transmission and distribution (t&d) volume 6, part 2 – pole...

Application No.: Exhibit No.: SCE-03, Vol. 06, Pt. 2 Witnesses: K. Trainor

(U 338-E)

2015 General Rate Case

Transmission and Distribution (T&D) Volume 6, Part 2 – Pole Loading

Before the

Public Utilities Commission of the State of California

Rosemead, CaliforniaNovember 2013

SUMMARY

This chapter describes SCE’s new initiative to address pole loading. It includes costs for pole

loading assessments and the associated remediation. SCE is requesting $1.079 billion in 2013-2017

capital expenditures and $38 million in 2015 test year expenses in these categories.

Pole Loading Program O&M Expenses 2015 Forecast

(Total Company Constant 2012 $Million)

T&D Engineering and Grid Technology (Volume 2)

$54 8%

Customer Driven Prog & Distr. Con. (Volume 5)

$16 2%

Distribution Maintenance (Volume 6, Part 1)

$190 30%

Pole Loading (Volume 6, Part 2)

$39 6%

Grid Operations (Volume 7)

$112 18%

Transmission & Substation Maintenance (Volume 8)

$86 13%

Safety, Training, and Environmental

Programs (Volume 9)$68

11%

T&D Other Costs and OOR (Volume 10)

$76 12%

Pole Loading Program Capital Expenditures 2013 – 2017 Forecast

($ Millions, CPUC Jurisdictional Only)

T&D Engineering and Grid Technology

(Volume 2), $183 , 1%

System Planning Capital Projects

(Volume 3), $2,165 , 18%

Infrastructure Replacement Programs

(Volume 4), $2,032 , 17%

Customer Driven Prog & Distr. Con.(Volume

5), $3,158 , 26%Distribution

Maintenance (Volume 6, Part 1), $2,519 ,

21%

Pole Loading (Volume 6, Part 2),

$1,078 , 9%Grid Operations (Volume 7), $511 , 4%

Transmission & Substation

Maintenance (Volume 8), $438 , 4%

SCE-03: Transmission and Distribution Volume 06, Part 2-Pole Loading

Table Of Contents Section Page Witness

-i-

I. Introduction ........................................................................................................1 K. Trainor

A. Historical Background of Pole Loading ................................................2

1. Pole Loading Regulation............................................................2

2. Description of Pole Loading ......................................................4

3. Evolution Of Pole Loading Methods Over Time .......................5

4. Mandatory Access ......................................................................6

B. Current Situation ....................................................................................7

C. Factors Contributing to the Current Situation ........................................7

1. Changes to Design Standards and Technology ..........................7

2. Changes to Areas Designated as High Wind .............................8

3. Increased Demand on Overhead Structures ...............................8

4. Gaps in the Joint Pole Process ...................................................9

D. Initial Studies and Improvement Efforts ..............................................10

1. Early Pole Loading Studies and Operational Improvements ..........................................................................10

2. Pole Loading Application Replacement (PoLAR) ..................10

3. 2012 GRC Study ......................................................................11

4. Wind Design Study ..................................................................12

5. “Grandfathered” Poles .............................................................12

E. The Pole Loading Program (PLP)........................................................12

1. Pole Loading Assessment and Remediation ............................13

a) Pole Loading Assessment Description.........................13

b) Pole Loading Remediation Description .......................14


Table Of Contents (Continued) Section Page Witness

-ii-

2. Ongoing Improvements to the Joint Pole Attachment Process ..................................................................15

a) Malibu Settlements ......................................................15

b) Fire Safety Rulemaking (R.08-11-005) .......................16

c) Improvements to Joint Pole .........................................17

II. Work Descriptions, Recorded Costs And Test Year Forecasts .......................18

A. Forecast O&M Expenses and Capital Expenditures Summary ..............................................................................................18

1. Comparison of 2012 GRC Authorized and Recorded ..................................................................................18

B. O&M Expenses ....................................................................................19

1. Pole Loading Assessment FERC Account ...............................19

a) Cost Forecasts ..............................................................19

2. Pole Loading Repair Expenses, portion of FERC Accounts 571.125 and 593.125 ................................................21

a) Cost Forecasts ..............................................................22

3. Related Expense, portion of FERC Accounts 571.125 and 593.125 ................................................................23

a) Cost Forecasts ..............................................................24

4. Joint Pole Organization (JPO) for Pole Loading, portion of FERC Account 583.125 ..........................................25

a) Cost Forecasts ..............................................................25

C. Capital Expenditures ............................................................................26

1. Pole Loading Driven Replacements Capital Expenditures ............................................................................26

a) Cost Forecasts ..............................................................26


Table Of Contents (Continued) Section Page Witness

-iii-

2. Pole Loading Program Driven Distribution Transformers ............................................................................28

a) Cost Forecast ................................................................28

3. Pole Loading Program Driven Prefabrication..........................29

a) Cost Forecasts ..............................................................29

4. Pole Loading Program Driven Joint Pole Credits ....................31

a) Cost Forecasts ..............................................................31

5. Pole Loading Program Driven Wood Pole Disposal ...............33

a) Cost Forecasts ..............................................................33

III. O&M Account Summaries ..............................................................................35

A. FERC Account 566.125 .......................................................................35

B. FERC Account 571.125 .......................................................................36

C. FERC Account 583.125 .......................................................................37

D. FERC Account 593.125 .......................................................................38

Appendix A Witness Qualification ..................................................................................


