

And this is a central priority for

PUBLIC UTILITIES COMMISSION, STATE OF CALIFORNIA
SAN FRANCISCO, CALIFORNIA

 5

1

us going forward.

2

proceedings, as President Picker mentioned,

3

many staff working on this.

4

of more importance to us.

5

We will have many

There is nothing

And in your comments here and

6

otherwise, please be thinking about how best

7

we coordinate these proceedings, what makes

8

sense to have part of this proceeding, part

9

of other proceedings, the timing in which

10

things should be done, the way to get the

11

maximum public participation and stakeholder

12

participation, how things relate to each

13

other.

14

to plot out what's going to be a very

15

punishing schedule for all of us, advocates

16

included, as well as our staff, to get these

17

plans approved, turned around, and the other

18

mandates by SB-901 and other legislation

19

implemented.

20
21

That will be very helpful as we try

Thanks.

ALJ ALLEN:

Thank you.

The next thing I want to do is take

22

appearances, and get party status.

For those

23

who may not be familiar, we have party

24

status, which is for the people who will be

25

actively participating in the proceedings.

26

It's also possible to be information only.

27

If you are information only, you would get

28

served with everything that's served in the

PUBLIC UTILITIES COMMISSION, STATE OF CALIFORNIA
SAN FRANCISCO, CALIFORNIA

 6

1

proceeding, but would not be a party.

2

So if you are in a monitoring kind

3

of role, information only would probably be

4

the most suitable role.

5

planning to do something, you should probably

6

become a party.

If you're actually

7

What I generally try to do is make

8

it relatively easy to switch back and forth.

9

So if you are only monitoring at the time,

10

sign up for information only.

11

the service list as information only and

12

later decide that you want to be a party,

13

please just send an email, and then emails in

14

this case for procedural things should go to

15

both Judge Thomas and I.

16

us on all emails on process issues.

17

If you are on

Please copy both of

If you request party status when you

18

are information only, we would make you a

19

party.

20

party and you don't do anything in the

21

proceedings, as it comes time to do a

22

decision, we may bump you down to information

23

only, and certainly we would not do that in

24

secret.

25

By the same token, if you become a

I have some forms requesting party

26

status:

Lisa Cottle for NextEra Transmission

27

requesting party status, which is granted.

28

Ronald Liebert for California Manufacturers

PUBLIC UTILITIES COMMISSION, STATE OF CALIFORNIA
SAN FRANCISCO, CALIFORNIA

 7

1

and Technology Association, CMTA, requesting

2

party status; that is granted.

3

Mills for the California Farm Bureau

4

Federation, requesting party status; that is

5

granted.

6

of San Francisco, party status.

7

Moosen for Local Government Sustainable

8

Energy Coalition, that's granted.

9

received motions for party status from the

Karen Norene

William Rostov for City and County
And Irene

I also

10

City of Malibu and County of Inyo; those

11

motions for party status are also granted.

12

In addition, I have requests for

13

information only:

14

Kawakami for East Bay MUD, and Benjamin

15

Bodell with Best, Best & Krieger.

16
17
18

Alyssa Koo for PG&E; Brett

Are there additional people who
request?
MS. MAURATH SOMMER:

April Maurath

19

Sommer for Protect our Communities

20

Foundation.

21

ALJ ALLEN:

22

MS. MAURATH SOMMER:

23

ALJ ALLEN:

24
25

Okay.

That's granted.
Great.

Thank you.

Any other people requesting

party status?
MS. STROTTMAN:

Good morning.

Britt

26

Strottman, Baron & Budd, representing the

27

County of Sonoma, County of Napa, County of

28

Mendocino, County of Lake, County of Yuba,

PUBLIC UTILITIES COMMISSION, STATE OF CALIFORNIA
SAN FRANCISCO, CALIFORNIA

 8

1

County of Nevada, and the City of Napa, the

2

City of Santa Rosa, and the City of Clear

3

Lake, and at this time, we're requesting just

4

information status only.

5

expedited timeline, we are checking in with

6

our boards of supervisors and our council

7

members to determine our level of

8

participation so that is why we're just

9

making a motion right now for information

10
11

Due to the

status.
ALJ ALLEN:

12

That's granted.

Everyone, please try to use the

13

microphones, and make sure your cell phones

14

are off.

15
16

Ms. Haug.
MS. HAUG:

Yes.

Lynn Haug,

17

representing East Bay Utility District.

18

are a party, but we were also asked to submit

19

an appearance form on behalf of the Zone 7

20

Water Agency, and it should be somewhere.

21

just wanted to make sure we were identified

22

as a party.

23

ALJ ALLEN:

24

MS. KOO:

Okay.

Your Honor, I apologize.

PG&E is, obviously, a party.

26

meant to request a transcript.
ALJ ALLEN:

28

MS. KOSS:

I

Thank you.

25

27

We

Okay.

My form was

Yes.

Your Honor, one more.

PUBLIC UTILITIES COMMISSION, STATE OF CALIFORNIA
SAN FRANCISCO, CALIFORNIA

 9

1

I believe we're on the party status

2

list, but just to be sure, Rachel Koss for

3

the Coalition of California Utility

4

Employees.

5

We did submit comments on OIR.

ALJ ALLEN:

And if you submitted

6

comments on the OIR, you would have party

7

status.

8
9

Sir?
AUDIENCE MEMBER:

Is it possible to

10

bring up the general PA, public address

11

system volume, because everybody is a little

12

hard to hear.

13

ALJ ALLEN:

I don't have control of

14

that here.

I don't know if anyone in the

15

back does.

What I can do is, let's pretend

16

there are no microphones and we'll all just

17

speak up.

18

Okay.

19

(No response.)

20

ALJ ALLEN:

Any other appearances?

What I want to do is get

21

into some of the questions of how this

22

proceeding might run and how it coordinates

23

with other proceedings, and I would like to

24

hear from parties for their suggestions.

25

One of the things that struck me

26

about the comments we received on the OIR was

27

that a lot of parties raised the

28

de-energization issue, and I understand

PUBLIC UTILITIES COMMISSION, STATE OF CALIFORNIA
SAN FRANCISCO, CALIFORNIA

 10

1

that's a very important issue for especially

2

a lot of communities.

3

De-energization is a somewhat

4

complicated topic, and it's not clear to me

5

how much detail we could resolve on

6

de-energization in this proceeding based on

7

the timing of when we need to get the

8

wildfire mitigation plans done.

9

So my question that I'm going to

10

want parties to address is:

11

better for that to be addressed in a separate

12

proceeding, like a separate OIR focusing on

13

de-energization?

14
15
16

Would it be

Would it be best to address it in a
separate track in this proceeding?
And then the question:

How much

17

could we actually do on that issue given the

18

timing of looking at having a wildfire

19

mitigation plan decision out in May?

20

Just off the top of my head, the

21

advantage of a separate OIR is that,

22

essentially, work could be done on that

23

concurrently with this proceeding.

24

doing a separate track of this proceeding,

25

realistically a lot of that work is going to

26

have to trail the work of getting the

27

wildfire mitigation plans done and processed,

28

and then the question is:

If we are

How much

PUBLIC UTILITIES COMMISSION, STATE OF CALIFORNIA
SAN FRANCISCO, CALIFORNIA

 11

1

de-energization could we do in the timeframe

2

we have of the approval of the initial

3

wildfire mitigation plans.

4

So what I would like to hear is

5

parties' perspective on that question:

6

do we do with de-energization?

7
8
9

What

Ma'am?
MS. BERLIN:

Good morning.

Susie

Berlin for the Northern California Power

10

Agency.

11

proceeding as customers of PG&E in that we

12

have publicly-owned utilities that are

13

transmission dependent; so the

14

de-energization issue is a significant one.

15

So as a threshold matter, you had mentioned

16

whether we should do it in a separate phase

17

or a separate proceeding because you want to

18

have a PD on approving the wildfire

19

mitigation plan and that includes, though,

20

the entirety of the wildfire mitigation plan.

21

Would that include de-energization component?

22

We are information only in this

ALJ ALLEN:

Well, one of my questions

23

is how much and how perfect a de-energization

24

component can we have in that time frame

25

because de-energization to me seems like kind

26

of a tricky, complicated issue that requires

27

some care.

28

could do with some sort of an initial thing

And, certainly, I think they

PUBLIC UTILITIES COMMISSION, STATE OF CALIFORNIA
SAN FRANCISCO, CALIFORNIA

 12

1

in the wildfire mitigation plan.

2

something we cannot do, but the question is,

3

how much can we do and what's the most

4

efficient way of doing the rest of the work?

5

Mr. Long?

6

MR. LONG:

7

ALJ ALLEN:

8

MR. LONG:

9

It's not

Yes, your Honor.
Just yell.
Okay.

Will do.

I think that it's a good idea to be

10

thinking about what can be accomplished in

11

the very short time frame that's allowed for

12

the decision on these plans.

13

it's also a good idea to be thinking about

14

particularly complex and important issues

15

that deserve the Commission's focused

16

attention, doing those in a separate,

17

concurrent proceeding.

18

And so I think

So TURN would endorse that

19

suggestion because not to say that it's of

20

paramount importance to get to that as

21

quickly as possible.

22

derailed in any respect, but it is

23

complicated enough that it does warrant

24

focused attention, and I hope we can get as

25

much participation from as many sectors of

26

the affected communities and first responders

27

and all organizations that have a stake in

28

that and the disability community as well.