List Of Figures Figure Page

-iv-

Figure I-1 Diagram of Wood Pole and Associated Equipment ...................................................................3

Figure II-2 Pole Loading Driven Pole Replacements Recorded 2008-2012/Forecast 2013-

2015 Capital Expenditures (Nominal and Constant 2012 $000) .........................................................28

Figure II-3 Distribution Transformers, PLP portion Recorded 2008-2012/Forecast 2013-

2017Capital Expenditures ....................................................................................................................29

Figure II-4 Prefabrication, PLP portion Recorded 2008-2012/Forecast 2013-2017Capital

Expenditures ........................................................................................................................................31

Figure II-5 Joint Pole Credits – Distribution, PLP portion Recorded 2008-2012/Forecast

2013-2017Capital Expenditures ...........................................................................................................32

Figure II-6 Joint Pole Credits – Transmission – PLP portion Recorded 2008-

2012/Forecast 2013-2017Capital Expenditures ...................................................................................33

Figure II-7 Wood Pole Disposal, PLP portion Recorded 2008-2012/Forecast 2013-

2017Capital Expenditures ....................................................................................................................34

Figure III-8 Summary of FERC Account 566.125 Recorded and Adjusted 2008-

2012/Forecast 2013-2015 (Constant 2012 $000) .................................................................................35








List Of Tables Table Page

-v-

Table I-1 Malibu Settlement Adjustment to Capital and O&M Forecasts (Nominal $) ............................16

Table II-2 Pole Loading Program Summary of 2015 O&M Forecast (Constant 2012

$000) ....................................................................................................................................................18

Table II-3 Pole Loading Program Capital Expenditures Summary of 2013-2017 Capital

Expenditures Forecast ..........................................................................................................................18

Table II-4 Total PLP Assessment Counts and Costs, Transmission & Distribution

(Constant 2012 $000) ...........................................................................................................................20

Table II-5 Pole Loading Assessments (Distribution) Portion of FERC Account 583.125

Recorded and Adjusted 2008-2012/Forecast 2013-2015 (Constant 2012 $000) ................................21

Table II-6 Pole Loading Assessments (Transmission) Portion of FERC Account 566.125


Table II-7 Pole Loading Repair Costs (Distribution and Transmission) – Detailed

Forecast (Constant 2012 $000) ............................................................................................................22

Table II-8 Pole Loading Repair Costs (Distribution) Portion of FERC Account 593.125


Table II-9 Pole Loading Repair Costs (Transmission) Portion of FERC Account 571.125


Table II-10 PLP Related Expense – Distribution Portion of FERC Account 593.125


Table II-11 PLP Related Expense – Transmission Portion of FERC Account 571.125


Table II-12 PLP JPO Expense Portion of FERC Account 583.125 Recorded and Adjusted

2008-2012/Forecast 2013-2015 (Constant 2012 $000) ......................................................................25

Table II-13 Pole Loading Driven Pole Replacements ...............................................................................27

Table II-14 Historical Prefabrication Capital Expenditures (Nominal $000) ............................................30

1

I. 1

INTRODUCTION 2

SCE’s electric and telecommunications facilities are attached to over 1.4 million poles that range 3

from less than one year to nearly 100 years of age. General Order (G.O.) 95 requires that utility poles 4

meet specified design criteria based upon calculated loads resulting primarily from wind and the 5

presence of attached facilities. These criteria are called “safety factors.” The calculation of safety 6

factors is referred to as “pole loading.” On approximately 70 percent of poles, SCE’s facilities share 7

space with the facilities of other electric and telecommunications utilities. SCE is required by 8

“mandatory access” to permit certain telecommunications utilities to attach to its poles.1 Each utility 9

that attaches to a pole must ensure that, following construction of the attachment, the pole will continue 10

to meet the safety factors specified in G.O. 95. Otherwise, the pole must be modified or replaced to 11

accommodate the increased load. 12

SCE has designed and constructed its overhead system to meet the regulatory and engineering 13

standards in effect at the time. Nevertheless, recent events, including the Malibu Canyon Fire in 14

October 2007 and the November 2011 San Gabriel Valley windstorm, have shown that some of the 15

poles that failed during those incidents did not meet minimum pole loading criteria when measured 16

against today’s standards. Even where SCE disputes that poles failed due to “overloading,”2 these 17

events initiated renewed interest in pole loading as a safety issue. 18

The Commission’s response to these recent events has also highlighted the fact that regardless of 19

the cause of the pole failure, SCE is expected to address the pole loading challenge for all poles owned 20

or jointly owned by SCE. Given the potential risks associated with overloaded poles, SCE has 21

developed a plan to address the challenge. This exhibit provides the technical and regulatory 22

background, highlights the need for a multi-pronged approach, presents SCE’s approach and work 23

completed to-date, and details the cost forecasts for conducting pole loading assessments and 24

remediation during this rate cycle. 25

1 See D.98-10-058. 2 Depending upon conditions and circumstances, even a pole that meets all regulatory requirements can fail (for example,

car-hit pole, wind exceeds design standards, trees, limbs, or debris blown into lines, or undetected weaknesses including deterioration or material strength).

2

A. Historical Background of Pole Loading 1

1. Pole Loading Regulation 2

The CPUC regulates safety and reliability through the issuance of rules and regulations 3

included in General Orders. General Order 95 (G.O. 95) sets forth rules for the design, construction, and 4

maintenance of overhead lines. These rules apply to all overhead electrical supply and communication 5

facilities that come within the jurisdiction of the Commission, located outside of buildings, including 6

facilities that belong to non-electric utilities. G.O. 95 was first issued in 1941 and has been revised 7

many times since its issuance in an effort to improve safety and reliability in the State of California. 8

G.O. 95 contains rules regarding the conditions, such as temperature and wind loading, that are used to 9

determine the required strength of a pole. It also specifies safety factors that must be met in order for a 10

pole to be in compliance. 11

Specifically, G.O. 95 states that at the time of installation, a newly constructed utility 12

pole containing both electric and communications equipment (known as a Grade A or combination 13

pole), must be built with a safety factor of 4.0.3 Once in-service, G.O. 95 requires that Grade A poles 14

must be replaced before the safety factor is reduced below 2.67 due to deterioration or the addition of 15

facilities.4 This safety factor calculation is called “pole loading.” Figure I-1 shows a diagram of a 16

typical joint use wood utility pole. 17

3 See G.O. 95 Rule 44.1, Table 4. 4 See G.O. 95 Rule 44.3. Poles that contain electric facilities only are called Grade B poles. Grade B poles have a

required new construction safety factor of 3.0 and once in-service must be replaced before the safety factor is reduced below 2.0.

3

Figure I-1 Diagram of Wood Pole and Associated Equipment

4

2. Description of Pole Loading 1

Pole loading calculations require many inputs, including but not limited to: 2

pole class (size), length, wood species, and groundline circumference; 3

height, number, size, weight, type, angle, and span length of attached conductors and 4

equipment; 5

the height, number, and lead of guys supporting the pole and its attachments; 6

height, number, size, weight, type, angle and span length of third party attachments, 7

including cables, messenger wires, antennas and risers, to the extent the information 8

is available or can be measured in the field. 9

The main risk associated with poles that do not meet minimum requirements is that they 10

may break or fail at wind loads that are below the minimum design wind loads for that geographic 11

location, resulting in an increased risk to public safety and system reliability. 12

A pole loading calculation is performed when a new pole is installed or when capital 13

equipment is installed or modified on a pole that will materially increase the load on the pole. SCE’s 14

design and construction standards require that newly constructed poles meet the safety factors specified 15

in G.O. 95 at the time of installation, plus any SCE internal design standards that may exceed minimum 16

regulatory requirements. SCE’s internal standards also require that a pole loading calculation be 17

performed whenever equipment is attached or modified that will materially increase the loading on the 18

pole. Thus, SCE’s facilities are designed and constructed to meet the standards applicable at the time of 19

installation.5 However, as described below, other parties attach equipment to SCE’s structures through 20

either a joint ownership arrangement or a rental arrangement. Joint owners are responsible for 21

performing the pole loading calculation whenever they attach or modify equipment and for ensuring that 22

the safety factor meets G.O. 95 standards. Renters are responsible for providing the necessary 23

information to SCE prior to attaching so that SCE can perform the pole loading calculation and take 24

action, if required. 25

5 SCE expects that if the planner follows SCE’s design processes (and SCE has controls in place plus a quality assurance

program to verify that planners meet their expectations), and the resulting pole and equipment are constructed as designed, the new structure will meet the required installation safety factors. Once installed, the safety factor may be reduced by one-third (see G.O. 95, Rule 44.3) prior to requiring replacement. The difference between the “installation” and “in-service” safety factors is used as a buffer against, among other things, deviations in design and construction, addition of new facilities, and deterioration of material strength.

5

3. Evolution Of Pole Loading Methods Over Time 1

SCE has met G.O. 95’s safety factor requirements in effect at the time of installation with 2

procedures that have changed over time due to various external and technological factors. In the years 3

following World War II up through most of the 1980s, SCE’s design standards incorporated safety 4

factors into the engineering tables used to select pole sizes. That is, safety factors were not separately 5

calculated, but were met due to pre-engineered design requirements. This was an accepted practice in 6

the industry at the time. As the demand on electrical and communication infrastructure rapidly 7

expanded from the 1980s to the present, SCE’s former design standards became obsolete, since those 8

standards had not been engineered to consider the kinds of conductor and equipment that SCE was now 9

required to host on its poles. Concurrently, technology and computing power to perform complex 10

engineering calculations also advanced in the 1990s, making it feasible to calculate individual safety 11

factors for each pole. 12

SCE developed a software tool to calculate safety factors as specified in Appendix F of 13

G.O. 95. That tool, called Wind Load Estimator, was introduced in 2000. Wind Load Estimator 14

changed the methodology used to determine pole loading compliance with G.O. 95 safety factors by 15

enabling pole loading for each pole to be individually calculated during the design of new pole 16

installation or pole modification, instead of referencing pre-engineered tables. The Wind Load 17

Estimator methodology measured the bending moment at the ground line, as shown in G.O. 95 18

Appendix F. It also calculated, as necessary, the “vertical” or “buckling” safety factor, and a separate 19

safety factor for each guy wire attached to the pole.6 Since 2000, computing power and software 20

capability have continued to mature, enabling more sophisticated and complex calculations, and 21

rendering Wind Load Estimator itself obsolete. New software can calculate precise safety factors along 22

the entire length of a pole in a manner that could never be calculated by hand or with Wind Load 23

Estimator. Adoption of a new software tool will once again change how SCE meets pole loading 24

requirements. In addition, a pole that was properly installed according to earlier standards and methods, 25

6 Although taken into account as part of the engineering tables, the vertical or buckling safety factor is an example of a

calculation that could not be performed regularly by hand. The introduction of Wind Load Estimator gave this particular variable visibility.

6

if re-calculated today, may now show a failing safety factor due solely to the difference in the 1

methodology used to perform the pole loading calculation.7 2

4. Mandatory Access 3

Under California’s mandatory access policy, implemented in D.98-10-058, SCE is 4

required to permit certain telecommunications utilities to attach to its poles through a rental 5

arrangement. SCE also meets its mandatory access obligations by voluntarily providing access to 6

certain third parties through a joint ownership arrangement. Each of these is discussed below. 7

Third-party entities that attach facilities to SCE poles are comprised of two categories, 8

joint owners and renters. Joint owners purchase an interest in a pole through membership in the 9

Southern California Joint Pole Committee. The Joint Pole Committee is made up of representatives of 10

utilities, communications providers, and municipalities in Southern California who hold joint equity 11

interest in utility poles. Established by telephone, electricity, and railroad companies in 1906, the 12