Not that it should be

PUBLIC UTILITIES COMMISSION, STATE OF CALIFORNIA
SAN FRANCISCO, CALIFORNIA

 13

1

So I think that's a very good idea, your

2

Honor.

3

ALJ ALLEN:

Thank you.

4

Other parties?

5

Mr. Archer.

6

MR. ARCHER:

Yes.

Good morning, your

7

Honor, Commissioners.

We agree with

8

Mr. Long's comments that it is a very

9

important issue that deserves our full

10

consideration and full attention.

11

shouldn't be slowed down, but a separate

12

proceeding probably make sense given all that

13

we have to do in this proceeding.

14

ALJ ALLEN:

15

MS. HAUG:

It

Ms. Haug.
Yes.

Lynn Haug, on behalf

16

of East Bay MUD.

17

are complex and additional proceedings may be

18

necessary; however, some issues related to

19

de-energization are of immediate concern,

20

particularly communication and notification

21

issues and inter-utility communication and

22

the scope of those seems to be narrower, and,

23

perhaps, could be handled in this phase and

24

then also discussed in subsequent,

25

longer-term hearings or proceedings.

26
27
28

ALJ ALLEN:

We agree that the issues

Thank you, Ms. Haug.

Mr. Bodell.
MR. BODELL:

Thank you, judges, and

PUBLIC UTILITIES COMMISSION, STATE OF CALIFORNIA
SAN FRANCISCO, CALIFORNIA

 14

1

Commissioners.

The City of Malibu is

2

concerned about the effects of

3

de-energization that's on first responders,

4

law enforcement agencies, and city residents,

5

particularly with regard to the tension

6

between de-energization and evacuation

7

protocols.

8

Malibu had many evacuation

9

communications that went out in the middle of

10

the night that went out with very little

11

notice and is concerned that anticipatory

12

de-energization, if not thought out

13

correctly, could affect those types of

14

evacuation protocols.

15

We do agree that it's complex, but

16

we do think that under SB-901 collaboration

17

between local agencies is kind of a paramount

18

aspect of it.

19

consider that local component as well.

20

So we want the Commission to

COMMISSIONER RECHTSCHAFFEN:

Where do

21

you come out on -- do you think it should be

22

part of this proceeding or separate?

23

MR. BODELL:

I think it should be part

24

of this proceeding as much as we can,

25

particularly related to first responders and

26

law enforcement agencies and communications

27

for its public agents.

28

PRESIDENT PICKER:

Help me understand

PUBLIC UTILITIES COMMISSION, STATE OF CALIFORNIA
SAN FRANCISCO, CALIFORNIA

 15

1

why this proceeding, given that the program

2

has existed for years and that the current

3

rules that we reestablished for it were

4

established through resolution, not in

5

preexisting wildfire management plans

6

attached to the vegetation management

7

program.

8

here since the issues are so different,

9

involve different parties than participated

So I'm trying to understand why

10

originally, and probably have a different

11

impact in overall wildfire management

12

planning.

13

here.

14

I'm struggling to understand why
]

MR. BODELL:

I suppose we're concerned

15

from an exigent circumstances point of view.

16

If this other track doesn't move along as

17

fast as this one does, will those issues be

18

addressed?

19

think that would abate our concerns.

20

If the other track does, then I

PRESIDENT PICKER:

So the whole train

21

is leaving the station, so you're jumping on

22

not knowing where it goes?

23

MR. BODELL:

24

ALJ ALLEN:

25

MS. KOSS:

Yes.
Okay.

Ma'am?

Rachel Koss for CUE.

26

I don't think this is working.

27

We would agree with the City of

28

Malibu that if this is going to take a

PUBLIC UTILITIES COMMISSION, STATE OF CALIFORNIA
SAN FRANCISCO, CALIFORNIA

 16

1

separate path it has to be on the same

2

timeline as this proceeding.

3

And, you know, clearly SB-901

4

requires in the plans to be protocols for

5

disabling and de-energization.

6

be included here.

7

in another proceeding, okay, fine, but it has

8

to be on the same timeline, you know.

9

just -- it's so urgent, we can't push this

If we want to flesh it out

10

out until the end of the year.

11

PRESIDENT PICKER:

It's

I understand the

12

urgency.

13

this proceeding.

14

deadline.

15

urgency you're describing, so.

16

So it has to

I'm still trying to understand why
This has got a statutory

There really is no deadline in the

MS. KOSS:

Well, the statute requires

17

the Commission to approve plans that have

18

protocols for de-energization.

19

be included in the plan.

20

all understand that and the reason is because

21

it's urgent, right?

22
23
24
25
26

ALJ ALLEN:

So, it has to

I mean I think we

I guess the question would

be how much -PRESIDENT PICKER:

I'm sorry.

I don't

understand that, so maybe you can educate me.
ALJ ALLEN:

I guess one of the

27

questions I would have is, "Okay, given that,

28

how much can we do in these plans on the time

PUBLIC UTILITIES COMMISSION, STATE OF CALIFORNIA
SAN FRANCISCO, CALIFORNIA

 17

1

frame and what's the most expeditious way to

2

do whatever we can't do here?"

3

don't think we can do it all here by May of

4

everything that needs to be looked at in

5

de-energization.

6

can we do here and what is the most

7

expeditious way to do the other pieces of it?

8

So if you have perspective on that,

9
10

Because I

So the question is:

What

I would like to hear that.
MS. KOSS:

Yeah, I think we agree.

I

11

think we have to hunker down and do as much

12

as possible in this proceeding.

13

we need to take pieces and flesh them out in

14

another proceeding that is okay.

15

think it is okay to extend the timeline much

16

longer that this proceeding.

17

other people, other resources working on the

18

details in another proceeding, along the same

19

timeline, so that we can come to the same

20

place at the same time with all of the

21

information that we need.

22

ALJ ALLEN:

I think if

But I don't

So we have

I think realistically, I

23

think we're also certainly looking at an

24

iterative process that will have -- we're

25

only going to get so much done on the

26

timeline we have and hopefully what we do in

27

the future is going to be improving that.

28

what we come up with in May is not going to

So

PUBLIC UTILITIES COMMISSION, STATE OF CALIFORNIA
SAN FRANCISCO, CALIFORNIA

 18

1

be -- I certainly do not expect that that is

2

going to be the ending -- the end of the

3

process.

4

MS. KOSS:

5

ALJ ALLEN:

Yes.
Other parties who wish to

6

be heard on this particular issue?

7

back, sir?

8
9

In the

Mr. Candelaria and then Ms. Moosen.
MR. CANDELARIA:

Jerome Candelaria,

10

CCTA, California Cable and Telecommunication

11

Association.

12

With regards to the need to work

13

with critical infrastructure providers such

14

as communications providers, fortunately

15

there has been another train that has left

16

the station in the form of ESRB-8, a

17

resolution the Commission set forth in July

18

that established communications and workshops

19

between the utilities and communications

20

infrastructure providers.

21

those opportunities to be ongoing and by

22

continuing this education and information

23

exchange between IOUs and critical

24

infrastructure providers, it would strike me

25

as though at least that element of SB-901 is

26

being addressed.

27

find that SB-901 and its own ESRB-8 needs to

28

have elements reconciled, for now it appears

I would expect

While the Commission may

PUBLIC UTILITIES COMMISSION, STATE OF CALIFORNIA
SAN FRANCISCO, CALIFORNIA

 19

1

as though the Commission has a way of

2

addressing at least one component of

3

de-energization.

4

ALJ ALLEN:

5
6

Thank you.

Ms. Moosen.
MS. MOOSEN:

Thank you, your Honor.

I

7

would like to echo some of the sentiments the

8

local government and TURN expressed --

9
10
11

ALJ ALLEN:

Ms. Moosen, you're

appearing for?
MS. MOOSEN:

The Local Government

12

Sustainable Energy Coalition.

13

only, as far as I know, statewide voice and

14

regulatory forum for local governments.

15

represent about 40 different jurisdictions,

16

cities and counties, special districts, a few

17

water agencies and some affiliated government

18

entities, both on the consumer side and on

19

the customers -- on the consumer side and on

20

the provider side.

21

We are the

We

Our interests are broad in this

22

proceeding.

23

split the issues.

24

Commission including de-energization and PSPs

25

policy in this proceeding as 911 contemplated

26

for a couple of deliverables that seem to be

27

lacking.

28

And I offer two things on how to
We would support the

One is an umbrella, even an

PUBLIC UTILITIES COMMISSION, STATE OF CALIFORNIA
SAN FRANCISCO, CALIFORNIA

 20

1

inventory of what we have addressed in the

2

various proceedings, what we're targeting now

3

and where the gaps are.

4

would move the ball tremendously in the short

5

realm.

6

If we did that, that

I think for local governments, the

7

implementation of ESRB-8 has been wildly

8

divergent in different parts of the state.

9

In some places where local governments

10

themselves have a lot of resources, it has

11

gone well and interactions with the utilities

12

have continued in very functional ways, even

13

as everybody is stressed beyond usual

14

circumstances and resources.

15

In smaller jurisdictions or others

16

that are just coming around, this has not

17

been the case.

18

difficult and recovery is difficult; often

19

knowing what the resources are available and

20

where to go on the short run, it's difficult.

21

That is long-winded way of saying that local

22

governments are trying to rally, just as you

23

are, on all the fronts at the same time.

24

Communication has been

And the other piece that I think

25

will have to be fleshed out through the other

26

proceedings but should be touched upon here

27

is what resources are going to be made

28

available or should be made available on the

PUBLIC UTILITIES COMMISSION, STATE OF CALIFORNIA
SAN FRANCISCO, CALIFORNIA

 21

1

front end, on the planning side.

We seem to

2

have a lot of infrastructure in place on the

3

during and after of an emergency, but on the

4

front-end planning, also there is a wide

5

diversity of resources and approaches even

6

between the utilities.

7

that seems to be missing from the

8

Commission's resolution on de-energization is

9

the planning criteria for when those will be

And one of the things

10

invoked and that filters down to local

11

governments.

12

Right now, for example, in the Santa

13

Barbara County, their Office of Management

14

Services is in the process of offering a

15

manual on preparation and protocols for

16

outages of different durations, hours,

17

24 hours, 4 days and beyond.

18

that is a much bigger topic than can be

19

addressed in this forum, but the fact that,

20

at least at the distribution level, there is

21

much more sophistication at the high-voltage

22

transmission level with all of the various

23

reliability infrastructure, but at the

24

distribution level -- but liability protocols

25

standards for engineering, standards for

26

response have really not been looked at in an

27

outage context.

28

outages imply different kinds of resources at

And obviously

And different kinds of

PUBLIC UTILITIES COMMISSION, STATE OF CALIFORNIA
SAN FRANCISCO, CALIFORNIA

 22

1

every level, financial, engineering, in the

2

ground and human and protocols.

3

if we started to rename those and identify

4

them as gaps, we'll have an easier time

5

deciding what can be done in the short run

6

and what should have a home in another

7

parallel proceeding.

8

ALJ ALLEN:

9

Thank you.

And I think

Other parties?

Mr. Melville and then Ms. Hook.

10

MR. MELVILLE:

Thank you, Judge Allen.

11

Keith Melville for San Diego Gas & Electric

12

Company.

13

We would support having a parallel

14

rulemaking for this topic.

15

SB-901 does indicate that protocols for

16

de-energizing portions should be in the

17

wildfire mitigation plan.

18

says that protocols for compliance with

19

disaster relief should be in the wildfire

20

mitigation plan and the Commission currently

21

has a parallel rulemaking ongoing for that.

22

That is Rulemaking 18-03-011 under Judge

23

Rizzo.

24

It's true that

However, it also

And the fact is that having that

25

particular topic in its own rulemaking allows

26

the right expertise to come in, the billing,

27

the collection, the expertise in that part of

28

the organization and the customers who deal

PUBLIC UTILITIES COMMISSION, STATE OF CALIFORNIA
SAN FRANCISCO, CALIFORNIA

 23

1

with them and the customer advocates that

2

deal with them.

3

rulemaking and all that gets rolled up into

4

the wildfire mitigation plan.

5

They get to be in their own

De-energization could be treated the

6

same way in its own parallel rulemaking and

7

with all expediency.

8

ALJ ALLEN:

9

Ms. Hook.

10
11

Thank you.

MS. HOOK:

Charlyn Hook for Public

Advocates Office.

12

As your Honors and parties have

13

pointed out, there is some tension between

14

the goal of finalizing these wildfire

15

mitigation plans by next summer and the need

16

to carefully review these plans and allow

17

opportunity for staff and parties to provide

18

meaningful comments and feedback on those

19

plans.

20

So, I note that the legislation

21

requires about 20 different things and

22

fortunately our utilities are already doing

23

many of these things.

24

idea, in the context of this proceeding, to

25

prioritize some of those things as we go

26

through the review of these plans.

27
28

But it may be a good

We're not opposed to having a
separate OIR but I know that that would take

PUBLIC UTILITIES COMMISSION, STATE OF CALIFORNIA
SAN FRANCISCO, CALIFORNIA

 24

1

30 to 60 days I think to get that written up

2

and on calendar.

3

ALJ ALLEN:

4

MS. HOOK:

5

ALJ ALLEN:

Not necessarily.
Okay.
I am getting a general

6

consensus.

7

somewhat different opinion or wishes to add

8

anything to this?

9

Ms. Koo.

10
11
12

Is there anyone who has a

MS. KOO:

Your Honor, Alyssa Koo from

PG&E.
I appreciate the concern and the

13

urgency felt about de-energization, but I'm

14

still concerned because there's the

15

overarching need to get wildfire mitigation

16

plans approved in time for the next summer.

17

And I'm just concerned that de-energization

18

is going to overwhelm and take the focus off

19

the plans as a whole.

20

important aspects that need to be discussed

21

and approved in the plans, such as system

22

hardening and vegetation management and

23

deployment of weather stations.

24

There are many

I'm concerned that however we handle

25

it, whether it's in a separate proceeding or

26

as part of this proceeding that we appreciate

27

that it's going to take a lot of time and

28

resources to address these issues.

And it's

PUBLIC UTILITIES COMMISSION, STATE OF CALIFORNIA
SAN FRANCISCO, CALIFORNIA

 25

1

frequently the same people who are trying to

2

develop the overall plan as we are working on

3

de-energization.

4

sure we have realistic deadlines to flesh out

5

this one aspect of our plan that it doesn't

6

take over and prevent kind of a thorough

7

complete development of the overall plan,

8

especially because as you mentioned the

9

wildfire mitigation plan is going to be an

And I just want to make

10

annual filing.

11

perfect, I'm not sure perfection is

12

realistic, we will have additional

13

opportunities to continue to improve it over

14

time.

15

So while it may not be

So I guess what I'm saying is

16

whether the Commission has it in a separate

17

proceeding or the same proceeding, I just

18

want to make sure that we are cognizant of

19

the demands on the same people's time to

20

actually get to a solid wildfire mitigation

21

plan at not just perfect protocols for

22

de-energization.

23

ALJ ALLEN:

I'm very cognizant of what

24

I can realistically do, even with Judge

25

Thomas and the Commission's involvement there

26

is only so much we can do.

27

this moment we can't strive for perfection,

28

but for minimizing imperfection as we go

And I think at

PUBLIC UTILITIES COMMISSION, STATE OF CALIFORNIA
SAN FRANCISCO, CALIFORNIA

 26

1

forward and hopefully we can get more

2

perfection.

3

Mr. Clay.

4
5

MR. CLAY:

Your Honor, Chris Clay on

behalf of the Office of the Safety Advocate.

6

We'll echo the views of the many of

7

the parties that de-energization probably

8

does warrant a separate track in a separate

9

proceeding, but we'll just briefly add that

10

perhaps one way that it could be looked at in

11

this proceeding in some preliminary way would

12

be in a workshop which we did propose

13

workshops in our comments and perhaps that is

14

-- would be a good place to get the ball

15

rolling and the discussion on that subject.

16

ALJ ALLEN:

That was actually my next

17

topic which was I wanted to raise the

18

possibility of workshops.

19

that this proceeding that would limit itself

20

to value of workshops.

21

question I would have is:

22

timing?

23

of the things that would be useful is a

24

workshop soon after the utilities put out

25

their plans just so that parties have an

26

opportunity to discuss those with the

27

utilities, make sure everyone understands

28

them.

It seems to me

I'm thinking the
How many and the

Certainly I think at some point one

I think that would also probably

PUBLIC UTILITIES COMMISSION, STATE OF CALIFORNIA
SAN FRANCISCO, CALIFORNIA

 27

1

reduce the need and amount of discovery that

2

has to his go on.

3

One thought that I have and I want

4

to hear if this is feasible, is whether it's

5

something the parties would be interested in

6

if the utilities could provide a draft plan

7

earlier than February, have a workshop, get

8

feedback that would then feed into their

9

February plan.

10

possible or not.

11

desirable.

I don't know if that's
I don't know if that is

That is one thing.

12

Then the other question would be:

13

Should there be additional workshops and if

14

so what should those be on and when should

15

they fall in the timing?

16

So, feeding off that, let's start.

17

I see Mr. Archer then Ms. Hook then Ms. Koo.

18

MR. ARCHER:

19
20

Thank you, your Honor.

As far as post-filing workshops,
that makes sense to us.

21

The three large electric utilities

22

have also developed a draft common template

23

that would address what the plan would look

24

like.

25

other parties to obtain feedback on that

26

template and we've conferred amongst

27

ourselves and it looks like feasible dates

28

for maybe an on-line webinar in the very near

And we would like to share that with

PUBLIC UTILITIES COMMISSION, STATE OF CALIFORNIA
SAN FRANCISCO, CALIFORNIA

 28

1

future would be the 27th or 28th of this

2

month in November.

3

I'd let the other utilities talk

4

about it, sort of a pre-filing draft plan is

5

feasible but as far as the template, we have

6

decided upon a draft.

7
8
9
10
11

ALJ ALLEN:

Thank you.

Ms. Hook.
MS. HOOK:

Charlyn Hook for Public

Advocates Office.
Public Advocates Office would

12

support the concept of holding two workshops

13

as TURN proposed in its comments.

14

also would like to see there be an initial

15

filing of the wildfire mitigation plan with

16

feedback and then a subsequent final wildfire

17

mitigation plan.

18

And we

And before the prehearing conference

19

this morning, I took a shot at coming up with

20

a schedule, which I handed out to parties.

21

And I'm not sure that the proposed timeline

22

that I came up with would be acceptable to

23

everybody, but perhaps the event -- so this

24

attempts to marry the proposal of the scoping

25

memo, TURN's, ORA's and the Joint Utilities'

26

feedback from their comments, but I haven't

27

had -- nobody has had time to really review

28

this until this morning.