Committee was formed because of the need to limit the number of poles in the field and to create a 13

uniform procedure for recording pole ownership. The Committee’s principal functions are to keep 14

accurate records of ownership for each jointly-owned pole, to calculate the established value of each 15

transaction involving the sale or purchase of joint pole equity interests or maintenance of those interests, 16

and to prepare monthly Bills of Sale, which are sent to the members to enable them to make monetary 17

settlement of their joint enterprises. Joint owners are typically telephone or wireless companies, or other 18

electric utilities. 19

Importantly, the Joint Pole Committee administers the parties’ interests and arranges 20

payments; it does not perform pole loading calculations, nor does it enforce or track compliance with 21

Commission rules and regulations. Once the joint owner has obtained an ownership interest in a pole, 22

the joint owner is solely responsible for ensuring that following its attachment (or the attachment of one 23

of its tenants) the pole meets G.O. 95 safety factor requirements. 24

The second category, renters, are “tenants” within space owned by SCE on its poles. 25

Tenants, primarily Cable TV companies, submit their requests to attach to SCE. SCE calculates the 26

resulting safety factors and determines whether the company can attach to an existing pole, or whether 27

modification or replacement of the pole is required before permitting the tenant to attach. Recent events 28

7 This is because the methodology used prior to the emergence of computer software relied upon a simplified calculation

performed at the pole’s groundline. This produces both false positives and false negatives when compared to modern calculations that consider distribution of load along the entire length of the pole.

7

have focused attention on the current practices and suggest that greater coordination among joint owners 1

and tenants is required. 2

B. Current Situation 3

In October 2007, wildfires ravaged Southern California. Three fires in San Diego County and 4

one in Los Angeles County were investigated by the California Public Utilities Commission (CPUC) as 5

power line ignitions. The fire allegedly sparked by SCE equipment is known as the Malibu Canyon 6

Fire. High wind conditions were observed at the time of the fire, and three joint use poles failed and fell 7

to the ground. One or more of the poles involved are alleged to have been “overloaded” at the time of 8

the fire, meaning they did not meet the minimum safety factor requirements in G.O. 95. This event 9

initiated renewed interest in pole loading as a safety issue. As a result of these fires, the CPUC opened a 10

rulemaking in 2008 seeking to clarify and strengthen safety rules to prevent power line fire ignitions. 11

On the evening of November 30 – December 1, 2011, an historic windstorm struck the San 12

Gabriel Valley in Southern California. Nearly 250 poles fell as a result of the storm. Although nearly 13

all the failures can be attributed to trees and other vegetation, pole loading calculations re-created after 14

the storm demonstrated that a number of the poles had safety factors below the minimums required by 15

G.O. 95. The Safety and Enforcement Division (SED), formerly the Consumer Protection and Safety 16

Division (CPSD), of the CPUC released a preliminary report that highlighted pole failures, especially 17

overloaded poles that failed, as a contributory cause to the outages experienced during the windstorm. 18

As discussed below, in recent studies where SCE tested a significant sample of poles using 19

modern methods for calculating the safety factor, SCE found that a percentage of those tested did not 20

meet the required G.O. 95 safety factors, even when deterioration is excluded from the calculation. 21

C. Factors Contributing to the Current Situation 22

Over time, many factors have contributed to the degradation of pole loading safety factors, 23

including those described below. 24

1. Changes to Design Standards and Technology 25

Technological advancement has led to changes over the years to SCE’s design standards. 26

For example, as described above, pole loading is now calculated separately using sophisticated software 27

rather than pre-engineered directly into the design, resulting in improved accuracy. In addition, SCE has 28

created new standards to test points of attachment (e.g., the strength of wood where transformers attach 29

to poles) and sidewalk anchor guys (also called queen posts). While these changes are positive and 30

necessary steps for continuous improvement, the result is that poles properly designed and constructed 31

8

using previous standards and measured using yesterday’s tools may not meet standards when evaluated 1

with today’s tools. 2

2. Changes to Areas Designated as High Wind 3

Due to incidents and observations of high wind events, SCE has designated certain areas 4

of its service territory as “high wind areas.” SCE’s design standards for high wind areas require poles to 5

be constructed using an assumed wind speed that is greater than the G.O. 95 minimum standard of eight 6

pounds per square inch.8 SCE continues to study wind conditions within its service territory to identify 7

the appropriate wind loading for calculating safety factors. This higher wind standard results in more 8

robust or “hardened” structures than would otherwise be required absent the designation. Current SCE 9

standards, as allowed by G.O. 95, permit poles that were constructed prior to the effective date of the 10

high wind designation to remain “grandfathered” under the prior standard. Thus, poles constructed in an 11

area before SCE designated it as a high wind area were constructed to a design standard lower than what 12

is required for poles constructed today in that area.9 13

3. Increased Demand on Overhead Structures 14

Demands for electricity and telecommunications have increased significantly since World 15

War II. This demand has led to an increased quantity of attachments on previously constructed poles 16

without assurances that attaching parties have met all of G.O. 95’s minimum loading requirements. 17

Since telecommunication deregulation, there has been unprecedented growth in 18

attachments with multiple telecommunications, cable, and wireless companies competing for 19

diminishing space to attach their equipment. At the same time, growth of air conditioning, appliances, 20

commercial lighting, and computing equipment has increased the demand for electrical upgrades such as 21

new transformers and heavier conductors. With the majority of SCE’s poles being jointly owned, SCE 22

shares pole space with a number of stakeholders across industries. Of the over 1.4 million poles in 23

SCE’s system, 70 percent are jointly owned, and of those, SCE is not the base owner of 16 percent, 24

meaning the pole was set by another company but supports SCE lines. There are also approximately 25

8 Since SCE’s internal standards exceed G.O. 95 minimum requirements, SCE has not been able to compel attaching

parties to design to its higher wind standards, which contributes to the finding of overloaded conditions in those areas. As part of the improvements to the Joint Pole process that SCE is seeking in conjunction with the Pole Loading Program, SCE will work with joint owners to come to an agreement on designing to SCE internal standards in designated high wind areas. This is also an issue that is being discussed in the ongoing Fire Safety Rulemaking, R.08-11-005.