PUBLIC UTILITIES COMMISSION, STATE OF CALIFORNIA
SAN FRANCISCO, CALIFORNIA

 29

1

ALJ ALLEN:

Thank you.

I understand.

2

That I found a copy of up here.

3

the proposal of Public Advocates?

4

MS. HOOK:

5

ALJ ALLEN:

6

Yes.
Thank you.

Ms. Koo.

7

MS. KOO:

8
9

So this is

Thank you, your Honor.

I agree to echo what Mr. Archer
said.

We are happy to circulate the template

10

that we have prepared on how we would

11

approach the wildfire mitigation plan and

12

then have an initial workshop to discuss it

13

and go over questions.

14

The idea of having -- of submitting

15

an initial plan and taking feedback raises a

16

lot of concerns for me if it were to be any

17

earlier than the date proposed by Ms. Hook

18

because it is taking time and it will take

19

additional time after we get the scoping memo

20

for the utilities to come up with, you know,

21

an adequate plan to be reviewed.

22

order to get feedback that we could then

23

incorporate by a February date, I just don't

24

think we can balance those needs.

25

have to submit a plan to the group very soon

26

in order to get feedback in order to submit

27

it by February but I don't think we can

28

actually have a plan that is sufficiently

But then in

We would

PUBLIC UTILITIES COMMISSION, STATE OF CALIFORNIA
SAN FRANCISCO, CALIFORNIA

 30

1

thought out by that time.

2

So I'm just suggesting that we not

3

have anything submitted before the February

4

date.

5
6
7
8
9
10

ALJ ALLEN:

Other comments on workshop

timing and number of workshops?
Ms. Haug.
MS. HAUG:

Yes.

Thank you.

East Bay MUD would support
workshops.

We think it's a good idea.

11

The process this summer of

12

communication with PG&E in trying to

13

implement Resolution ESRB-8 brought to light

14

the need for discussion at a finer level and

15

education on both sides of the interaction

16

between electric de-energization and the

17

impacts on water supply and water quality and

18

water storage timing and pumping, et cetera.

19

And so the one other recommendation

20

that I would make, since there are a lot of

21

topics and many interested parties and

22

subjects, is that to the extent possible it

23

would be useful if the workshops -- if you

24

could break out some immediate topics of

25

higher concern or somehow, you know, isolate

26

issues a bit to make it easier for

27

participation by parties only interested in,

28

you know, in certain issues.

PUBLIC UTILITIES COMMISSION, STATE OF CALIFORNIA
SAN FRANCISCO, CALIFORNIA

 31

1

ALJ ALLEN:

That's an interesting idea.

2

Because certainly back in implementing RPS

3

the Commission did that which was a series of

4

workshops and each workshop was focused on

5

kind of a different key area.

6

So I think -- I mean there is one

7

question of we definitely want to have

8

something after the utilities present the

9

plan so the parties can ask questions, but

10

I'm wondering:

11

feeling about subworkshops kind of in

12

specialized areas?

13
14

Do other parties have a

Mr. Long.
MR. LONG:

Yes, your Honor.

We did

15

propose and I'm glad to hear others seem to

16

agree there should be a workshop right after

17

the utilities present their plans -- submit

18

their plans.

19

I don't think you were suggesting this, I

20

think that one should not be focused.

21

should be the utilities presenting

22

item-by-item what's in their plan, as you

23

say, so that we can understand it, maybe

24

obviate the need for some discovery and get

25

rolling as quickly as possible in analyzing

26

the plans.

27
28

And I think it -- that one and

That

I see that the value of trying to -the next step would then be the follow-up

PUBLIC UTILITIES COMMISSION, STATE OF CALIFORNIA
SAN FRANCISCO, CALIFORNIA

 32

1

workshops which TURN also suggests 30 days

2

after the initial presentation of the plan.

3

And as I was starting to say, there is value

4

to trying to focus that by topic but there

5

are so many topics here and really it's hard

6

to say until we see the plans at least from

7

our perspective of what are going to be the

8

key issues.

9

to depend on the parties.

And I think that is also going
The local

10

governments are going to have certain issues

11

that are going to be front and center for

12

them.

13

have other interests.

Other community members are going to

14

So I would -- I think I lean toward

15

cautioning against at this point trying to

16

determine now what the topics should be.

17

Maybe that could be something we talk about

18

at the initial workshop and try to get some

19

input on that in the initial workshop to help

20

the Commission perhaps think about subject

21

matter topics for the follow-up workshop.

22

ALJ ALLEN:

]

To follow on that, I mean,

23

I think your point is a good one that

24

different parties have very different

25

focuses.

26

because then there will be a workshop that

27

will cover the issues that are most important

28

to local cities and other workshops that

So some workshops might be useful

PUBLIC UTILITIES COMMISSION, STATE OF CALIFORNIA
SAN FRANCISCO, CALIFORNIA

 33

1

might be most important to, you know, first

2

responders, generators, things like that.

3

But, yeah, I think it would take a little bit

4

of thought and refinement.

5

What I'm gathering is, there's

6

general consensus that having a workshop

7

immediately after the plans are presented is

8

worthwhile, and it seems likely that

9

subsequent workshops organized one way or

10

another would probably be useful, and then

11

it's a question of kind of the scope and

12

timing of those.

13

Ma'am?

14
15
16

MS. MIFSUD:

Yes, Judge.

This is

Cynthia Mifsud with PacifiCorp.
So PacifiCorp is a smaller utility

17

in Northern California.

18

make a pitch for sort of a peer-to-peer

19

workshop and maybe around the time that PG&E

20

puts together its template, so that, you know

21

-- and it sounds like there's going to be

22

some instructions for the plan that comes out

23

of the scoping memo.

24

very useful for the utilities to get together

25

and have a common understanding of what those

26

instructions mean and what each of the

27

elements mean.

28

I just wanted to

I think it would be

And, also, I would urge you to

PUBLIC UTILITIES COMMISSION, STATE OF CALIFORNIA
SAN FRANCISCO, CALIFORNIA

 34

1

consider, as you put the instructions

2

together in a scoping memo, to consider

3

whether there ought to be separate

4

instructions for the smaller utilities versus

5

the larger utilities.

6

ALJ ALLEN:

7

Sir?

8

MR. GIBSON:

9
10
11

Thank you.

Good morning, your Honor.

Jed Gibson on behalf of Bear Valley Electric
Service and Liberty Utilities.
We would just like to echo the

12

comments and concerns raised by PacifiCorp.

13

While we're very concerned and eager to

14

implement the wildfire mitigation plans, we

15

don't have the staff or the experience that

16

the large IOUs have.

17

beneficial to have workshops to gain some

18

clarity about planning requirements and

19

eventually develop a consensus as what will

20

be included in those plans and how best to

21

address that, given the more limited

22

resources of the smaller utilities.

23

ALJ ALLEN:

24

MS. FERNANDEZ:

We think it would be

Thank you.
Laura Fernandez on

25

behalf of the California Municipal Utilities

26

Association.

27
28

I would echo both the comments of
PacifiCorp and Bear Valley.

CMUA supports

PUBLIC UTILITIES COMMISSION, STATE OF CALIFORNIA
SAN FRANCISCO, CALIFORNIA

 35

1

workshops both after the plans are filed and

2

perhaps before, but we also agree that

3

workshops earlier as East Bay MUD mentioned

4

on, perhaps, specific topics would be very

5

informative and very helpful to parties.

6

Our only question is with comments

7

on instructions for initial plans due so soon

8

where these workshops would fit in.

9

workshops earlier would be a good idea, but

10

that deadline is, obviously, rapidly

11

approaching.

12

ALJ ALLEN:

We think

With the scoping memo, we

13

will clarify and refine this.

14

some workshops of smaller groups of parties

15

of utilities, I'm not sure that's necessarily

16

something we're going to set out in the

17

scoping memo, but, certainly, if any parties

18

or subgroups of parties wish to get together

19

to try and coordinate and share information

20

to streamline the process, that is certainly

21

okay.

22

In terms of

I think what we're going to be

23

focusing on with the scoping memo is setting

24

the schedule for larger proceedings and

25

events that are going to be open to all

26

parties.

27
28

Ma'am.
MS. MAURATH SOMMER:

April Maurath

PUBLIC UTILITIES COMMISSION, STATE OF CALIFORNIA
SAN FRANCISCO, CALIFORNIA

 36

1

Sommer for the Protect Our Communities

2

Foundation.

3

One of the concerns that we had

4

understands that this needs to be a very, you

5

know, fast-track proceeding, but that there's

6

little opportunity for development of the

7

record.

8

workshops, what we would like to see is that

9

it is not done informally, and that there's,

And if there's going to be use of

10

you know, information that's generated from

11

the workshops that is put on the record.

12

ALJ ALLEN:

This moves to the next

13

thing, which I actually had on my list.

14

Thank you.

15

doing in terms of the record.

16

It's a question about what we're

One of the possibilities is that

17

essentially the plans would be treated as

18

testimony, and that we would have evidentiary

19

hearings and parties could cross-examine on

20

those plans, and then subsequently there

21

would be briefing.

22

The advantage of this is that there

23

would be on the record conversation of the

24

plans.

25

be on the record.

26

the ALJs have questions on the plans, those

27

could be asked on the record.

28

Anyone's questions and answers would
If the Commissioners or

The thing I'm thinking is

PUBLIC UTILITIES COMMISSION, STATE OF CALIFORNIA
SAN FRANCISCO, CALIFORNIA

 37

1

realistically only the utilities are going to

2

have plans; so no other party would be

3

submitting testimony.

4

chance to do cross-examination and briefing

5

under that scenario.

6

Parties would have a

The more conventional approach of

7

how this Commission would typically do it in

8

rulemaking is that the plans would be filed

9

and served, and then the parties would have a

10

chance to do written comments on those plans

11

and there would be a chance for parties to

12

respond to each other.

13

plans would be filed.

14

be comments and reply comments so that

15

everything would be on paper.

16

So, essentially, the
There would probably

So those are kind of what I see as

17

the two choices.

18

everything's on paper.

19

not be part of the record.

20

The conventional one is
The workshops would

The other option is to have,

21

essentially, the plans treated as testimony

22

so you would have cross-examination and then

23

you'd have briefings.

24

an in-person, cross-exam component and a

25

written component.

26

So you would have both

Those are the two kind of

27

alternatives I see in how we can do this in

28

the time that we have.

And given Judge

PUBLIC UTILITIES COMMISSION, STATE OF CALIFORNIA
SAN FRANCISCO, CALIFORNIA

 38

1

Thomas and my background, we can make either

2

one of those work for the schedule.

3

just a question of which one is going to give

4

us the better record for going forward with

5

what we need to write a decision.

6
7

Do parties have a perspective on
this?

8
9

Mr. Melville.
MR. MELVILLE:

10
11

It's

Thank you, your Honor.

Keith Melville, San Diego Gas &
Electric.

12

I think I would strongly urge the

13

Commission not to go the route of evidentiary

14

hearings.

15

by midyear, it does not lend itself to rapid

16

decision.

17

If you're trying to get this done

Another option that was recently

18

used by the Commission was to have a

19

transcribed workshop.

That happened at

20

Cal OES up in Mather.

That seems to be an

21

interesting development and a way to create a

22

record.

23

I would also urge you to consider

24

two-day workshops.

The number of subject

25

matter and topics in here - 20 different

26

topics in SB-901 - would lend itself to

27

multiple day workshops.

28

for people who have to travel.

It's more efficient

PUBLIC UTILITIES COMMISSION, STATE OF CALIFORNIA
SAN FRANCISCO, CALIFORNIA

 39

1

So I think I would encourage you to

2

look at workshops, possibly with a transcript

3

and written comments as necessary.

4

ALJ ALLEN:

5

Thank you.

Mr. Clay.

6

MR. CLAY:

Chris Clay for the Office of

7

the Safety Advocate.

8

we're inclined to agree with San Diego on

9

that point.

10
11

ALJ ALLEN:

I will quickly say that

On which part of it; all of

it?

12

MR. CLAY:

13

ALJ ALLEN:

Yes.
I have serious concerns

14

about a transcribed workshop for a number of

15

reasons; so unless you can persuade me

16

otherwise, I'd rather not have a transcribed

17

workshop.

18

interchange with questions and answers, I

19

think we get a much cleaner record from a

20

structured hearing.

21

If we want to have actual

So I don't have a strong preference

22

either way, but I'm not inclined to do that.

23

I also think that you end up with parties

24

tending to posture a little bit more in a

25

workshop.

26

to be constructive and not kind of posturing.

27

And so I'm concerned that if the workshops

28

become the record, that the workshops end up

So I'd really like the workshops

PUBLIC UTILITIES COMMISSION, STATE OF CALIFORNIA
SAN FRANCISCO, CALIFORNIA

 40

1

being less useful.

2

So I do not want to do a transcribed

3

workshop.

4

two-day workshop or multiple-day workshops or

5

sequential-day workshops, like we do multiple

6

topics, but the question is, do we want

7

hearings or do we want it just on paper?

8

I certainly have no problem with

Mr. Long.

9

MR. LONG:

TURN also leans toward the

10

workshop approach and not the evidentiary

11

hearing approach.

12

frame, I think, would be better addressed in

13

a setting where we can, you know, literally

14

or figuratively sit around the table and talk

15

about them, as opposed to interrogate each

16

other.

17

ALJ ALLEN:

These topics in the time

So what I'm proposing is

18

not in lieu of workshops.

So there would be

19

workshops and there would be hearings.

20

Looking as an example, if you look at the

21

initial RPS that I ran - I'm dating myself -

22

back in 2003, maybe 2004.

23

workshops and evidentiary hearings.

24

workshops were very valuable in making sure

25

that everyone got up to speed on all the

26

technical things, but didn't preclude the

27

evidentiary hearings.

28

consensus that workshops will be useful.

There were
And the

So I think there's a

PUBLIC UTILITIES COMMISSION, STATE OF CALIFORNIA
SAN FRANCISCO, CALIFORNIA

 41

1

So, I think, regardless of which

2

approach we use, there would be workshops.

3

It's just a question of is the record just

4

paper-based or --

5

MR. LONG:

I appreciate that

6

qualification.

7

about the best way to use our time in an

8

extremely truncated proceeding, I'm not sure

9

the evidentiary hearing, which is a rather

10

deliberative way to go, is the best use of

11

our time.

12

Still, I think, thinking

I understand what you're saying

13

about the difficulties of transcribing a

14

workshop, and I tend to agree with you that

15

there are problems with that.

16

What still gives some comfort about

17

the workshop process, and only the workshop

18

process, is after the workshop, the parties

19

get an opportunity to submit comments based

20

on what they've learned.

21

that have, you know -- they've developed

22

based on the workshops, and then having an

23

opportunity to reply.

24

a better way to use our time rather than go

25

through the evidentiary hearing process.

26

ALJ ALLEN:

27

MS. MIFSUD:

28

Ideas and issues

I think that would be

Okay.

Thank you.

Thank you, your Honor.

This is Cynthia Mifsud with

PUBLIC UTILITIES COMMISSION, STATE OF CALIFORNIA
SAN FRANCISCO, CALIFORNIA

 42

1

PacifiCorp.

2

I just want to lend some support to

3

Mr. Melville's suggestions regarding

4

workshops and in lieu of the evidentiary

5

hearing.

6

in transcribing workshops.

7

we've submitted workshops into the record in

8

any number of proceedings recently is to have

9

a workshop report team put together a

I understand you're not interested
One way that

10

workshop report at the close of the workshop,

11

or a series of workshops, and then that

12

workshop report is submitted, and comments

13

get filed and served, and comments can be

14

submitted on that workshop report.

15

ALJ ALLEN:

One concern I have with the

16

workshop report is, one, who is going to do

17

it?

18

that tends to be a lot of work for commission

19

staff, and we have to wait for the workshop

20

report before the comments.

21

Just because if it's a staff product,

Given the time frame, I'm thinking

22

if parties attend the workshop, as Mr. Long

23

said, then when they file comments, they can

24

be informed by what they've learned from the

25

workshop rather than having an additional

26

step of the comments.

27
28

Ms. Hook, and then you in the back.
MS. HOOK:

Charlyn Hook for the Public

PUBLIC UTILITIES COMMISSION, STATE OF CALIFORNIA
SAN FRANCISCO, CALIFORNIA

 43

1
2

Advocates Office.
One hybrid-type model I've seen done

3

before is to have a workshop, but then a

4

court reporter is available at the workshop

5

and then transcribes a little bit either at

6

the end of each session or at the end of the

7

day, and then you don't have the need to wait

8

around to get a reporter later.

9

all done in the moment, but the parties still

It's just

10

get the opportunity to have a free-flowing

11

discussion without being inhibited by having

12

the court reporter there.

13

court reporter.

14

No offense to the

And the Public Advocates Office was

15

not 100 percent certain at the time when we

16

submitted our comments, but we proposed

17

possibly building in a final day to request

18

evidentiary hearings into the schedule.

19

Obviously, these dates are all subject to

20

your discretion, but maybe we can see how the

21

workshops go and reserve a limited time for

22

the EH's as well.

23

ALJ ALLEN:

I guess one question I have

24

is, is there any party who at this time

25

thinks that evidentiary hearings are

26

necessary just from a process standpoint in

27

that there may be material issues of fact

28

contested?

PUBLIC UTILITIES COMMISSION, STATE OF CALIFORNIA
SAN FRANCISCO, CALIFORNIA

 44

1
2
3

Ma'am?
MS. MAURATH SOMMER:

April Maurath

Sommer, Protect Our Communities Foundation.

4

We would certainly strongly support

5

evidentiary hearings.

These are plans with

6

which future actions are going to be measured

7

against, and it's very important, and the

8

evidentiary hearing process is going to be

9

developed to promote the most fulsome and

10

useful record, and certainly it will be

11

helpful in making these plans better.

12

The one thing I would have a concern

13

about is the way you've proposed does not

14

allow there to be any expert testimony from

15

any of the parties.

16

this is very speedy timeframe, but maybe some

17

consideration that there could be some of

18

that that is done in writing, and, you know,

19

there could be some rebuttal testimony that

20

could be done with, you know, experts being

21

able to participate on behalf of the party.

22

ALJ ALLEN:

23
24

Again, I do understand

Thank you.

Other comments?
MS. FERNANDEZ:

25

Laura Fernandez.

We would share her concerns about

26

there not being an opportunity for other

27

parties to submit into the record their

28

position.