9 As described below, SCE plans to upgrade grandfathered poles to existing high wind standards as part of the Pole Loading Program.

9

160 active licensees for which SCE validates pole loading. These include cable TV companies, the U.S. 1

Government, and water companies. For joint owners, the agreements recognize that G.O. 95 requires 2

that the last member attaching must not overload the pole or otherwise violate G.O. 95. However, since 3

the 2007 wildfires in Southern California, SED has taken the position that all parties attached to a pole 4

are accountable for pole loading violations regardless of which company actually “caused” the 5

condition. 6

4. Gaps in the Joint Pole Process 7

Each owner or lessor is required to perform pole loading calculations before attaching 8

their equipment or leasing space to another company for its attachments. But there are no assurances 9

that attaching parties have consistently performed these calculations – or performed them correctly – 10

over the last 30 or more years. Moreover, unauthorized attachments by renters or joint owners—11

attachments without records of rental or joint pole agreements—have contributed to additional 12

equipment on poles. Further, joint owners may add equipment to space they own, or rent to others 13

without providing any notification to SCE. 14

Even if it is assumed that each attaching party makes a good faith effort to perform the 15

calculation, disputes over interpretation of regulatory requirements (e.g., G.O. 95, Rules 48 and 31.1) 16

have led to uncertainty as to what qualifies as a valid pole loading calculation. Furthermore, differences 17

in assumptions, methodologies, measurements, and inputs result in variations in safety factor 18

calculations for the same structure.10 While Rule 44.4 requires that companies share the most recent 19

intrusive pole test data to accurately calculate the safety factor of a pole accounting for any measured 20

deterioration, it appears companies are not universally considering intrusive data in their calculations. 21

So while each company may have been following the rules as they understood them, and constructed 22

their facilities in accordance with that understanding, differing assumptions, disparate methodologies, 23

and various interpretations of the rules have contributed to the fact that poles have become overloaded 24

when measured against SCE’s internal design standards using today’s sophisticated calculation 25

methodology. 26

10 Important differences among companies performing pole loading include (1) different conductor sizes and weights; (2)

different tension values; and (3) differences in the use of certain constants, such as the modulus of elasticity for various species of wood.

10

D. Initial Studies and Improvement Efforts 1

1. Early Pole Loading Studies and Operational Improvements 2

Following SED’s testimony in the 2007 Malibu Canyon Fire Investigation,11 SCE 3

initiated studies to determine whether and to what extent overloaded poles existed within its service 4

territory. The first of these studies, the Pole Loading Inspection Pilot, evaluated a small sample of poles 5

(300) in high risk areas. Following this study, the November 30, 2011 San Gabriel Valley windstorm 6

caused approximately 250 poles to fail. After the windstorm, SCE performed post-incident pole loading 7

calculations on the failed poles plus every pole that was modified as a result of the windstorm.12 SCE 8

also received a request from the Commission in late 2011 to perform additional inspections on five 9

specific circuits and report back any findings. In response to this request, SCE performed pole loading 10

on the approximately 1,200 poles on those circuits. In each of these cases, a portion of the assessed 11

poles came back with safety factors below the minimum required by G.O. 95. 12

Following the San Gabriel Valley windstorm event in December 2011, SCE initiated a 13

series of operational improvements to reduce the risk that poles would continue to become overloaded 14

within its service territory. These improvements included: (1) the PoLAR project; (2) mandatory 15

training on pole loading for every SCE planner and estimator; and (3) updated processes, procedures, 16

and controls designed to require that pole load calculations are performed as necessary, performed 17

correctly, reviewed by a supervisor, and retained in SCE’s system of record, SAP. SCE’s improvements 18

in record retention are designed to meet the new requirement to retain pole loading records for 10 years, 19

which was added to G.O. 95 by D.12-01-032. 20

2. Pole Loading Application Replacement (PoLAR) 21

As one of several steps to improve the identification and correction of overloaded poles 22

in SCE’s service territory, SCE launched the PoLAR project, which is described more fully in Exhibit 23

11 SED’s testimony alleged that every attaching party on an overloaded pole has violated G.O. 95 requirements due to the

overloaded condition, regardless of which attachment actually caused the pole to become overloaded. 12 In the second-half of 2012, following re-training of SCE’s planners, estimators, and design contractors, SCE recalculated

the safety factors of every pole installed or modified by SCE since December 1, 2011. That effort found that approximately 9.8 percent of the poles installed or modified between December 1, 2011 and July 31, 2012 required replacement. This finding is not comparable to the preliminary findings of the 2012 GRC Pole Load Study that are used as the basis for the forecasts in this Volume because: (i) many of the poles in the recalculated sample were originally repaired under emergency conditions that do not require a pole load calculation to be performed (See G.O. 95, Rule 12.5); and (ii) prior to the recalculation effort, SCE strengthened its standards defining a “material increase in load” and therefore poles that did not require a calculation when they were modified were now being tested, and some of these were found to have been overloaded for other reasons even prior to the modification.

11

SCE-05, Vol. 2, Pt. 2. Briefly, SCE previously used an in-house tool developed in 2000 called Wind 1

Load Estimator to calculate pole loading safety factors. In April of 2013, SCE began using a new, 2

modern software program called SPIDACalc to calculate pole loading calculations. SPIDACalc uses a 3

Finite Element Analysis (FEA) model to calculate the loading experienced by a pole and the resulting 4

safety factors along the entire length of the pole, resulting in a more accurate calculation than the 5

ground-line check performed by Wind Load Estimator. FEA models are the standard methodology used 6

today in all modern pole loading software platforms. As discussed above, a change in methodology 7

such as this one will result in some poles constructed with a passing safety factor using Wind Load 8

Estimator or prior methodologies now showing a failing safety factor when calculated with the new 9

software. SCE’s pole loading program will assess and remediate poles based upon the results from the 10

new software. 11

3. 2012 GRC Study 12

SCE’s 2012 GRC Decision directed SCE to perform a Pole Load Study and report back 13

to the Commission the results by July 31, 2013.13 In D. 12-11-051, the Commission said: 14

…we adopt SCE’s forecast [for intrusive pole inspections] but direct SCE to initiate an 15 assessment of pole loads in its territory…SCE shall use up to $0.753 million, the remainder 16 of the its request, to perform full inspections of a statistically valid random sample of loaded 17 poles, utility-owned and jointly-owned, to determine whether the loads meets current legal 18 standards. To the extent that the Commission orders, through any other proceeding, an 19 examination of pole loads within SCE’s territory, the study ordered here shall be coordinated 20 to avoid duplication. Any unspent funds must be used for intrusive pole inspections unless 21 the Commission is notified to the contrary by a Tier 2 Advice Letter. SCE shall serve the 22 summary results of the study on the service lists of the GRC and R.08-11-005, and provide 23 the pole-by-pole results to the Director of CPSD, no later than [July] 31, 2013. The results 24 should also be included in SCE’s next DIMP annual report. Following receipt of the study 25 results, CPSD shall make recommendations to the Commission about what steps, if any, are 26 necessary to assure that SCE’s poles are not overloaded going forward. 27

Accordingly, SCE designed a study involving a sampling of approximately 5,000 poles 28

throughout SCE’s service territory. SCE hired an independent third-party contractor to perform the 29

assessments, with SCE resources performing quality control on a sample of the contractor data. This 30

study will be used to forecast the extent that poles within SCE’s service territory will require 31

remediation to meet current standards. 32

13 See D.12-11-051, pp. 181-182.

12

Preliminary results of this study were used as the basis for SCE’s forecast for pole 1

replacements (capital) and repairs (O&M) detailed in this exhibit. 2

4. Wind Design Study 3

Over the years, SCE has designated certain areas of its service territory as high wind 4

areas, subject to loading requirements that exceed G.O. 95 minimum standards. The current wind 5

design standards were largely based on wind related incidents. SCE has engaged an experienced 6

meteorological engineering firm to perform a system-wide wind study during 2013. The study will 7

result in a system-wide map based on scientific evaluation of a 30-year history of wind events. The 8

results will be compared to current geographical wind design designations and adjustments to SCE’s 9

published pole loading standards will be made as necessary and shared with Joint Pole utilities. 10

5. “Grandfathered” Poles 11

Historically, when an area of SCE’s service territory is designated as a high wind area, 12

poles that were installed prior to the date of the designation remain “grandfathered” under the prior 13

standard. Poles set prior to 1977 in light loading districts used an 8-pound wind design equal to the G.O. 14

95 minimum standard. Since that time, as standards in wind-prone areas have been increased to 12-15

pound or 18-pound wind design, larger poles have gradually been designed and installed as the 16

grandfathered poles are replaced. SCE has determined that as part of its Pole Loading Program, 17

grandfathered poles will be assessed against current wind loading standards, and will be remediated as 18

necessary to meet the strengthened standards. 19

E. The Pole Loading Program (PLP) 20

As described above, SCE has taken many steps to address the issue of non-compliant poles 21

within its service territory. While these initiatives have and will continue to improve the situation, more 22

work is needed to bring every pole into compliance and to correct joint pole processes to prevent poles 23

from becoming overloaded with future attachments. Hence, SCE is proposing a comprehensive 24

program, the Pole Loading Program (PLP), to address pole loading issues. Thus, just as DIMP is 25

designed to identify and remediate visible non-conformances on overhead and underground facilities, 26

SCE has designed a Pole Loading Program that will assess each of SCE’s poles14 to identify and 27

remediate those poles that do not meet G.O. 95 minimum safety factors or SCE’s internal safety 28

14 PLP will include all wood, light duty steel, and other non-engineered structures. Engineered steel poles and transmission

towers are excluded.

13

standards. PLP is a multi-year program designed to mitigate the risk of pole failures due to overloading 1

through assessments and remediation, while bringing clarity to the regulations (G.O. 95) and 2

improvements to the joint pole process. Multiple work streams will run in parallel to complete the work 3

required. 4

1. Pole Loading Assessment and Remediation 5

a) Pole Loading Assessment Description 6

The work associated with PLP begins with performing physical pole loading 7

calculations on over 1.4 million wood poles, light duty steel, and composite poles in the system over a 8

seven year period. Poles located in the highest risk areas will be assessed first. Remediation is planned 9

to be completed over a twelve year period, prioritized based on risk. Numerous contract and full time 10

resources will be needed to conduct the assessments, perform the required construction remediation, and 11

to manage the large-scale effort. SCE is committed to completing this assessment as quickly as 12

possible, but has to be mindful of the volume of work, resource availability, and ability to maintain the 13

quality of inspections. Therefore, SCE is proposing a 7-year pole loading assessment period starting in 14

2014 continuing through 2020. The highest priority poles including those identified in high wind and 15

high fire areas, and poles grandfathered under previous standards will be assessed in the first three years 16

to mitigate the highest safety risks. 17

Pole loading assessments require a field assessment as well as a desktop analysis 18

to estimate each pole’s safety factor. Inputs include the physical attributes of the pole, its attachments, 19

and local weather conditions. The field assessment measures or validates the pole’s attributes as well as 20

the size and type of equipment it supports. Collected data will include SCE, Joint Pole Owners, and 21

renter attachments. The scope of data collected includes: 22

pole class (size), length, wood species, and groundline circumference, 23

height, size, number, type and span length of attached conductors, as well as 24

the size and weight of attached equipment, 25

the height, number, and lead of guys supporting the pole and its attachments. 26

Collecting the data to perform a pole loading calculation requires an experienced 27

assessor who must be able to access poles throughout SCE’s service territory, including those located in 28

remote terrain and other difficult to access locations such as customer backyards, and take accurate 29

measurements. Assessors must be close enough to the pole to measure the groundline circumference 30