So rather than evidentiary

PUBLIC UTILITIES COMMISSION, STATE OF CALIFORNIA
SAN FRANCISCO, CALIFORNIA

 45

1

hearings, we would prefer having written

2

comments on the plans.

3

ALJ ALLEN:

Okay.

So I'm hearing a

4

slightly different perspective.

5

hearing from Protect Our --

6

MS. FERNANDEZ:

What I'm

Well, on the -- on the

7

evidentiary hearings, we do not agree that

8

evidence hearings are necessary, but we do

9

agree with the concern that if you went the

10

route of evidentiary hearings, you would only

11

have the utility plans as evidence.

12

ALJ ALLEN:

13
14

Thank you.

Anything else on -- Mr. Long.
MR. LONG:

Yes, your Honor.

I just

15

wanted to stick with my previous comment, but

16

just also note that there is considerable

17

uncertainty about what actually will be in

18

the plan.

19

point that there will not be any disputed

20

issues of fact that would lend themselves to

21

be addressed in the evidentiary hearing.

22

If the plans come in the way I

So it's very hard to say at this

23

expect, I don't see that -- because I don't

24

see that happening.

25

be big, new programs where they're

26

forecasting costs and the like.

27

different day, a different proceeding.

28

if the utilities do something like that, then

These are not going to

That's for a
But

PUBLIC UTILITIES COMMISSION, STATE OF CALIFORNIA
SAN FRANCISCO, CALIFORNIA

 46

1

I think you'll be hearing from us, either, A,

2

that's not appropriate for this proceeding;

3

or, B, if it's deemed to be appropriate, then

4

we should be -- we have to go with a

5

different process.

6
7
8
9

ALJ ALLEN:

]
Ms. Haug and then

Ms. Moosen.
MS. HAUG:

On behalf of East Bay MUD,

we agree that with parties advocating not

10

having evidentiary hearings, it seems like

11

that that wouldn't be the best process for

12

this particular proceeding; however, we

13

support the idea of through, you know, some

14

method allowing parties to provide expert

15

information on the issue of particular

16

interest to them and that could be through

17

written submissions, comments or testimony.

18

And it also could be provided by experts

19

participating in the workshops.

20

And I just wanted to add there's one

21

other way that workshops can be used by

22

parties in terms of supporting a record.

23

that is in the electric vehicle proceedings

24

what has happened is that there was a sound

25

recording of the workshops and parties were

26

permitted to cite to that statements made in

27

that sound recording if they needed to.

28

it wasn't used extensively, but it did allow

And

And

PUBLIC UTILITIES COMMISSION, STATE OF CALIFORNIA
SAN FRANCISCO, CALIFORNIA

 47

1

parties to reflect points made in the

2

workshop if they wanted to cite that in their

3

subsequent filings.

4
5
6

ALJ ALLEN:

Okay.

That is interesting.

Ms. Moosen.
MS. MOOSEN:

Thank you, your Honor.

I

7

wanted to echo the sentiments of those who

8

are addressing the desire to put evidentiary

9

hearings aside or to have a very high bar for

10
11

having them in this proceeding.
Since our organization represents a

12

diversity of local governments, I can tell

13

you that their resources are also equally

14

diverse and that evidentiary hearings and the

15

demands of the record, while it is a cleaner

16

record for Commission decision-making would

17

effectively eliminate participation by the

18

vast majority of local jurisdictions.

19

just simply don't have the resources to

20

engage at that level in a single proceeding

21

when so much else is going on on the same

22

subject matter, or at any time for a great

23

many of them.

24

They

And I would invite you to include in

25

the procedural approach a diversity of

26

approaches so that you could have the benefit

27

of subject matter experts that are on the

28

ground and performing in local jurisdictions

PUBLIC UTILITIES COMMISSION, STATE OF CALIFORNIA
SAN FRANCISCO, CALIFORNIA

 48

1

on all of the various 20 points in SB-901's

2

subject list for the plans and be able to

3

take those in in writings of various forms,

4

obviously in an organized matter, by subject

5

matter in workshops, in response to workshops

6

reports, plans only, I don't have a

7

preference for that.

8

been creative in the last few years in

9

creating web portals and allowing electeds an

10

other city managers to present things through

11

correspondence, but to have that included in

12

the record.

13

correspondence is not -- is usually taken

14

into the administrative record and not

15

included in the deliberative final record.

16

We would ask that that be altered, at least

17

for local government parties and entities

18

that have subject matter responsibility

19

locally so that you can get the broadest

20

feedback.

21

But the Commission has

I know that usually

ALJ ALLEN:

Do you have specific

22

recommendations of how best to the do that

23

here?

24

MS. MOOSEN:

I have a number of

25

suggestions.

I believe workshop with report

26

after perhaps authored by the utilities to

27

the extent that parties feel excluded or

28

don't feel that they're well represented,

PUBLIC UTILITIES COMMISSION, STATE OF CALIFORNIA
SAN FRANCISCO, CALIFORNIA

 49

1

they have the opportunity to include written

2

materials or present at the workshops that

3

are then included.

4

the best opportunity.

5

opinion and have a great experience with

6

transcribed workshops.

7

both helpful and burdensome.

8

and a curse.

9

So I think that presents
I don't have an

I think that can be
It's a blessing

It will fall heavily on the

10

utilities' shoulders to produce a written

11

product in this proceeding.

12

not a big step in addition to their lift to

13

provide a post-workshop report that parties

14

can either supplement or comment on

15

afterwards.

16

And perhaps it's

And I would also invite there to be

17

some kind of web-based.

18

can webcast and the more that you can take in

19

responses from remote areas without having to

20

be at the table physically, facilities

21

diversity of views being presented to the

22

Commission.

23

ALJ ALLEN:

The more that you

One of the things I'm

24

hearing that seems to make some sense is at

25

least after the initial workshop after the

26

utilities present their plans, that there

27

needs to be a thing.

28

be, you know, Mr. Long was talking about

And that thing could

PUBLIC UTILITIES COMMISSION, STATE OF CALIFORNIA
SAN FRANCISCO, CALIFORNIA

 50

1

whether there is a need for asserting a

2

desire for evidentiary hearings because of

3

the nature of the plan whether, or input from

4

various stakeholders as Ms. Moosen talked

5

about or report that there needs to be some

6

mechanism for the parties to kind of weigh in

7

on probably both substance and process as we

8

go forward.

9

So we will confer about that, but it

10

seems like there needs to be some sort of a

11

post-workshop vehicle.

12
13

Mr. Archer.
MR. ARCHER:

Thank you, your Honor.

I

14

just wanted to follow up on something that

15

Mr. Long said.

16

plans in this proceeding to include proposed

17

new utility programs or requests for cost

18

recovery or a need for evidentiary hearings.

19

He said he didn't expect our

There are proceedings, though, where

20

the utilities have and will make proposals

21

for new programs or they have asked for cost

22

recoveries and which will require evidentiary

23

hearings.

24

Edison's Grid Safety and Resiliency Program.

25

The PHC for that is tomorrow and I just

26

encourage the Commission to carefully

27

consider not conflating the of work that

28

needs to be done in that proceeding with the

I'm specifically referring to

PUBLIC UTILITIES COMMISSION, STATE OF CALIFORNIA
SAN FRANCISCO, CALIFORNIA

 51

1

work that needs to be done in this proceeding

2

and to keep them separate.

3

The work in both proceedings is

4

urgent and we plan to do it all, but we do

5

think that it's appropriately considered

6

separately.

7

ALJ ALLEN:

Thank you.

Given that you

8

have raised that, I would ask for the input

9

if other parties have an opinion about the

10

relationship between that proceeding and this

11

proceeding whether they should be

12

consolidated, whether they should not be

13

consolidated, whether the Edison proceedings

14

should trail this one, whether they should

15

proceed concurrently.

16

what other parties think about the

17

relationship between the two proceedings.

18
19
20

Ma'am.
MS. HOOK:

I just want to hear

Ms. Hook, go ahead.
Charlyn Hook, Public

Advocates Office.

21

We support Edison's Grid Safety and

22

Reliability Projects Program proceeding

23

separately and concurrently with this OIR.

24
25
26
27
28

ALJ ALLEN:

Thank you.

Any other

parties?
MS. KOSS:

Rachel Koss for CUE.

And we agree that this proceeding is
separate and should remain separate from the

PUBLIC UTILITIES COMMISSION, STATE OF CALIFORNIA
SAN FRANCISCO, CALIFORNIA

 52

1

Grid Safety and Resiliency Program and that

2

the two proceedings should run concurrently

3

on the same timeline.

4

ALJ ALLEN:

5

MS. MORSONY:

6

Ma'am.
Katie Morsony for TURN.

I just wanted to note that a

7

prehearing conference statement was filed by

8

the Joint Parties in the GS and RP yesterday

9

that outlined both the Public Advocates, TURN

10

perspective, the SCE perspective and also the

11

CUE perspective.

12

forward concurrently but perhaps being aware

13

of the different deliberative loads in each

14

of the cases and how that may impact the

15

schedule and the time needed.

16

ALJ ALLEN:

We also recommend moving

One question I had is:

How

17

much or how many of the issues in that

18

proceeding would be dependent upon what the

19

actual plan approved by the Commission in

20

this proceeding would be?

21

for that, you know, I have not been reviewing

22

the record in that proceeding so I don't have

23

an opinion.

24

other proceeding getting out ahead of this

25

proceeding?