14

and have sufficient room around the pole to measure attachment heights and span lengths. Photographs 1

will also be taken of each pole. 2

The desktop analysis integrates data from the field assessment, design standards, 3

and other data associated with the pole to calculate the pole loading safety factor. Other inputs include 4

the pole’s shell thickness, which is obtained from intrusive inspection results, the local wind load level 5

provided by the SCE Pole Load Manual, and other climate factors such as elevation and prevalence of 6

ice. The measurements are entered into the pole loading software (SPIDACalc), the appropriate wind 7

loading case is selected, and the safety factors are calculated. 8

b) Pole Loading Remediation Description 9

SCE planning resources dedicated to this program will review the results of 10

assessments. Poles that are not compliant with G.O. 95 safety factors or SCE internal standards will be 11

identified and the appropriate remediation will be designed and implemented. Depending on the nature 12

and extent of the noncompliant safety factor, the remediation will require either repair (i.e., the 13

installation or modification of guy wires) or complete replacement of the pole, including removal and 14

reinstallation of all attachments. SCE is responsible for guy repair at electrical levels only. If guy 15

repairs are required at communication levels, the communication companies will be notified and will be 16

responsible for the costs. If a pole replacement is required, SCE will replace the pole. Joint owners will 17

contribute to the cost of pole replacements in accordance with the applicable joint pole agreements. 18

Significant resources will be required to implement capital and O&M remediation for all poles failing 19

pole loading. 20

In order to promote efficiency and minimize duplication of work, the remediation 21

designs may be integrated with other potential work proposed in the same area, such as, but not limited 22

to, overhead to underground conversions (Rule 20), systematic rebuild, other infrastructure replacement, 23

and 4kV cutovers. It is advantageous to coordinate the PLP replacement work with other planned work 24

in order to avoid the situation of replacing a pole because of PLP and then having that same pole 25

removed or upgraded subsequently because of another project. For example, it would be duplicative to 26

replace a pole under PLP only to have it removed a few years later when the pole line is replaced with 27

an underground line. This coordination between PLP replacements and other capital projects is 28

extremely important because of the large number of pole replacements expected. Furthermore, the fact 29

that PLP may generate pole replacements in a concentrated area calls for a more comprehensive 30

15

replacement design – as opposed to mere replacement of individual poles. The remediation design will 1

be performed by SCE or contractor resources based on available capacity and other factors. 2

Concurrent with ramping up design resources, SCE is making efforts to ensure 3

electrical line construction resources are available to implement the remediation design, which could 4

involve installation of guying or complete replacement of the pole. It is anticipated that much of the 5

increased work load will be performed by existing SCE district crews and regional contractors. 6

However, a significant number of additional contract crews will be required to complete the estimated 7

work scope. Regional contract management personnel will be supplemented as necessary to adequately 8

oversee the additional crews. 9

The aged pole program, described in Exhibit SCE-03, Vol. 06, Pt. 1, will allow 10

SCE to ramp up to meet the significant increase in volume of pole replacements that will result from 11

PLP implementation. It is anticipated that as PLP replacements increase, the aged pole program volume 12

will be reduced accordingly. 13

2. Ongoing Improvements to the Joint Pole Attachment Process 14

This section describes SCE’s activities internally and externally to sustain accurate pole 15

loading in the future by all parties to avoid poles from becoming overloaded. As described above, SCE 16

has implemented new software for more accurate pole loading calculations and has provided pole 17

loading training to the relevant employees. However, variations in assumptions, interpretations, and the 18

lack of shared information remain a significant gap that must be addressed in order for accurate pole 19

loading calculations to be maintained over the long term. Therefore, SCE is focusing on working with 20

other stakeholders in the State and within the Southern California Joint Pole Committee. 21

The focus of the PLP Regulatory Plan is to drive improvements in the joint pole process 22

and to adopt a statewide methodology for performing pole loading calculations. This will be done 23

through SCE’s involvement in formal proceedings and by engaging utility peers in discussions to gain 24

concurrence on pole loading practices. 25

a) Malibu Settlements 26

Three separate settlements by various parties to the Malibu Canyon Fire OII (I.09-27

01-018) have been adopted by the Commission. The first of these settlements, known as the “CIP 28

Settlement” requires that the three settling parties – Verizon Wireless, AT&T Wireless, and Sprint – (1) 29

assess all poles along a 3.38 mile stretch of Malibu Canyon Road and bring the poles up to a safety 30

factor of 4.0; and (2) perform a statistically valid pole loading study of joint use poles within SCE 31

16

territory. The work that is being performed as a result of this settlement necessarily involves SCE as its 1

facilities are attached to the poles being assessed. SCE is cooperating with the settling parties and have 2

begun exchanging information regarding wire sizes and tensions, strength values for different species of 3

wood poles, and calculation methodology. 4

In addition, the two other settlements – one from NextG and the other from SCE – 5

both also contain provisions that will require additional pole loading assessments to be performed within 6

SCE’s service territory. The three settlements together provide the parties with a head start on efforts to 7

come to a common understanding regarding the methodology for performing pole loading calculations, 8

and on the efforts to improve joint pole processes and procedures. 9

Finally, as part of the SCE settlement, SCE shareholders have pledged to 10

contribute $17 million towards pole loading assessments and remediation in the Malibu area. In its 11

forecast costs for the Pole Loading Program, SCE has applied this $17 million as a reduction to the 12

program’s expenses and capital expenditures during this rate case period as shown in Table I-1 below.15 13