26

we need a result here before we can go ahead

27

with the issues in that proceeding?

28

In other words,

But my question is:

Is that

Do we need this proceeding?

Do

Mr. Archer.

PUBLIC UTILITIES COMMISSION, STATE OF CALIFORNIA
SAN FRANCISCO, CALIFORNIA

 53

1

MR. ARCHER:

No.

I don't think so,

2

your Honor.

3

the utilities must do to comply with SB-901.

4

Our separate proceeding is what the utilities

5

can do if the Commission gives us permission

6

to do it.

7

some overlap between the two, one is not

8

dependent on the other and we strongly feel

9

they should go forward concurrently and

10

I think this proceeding is what

So I don't think, while there is

expeditiously.

11

ALJ ALLEN:

12

MS. HOOK:

13
14

Thank you.
Charlyn Hook, Public

Advocates Office.
Yeah, we do see that there is some

15

overlap between what's being requested in

16

Edison's application proceeding and what is

17

required per the SB-901 legislation, but the

18

other proceeding gives us a forum and

19

opportunity to review testimony, put in our

20

own testimony, do discovery, review the costs

21

and have evidentiary hearings.

22

see time to do that in this rulemaking.

23

ALJ ALLEN:

And we don't

I would encourage that if

24

parties are thinking of doing discovery that

25

you are free to do discovery now.

26

open proceeding.

27

the utilities' plans may still be under

28

development and so they may not have complete

This is an

Certainly I understand that

PUBLIC UTILITIES COMMISSION, STATE OF CALIFORNIA
SAN FRANCISCO, CALIFORNIA

 54

1

answers for discovery that's served on them

2

asking about the contents of the plan, but

3

certainly if parties have some preliminary

4

questions and want to do discovery, the

5

proceeding is open.

6

The question would be, of course:

7

What is the scope of discovery if we are not

8

having hearings?

9

anything that is too horribly -- going to be

So I certainly don't want

10

too horribly burdensome or overbroad in

11

discovery, but if you have some specific

12

questions, specific requests, you should feel

13

free to go ahead and start asking them.

14

if there's question about the timing or the

15

burden, those can be referred to Judge Thomas

16

or I.

17

And

I think we have largely covered the

18

-- kind of the points that I wanted.

19

has been useful feedback and we'll consider

20

the various comments we have gotten and

21

incorporate this into the scoping memo to

22

give guidance for going foward.

23

been helpful.

24
25
26

So this

So that has

Are there other points that we wish
to raise?
First -- I'm sorry, Ma'am.

I forgot

27

your name in the back.

And if you could

28

stand up, please, that would be helpful.

And

PUBLIC UTILITIES COMMISSION, STATE OF CALIFORNIA
SAN FRANCISCO, CALIFORNIA

 55

1
2
3

then Mr. Long.
MS. MAURATH SOMMER:

April Maurath

Sommer, Protect Our Communities Foundation.

4

Just one thing I think might be

5

helpful would be if there is a web page that

6

put together, that pulls together all of

7

these different proceedings, I think that

8

would be really helpful for the public

9

parties.

10

PRESIDENT PICKER:

We are actually

11

trying to prepare something like that because

12

there are a variety of tasks, some of which

13

are underway separately, some of which are --

14

and while there's overlaps to the

15

conversation we have had here, there are

16

things that are implicit in SB-901 but aren't

17

necessarily as closely aligned to the

18

wildfire mitigation programs.

19

So we understand the challenge of

20

trying to -- for you to understand it.

I

21

would just be honest that it is also a

22

challenge for us to keep track of things and

23

how they relate to each other.

24

won't be as detailed or as sophisticated

25

initially as our DER action plan, but I think

26

the general intent is to show that as we have

27

to deal with these larger challenges and

28

changes in society and roles of the

It probably

PUBLIC UTILITIES COMMISSION, STATE OF CALIFORNIA
SAN FRANCISCO, CALIFORNIA

 56

1

utilities, we have to kind of map out how

2

we're going to try to do that.

3

MS. SOMMER:

4

MR. LONG:

5
6

Great.

Thank you.

Your Honor, Tom Long for

TURN.
I just wanted to address what I

7

perceive as a couple of loose ends that came

8

out of the conversation.

9

One was there was mention of the

10

utilities developing a template and of course

11

I just wanted to note that TURN prepared its

12

own template to get the ball rolling.

13

hope the utilities took that into

14

consideration in what they're developing.

And we

15

We're interested in that.

16

that can be a way to streamline the

17

presentations and help us focus on exactly

18

what is needed to comply with SB-901.

19

encourage that effort and would like to hear

20

more from the utilities by e-mail or some way

21

about this notion of a webinar.

22

would be a conversation and not just "here's

23

our template and this is what we're going to

24

do" kind of thing.

25

We think

So we

We hope that

That is one thing.

The other is you just mentioned

26

discovery.

I think a couple of us suggested

27

in our comments that given the very

28

fast-track nature of this proceeding that

PUBLIC UTILITIES COMMISSION, STATE OF CALIFORNIA
SAN FRANCISCO, CALIFORNIA

 57

1

there be a fast-track discovery process; that

2

instead of the normal 10-business-day

3

turnaround time or 14-calendar-day turnaround

4

time for data request responses, that

5

utilities endeavor to meet a 5-business-day

6

or 7-calendar-day turnaround time.

7

there be a discovery portal set up by the

8

utilities, either each of them separately or

9

a single portal, however they want to do it,

10

that enables us to see all the requests that

11

have come in and all the responses so that we

12

can avoid redundancy in our discovery.

13

ALJ ALLEN:

Also that

I like the idea of a

14

discovery portal, whether it's a unified one

15

or separate one because I think that way you

16

can avoid answering redundant or similar

17

questions.

18

that be set up.

19
20
21
22

So I would highly recommend that

Judge Thomas.
ALJ THOMAS:

I had a question for

Mr. Archer.
When are you planning on circulating

23

the template?

24

days, November 27th and 28th, which is coming

25

up awfully soon, the week after Thanksgiving.

26

And therefore were you planning on

27

circulating those today, this week?

28

You had suggested a couple of

MR. ARCHER:

I will just defer that to

PUBLIC UTILITIES COMMISSION, STATE OF CALIFORNIA
SAN FRANCISCO, CALIFORNIA

 58

1

one of my other colleagues.

2

to the issue than I am.

3

ALJ THOMAS:

Okay.

They're closer

And then the other

4

question, the follow-up to that is:

5

take into account the information that TURN

6

submitted in developing this template?

7

Did you

I like the idea of getting this

8

around quickly and having some sort of a

9

webinar so that we can allow remote

10

participation quickly.

11

sure that I understand the process that

12

you're proposing.

13
14

MS. KOO:

I just want to make

Your Honor, Alyssa Koo, PG&E.

I think we would be happy to

15

circulate the template today after the -- to

16

the distribution list for this hearing.

17

then we were proposing to have the webinar on

18

the 27th or 28th, if we can agree on a date

19

to kind of go over it.

20

was not that closely involved in developing

21

the template, so I can't speak to what extent

22

Mr. Long's proposal was incorporated.

23
24
25

MS. GENAO:

And

I have to admit, I

This is Laura Genao with

Southern California Edison.
Our template was developed before we

26

saw TURN's template, but we are more than

27

happy to consider it and the workshop I think

28

is a good time to talk about where it might

PUBLIC UTILITIES COMMISSION, STATE OF CALIFORNIA
SAN FRANCISCO, CALIFORNIA

 59

1

fit, whether or not yours is better.

2

absolutely willing to accommodate that and

3

have that discussion.

4

ALJ THOMAS:

We are

If TURN -- if you're

5

prepared, Mr. Long, to circulate your

6

template as well, that would be appropriate

7

as well to the full service list.

8
9

MR. LONG:
OIR comments.

10

We have already done that.

ALJ THOMAS:

11

In fact it's attached to our

Okay.

Great.

There was one point and it is sort

12

of a minor point, but PacifiCorp mentioned

13

something about coordination with the large

14

IOUs.

15

own.

16

go ahead and do that now without further

17

action by the Commission.

18

to -- all of you are free to talk to each

19

other at any time and coordinate in any way

20

that is appropriate.

21

tell you to do discovery or coordinate or

22

meet and confer; just go ahead and start that

23

because we really do have a short timeline.

24

You can go ahead and do that on your
We don't need to order that.

So please

Don't wait for us

So don't wait for us to

In terms of the website proposal, I

25

think that is a great one.

We do have a

26

website out for this proceeding.

27

I don't know that we have one that links all

28

of the related proceedings like the Edison

We don't --

PUBLIC UTILITIES COMMISSION, STATE OF CALIFORNIA
SAN FRANCISCO, CALIFORNIA

 60

1

application or the Rizzo Emergency

2

Preparedness, but we'll take that suggestion

3

as well.

4

wildfire mitigation plans on our website, you

5

will get our webpage on that.

6

any suggestions for what should be on it that

7

isn't there, we have done a lot of outreach

8

to try to send local communities and a bunch

9

of, you know, public safety organizations

10

seeking informal input from them as well.

11

that page is also kind of a landing spot for

12

that.

But there is -- if you search

13

ALJ ALLEN:

14

MS. MOOSEN:

15

of your comments.

If anybody has

So

Ms. Moosen.
Just segueing off of one

16

One of the things that we would

17

request that has been quite useful in the

18

past where you have an umbrella rulemaking

19

that touches upon many active proceedings in

20

other particular applications, is to have at

21

the outset -- have the utilities prepare a

22

related case matrix that becomes part of the

23

record.

24

update it periodically.

25

to the website of course but at least made

26

available here so that when the Commission

27

already has in place proceedings that are the

28

time and the place for dealing with deep

It's a really useful tool and you
It should be posted

PUBLIC UTILITIES COMMISSION, STATE OF CALIFORNIA
SAN FRANCISCO, CALIFORNIA

 61

1

dives into much more substantive material and

2

specific funding asks that we know where to

3

go.

4

And it's difficult, I know, for the

5

Commission to get their arms around all of

6

that, especially with something as broad as

7

this subject matter but it's a very useful

8

tool and I would guess that it's not a big

9

lift for them to produce.

The are good at

10

case managing and they know which cases

11

relate to which.

12

prepared and posted for the public or somehow

13

at least distributed to the service list

14

here.

15
16

19

]
ALJ ALLEN:

Any other housekeeping

matters, ma'am?

17
18

So I would ask that that be

MS. FERNANDEZ:

Laura Fernandez for

CMUA.
We would like to request that to the

20

extent that there's informal activities or

21

coordination going on amongst parties that

22

are preparing these plans, that this

23

information for webinars, about templates, or

24

any sort of informal workshops are circulated

25

to the service list so that parties who are

26

not preparing mitigation plans in this

27

proceeding, but who are potentially impacted

28

by them, such as East Bay MUD and other

PUBLIC UTILITIES COMMISSION, STATE OF CALIFORNIA
SAN FRANCISCO, CALIFORNIA

 62

1

utilities are able to participate as they

2

would like to participate.

3

ALJ ALLEN:

Yes.

We would encourage

4

the broad inclusion of all the parties.

5

mean, certainly, if parties want to have

6

separate conversations, we can do that, but

7

to the extent possible, I think it would be

8

best if communications are inclusive.

9
10

Are there any other housekeeping
matters to address?

11
12

I

MS. HOOK:

Charlyn Hook, Public

Advocates Office.

13

Yes.

Thank you for informing us we

14

can do discovery now.

15

have asked for an expedited discovery

16

turnaround, and we would support that, and we

17

would also like to request a dedicated

18

administrative law judge for discovery

19

disputes, if they arise, because they can

20

take a long time.

21

ALJ ALLEN:

We note that parties

Any discovery disputes

22

should be referred to Judge Thomas and I, and

23

we certainly support the idea of expedited

24

responses.

25

more formally.

26

responses are possible, we would encourage

27

those.

28

The scoping memo may lay this out
To the extent expedited

At this time I think I will turn it

PUBLIC UTILITIES COMMISSION, STATE OF CALIFORNIA
SAN FRANCISCO, CALIFORNIA

 63

1
2

over to President Picker.
PRESIDENT PICKER:

3

Thank you.

I just wanted to say a few things

4

that I have been repeating a lot in different

5

settings to remind people of the overall

6

context and try to avoid the use of the word

7

"scope," which has a particular meaning here

8

at the PUC, but one in 10 wildfires is

9

related to utility infrastructure, and out of

10

that one in 10, half them are caused by

11

extrinsic actors.

12

is mylar balloons, and that's going to be

13

very hard to account for in a wildfire

14

mitigation plan.

15

aware of many efforts to try to get mylar

16

balloons banned, and it's an ongoing

17

challenge, and it's still not regulated, and

18

I'm definitely not asking for jurisdiction

19

over mylar balloons.

20

balloons.

21

kinds of things that when you think about --

22

you know, in case you missed it, earlier this

23

summer, there was a wildfire caused in Chico

24

by a bear that climbed a pole and sadly for

25

the bear, their behavior resulted in bear

26

death, but also some couple hundred acres in

27

wildfire and property damage.

28

be aware that not everything, not all

So, for example, classic

As a matter of fact, I'm

We just got hot air

But I do think that those are the

So we have to

PUBLIC UTILITIES COMMISSION, STATE OF CALIFORNIA
SAN FRANCISCO, CALIFORNIA

 64

1

problems are going to be solved here.

2

I'll just go back to outages.

There

3

was an 80,000 customer outage that happened

4

previous to the southern California fires

5

that was not related to public safety power

6

shutoff.

7

count on solving all of their problems here

8

at the PUC.

9

being realistic about what we can accomplish

So local governments need to not

And, again, I'll make a plea for

10

here in the proceeding, but also set the

11

expectation that not all problems will be

12

cured here in this proceeding, and people

13

need to think about how they are going to

14

address that.

15

Ms. Moosen had a ringing endorsement

16

of centralized planning that I would like to

17

read into the PCIA Phase 2, but, again, I

18

think we have to be realistic about how much

19

we can do.

20

Similarly many of the

21

characteristics you experience in southern

22

California due to the chaparral brushlands

23

are going to be different than you see in the

24

coastal mountains of northern California with

25

wild oak woodlands and high Sierran forests.

26

So it will be a challenge to really

27

come up with a singular perfect plan that

28

will stand for all time.

So, A, there ought

PUBLIC UTILITIES COMMISSION, STATE OF CALIFORNIA
SAN FRANCISCO, CALIFORNIA

 65

1

to be some regional variation in how we

2

address this, or we ought to be permissive

3

enough that there's actual scope for

4

implementation at the local level based on

5

vastly differing conditions.

6

So I'm just aware that there's only

7

so much that can be done in a regulatory

8

setting.

9

heard hear strike me not so much as

I will say that some of things I

10

necessarily being cured by rules, but simply

11

by improved implementation.

12

things together suggest to me, as the judge

13

started, that we will probably not come up

14

with the perfect framework for plans at the

15

outset, particularly given the timeline, and

16

I want myself and other people to start with

17

the expectation that we may come up with

18

plans this year that we evaluate and learn

19

and that we iterate into, perhaps, a second

20

set of plans.

21

So all these

We have done this elsewhere in

22

vegetation management where we started with

23

the RAMP plan.

24

Cal Fire's fire scientists were able to

25

provide to us on fuel situation, and then

26

over time, as the drought continued and we

27

saw the advancing impacts of climate change,

28

and we learned about the presence of

It was based on information

PUBLIC UTILITIES COMMISSION, STATE OF CALIFORNIA
SAN FRANCISCO, CALIFORNIA

 66

1

conditions that have never been experienced

2

before in northern California, much more

3

ferocious winds in specific canyons than had

4

ever been measured before, we learned, and

5

we're going to have to adapt.

6

So I'm saying this to myself over

7

and over and over again so that I temper my

8

expectations about the judge's statement that

9

what we need to do is avoid the worst

10

imperfections, and be humble, and also just

11

remind people elsewhere that not everything

12

can be cured here.

13

are outside of the PUC and the utility scope

14

that we all need to be aware of, and I think

15

for that we need to look at our colleagues

16

and partners in Cal OES, and Cal Fire in

17

terms of fire, and OES in terms of a variety

18

of other kinds of emergencies.

19

pressing for us, but I want to humble about

20

the scope of what we can actually achieve in

21

every case here.

22

ALJ ALLEN:

23
24

There are clearly things

These are

Thank you.

Commissioner Rechtschaffen, do you
have anything?

25

COMMISSIONER RECHTSCHAFFEN:

26

ALJ ALLEN:

27
28

No.

Thank you.

I have two more appearance forms,
Zone 7 Water Agency requesting party status,

PUBLIC UTILITIES COMMISSION, STATE OF CALIFORNIA
SAN FRANCISCO, CALIFORNIA

 67

1

and April Sommer for Protect Our Communities

2

Foundation requesting party status; those

3

requests are granted.

4
5
6
7

Is there anything else that we need
to address today?
(No response.)
ALJ ALLEN:

Seeing none, thank you very

8

much for your time.

9

This prehearing conference is adjourned.

10
11
12

Greatly appreciated.

(Whereupon, at the hour of 12:00
p.m., at San Francisco, California,
the Commission then adjourned.)
]
*

*

*

*

*

13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28

PUBLIC UTILITIES COMMISSION, STATE OF CALIFORNIA
SAN FRANCISCO, CALIFORNIA

 68

BEFORE THE PUBLIC UTILITIES COMMISSION
OF THE
STATE OF CALIFORNIA

CERTIFICATION OF TRANSCRIPT OF PROCEEDING
I, Carol A. Mendez, Certified Shorthand Reporter
No. 4330, in and for the State of California, do
hereby certify that the pages of this transcript
prepared by me comprise a full, true, and correct
transcript of the testimony and proceedings held in
this matter on November 14, 2018.
I further certify that I have no interest in the
events of the matter or the outcome of the proceeding.
EXECUTED this 14th day of November, 2018.

_________________________
Carol A. Mendez
CSR No. 4330

 69

BEFORE THE PUBLIC UTILITIES COMMISSION
OF THE
STATE OF CALIFORNIA

CERTIFICATION OF TRANSCRIPT OF PROCEEDING
I, Shannon Ross, Certified Shorthand Reporter
No. 8916, in and for the State of California, do
hereby certify that the pages of this transcript
prepared by me comprise a full, true, and correct
transcript of the testimony and proceedings held in
this matter on November 14, 2018.
I further certify that I have no interest in the
events of the matter or the outcome of the proceeding.
EXECUTED this 14th day of November, 2018.

_________________________
SHANNON ROSS
CSR No. 8916