Table I-1 Malibu Settlement Adjustment to Capital and O&M Forecasts

(Nominal $) T o ta l 20 15 2 01 6 20 17

C ap ita l 1 5 ,390 ,0 64$ 5 ,13 0 ,02 1$ 5 ,1 30 ,0 21$ 5 ,1 30 ,02 1$ O & M 1,6 09 ,9 36$ 53 6 ,64 5$ 536 ,6 45$ 53 6 ,64 5$ T o ta l 1 7 ,000 ,0 00$ 5 ,66 6 ,66 7$ 5 ,6 66 ,6 67$ 5 ,6 66 ,66 7$

b) Fire Safety Rulemaking (R.08-11-005) 14

Another area where improvements are being made to pole loading and other 15

safety practices is within the fire safety rulemaking (R.08-11-005), which has been divided into three 16

phases. SCE has already implemented the Phase 1 changes to vegetation management requirements by 17

increasing tree clearance requirements to 48” in high fire hazard areas. Phase 2 requirements for “date 18

compliant” inspections were implemented January 1, 2013. Phase 2 also required that SCE establish a 19

fire prevention plan, which was filed with the CPUC on December 20, 2012. Additionally, Phase 2 20

imposed a series of new inspection requirements on CIPs. Phase 3 was itself divided into three tracks: 21

15 See Workpaper entitled “Malibu Fire Settlement Adjustments.”

17

(1) revisions to G.O. 95, Section IV (pole loading) for clarification and ease of enforcement;16 (2) data 1

collection requirements for utility-related fire starts; and (3) updated utility-specific statewide fire maps. 2

Technical panels and workshops have concluded on the first two issues and mapping issues will be 3

addressed in Track 3. As part of Track 3, SCE will contribute its wind study to aid in the development 4

of the new fire hazard maps that may define new, higher pole loading standards once Phase 3 is 5

complete. SCE is actively participating in the Rulemaking to mitigate the risk that different, higher 6

standards will be implemented than those SCE will be employing as part of PLP. SCE estimates that 7

such risk is low, however, because heightened internal wind standards will be used during PLP, which 8

should meet or exceed the final standards adopted by the Commission for those areas as part of Phase 3 9

of the Rulemaking. 10

c) Improvements to Joint Pole 11

SCE plans to work with the Southern California Joint Pole Committee and SED to 12

enhance the joint pole process to facilitate sharing of asset data and Pole Loading Calculations (PLC) 13

records, and to improve the consistency of pole loading calculations. The primary objectives are to 14

increase capabilities of Southern California Joint Pole Committee members by hosting a centralized 15

database for pole loading information (e.g., asset data, intrusive data, PLC records) and achieve 16

consensus with joint pole members on the methodology for performing pole loading calculations. As a 17

first step, SCE will require that, as of November 1, 2013, all requests to attach coming through the joint 18

pole committee must be accompanied by pole loading calculations. Requests lacking pole loading 19

calculations will be rejected. SCE also intends to reach consensus on an SED-endorsed pole loading 20

methodology including consensus on standard conductor tension values and wire sizes as well as 21

developing a single, consensus methodology for computing all required safety factors, including 22

bending, vertical, guying, and sidewalk anchor guys (queen post). 23

16 SCE is actively involved in efforts to pursue consensus or a Commission decision resolving differences in interpretation

of G.O. 95 pole loading rules, including resolution of “will not fail” language in Rule 48, and the applicability of “known local conditions” in Rule 31.1 to pole loading. Finally, SCE will seek resolution on whether increased pole loading standards, if adopted, will apply retroactively.

18

II. 1

WORK DESCRIPTIONS, RECORDED COSTS AND TEST YEAR FORECASTS 2

A. Forecast O&M Expenses and Capital Expenditures Summary17 3

The following tables provide SCE’s O&M expense and capital expenditure forecasts that are 4

described and supported in this chapter. 5

Table II-2 Pole Loading Program

Summary of 2015 O&M Forecast (Total Company Constant 2012 $000)

Account Activity 2015566.125 Pole Loading Assessments - Transmission 2,712$ 571.125 Pole Loading Repairs & Related Expense - Transmission 1,578$ 583.125 Pole Loading Assessments - Distribution 23,651$ 593.125 Pole Loading Repairs & Related Expense - Distribution 11,333$

Malibu Settlement Adjustment (537)$

Total O&M Expenses $38,737

Table II-3 Pole Loading Program Capital Expenditures

Summary of 2013-2017 Capital Expenditures Forecast (Total Company Nominal $000)

D e s c rip t io n s 2 0 1 3 2 0 1 4 2 0 1 5 2 0 1 6 2 0 1 7 T o ta lP o le L o ad in g P ro g ram , D is trib u t io n - 3 3 ,9 1 6 2 8 8 ,6 3 6 2 9 5 ,0 9 0 3 0 3 ,0 6 4 9 2 0 ,7 0 6$ M alib u A d ju s tm e n t - - (5 ,1 3 0 ) (5 ,1 3 0 ) (5 ,1 3 0 ) (1 5 ,3 9 0 )$ P o le L o ad in g P ro g ram , T ran s m is s io - 6 ,7 8 9 5 8 ,0 8 0 5 9 ,0 3 2 6 0 ,4 6 9 1 8 4 ,3 7 0$ T ran s fo rm e rs (5 8 0 ) - 1 ,3 7 1 1 1 ,6 6 8 1 1 ,9 2 9 1 2 ,2 5 1 3 7 ,2 2 0$ P re fab (3 9 5 ) - 9 3 1 7 ,9 2 6 8 ,1 0 3 8 ,3 2 2 2 5 ,2 8 1$ J o in t P o le - D is trib u t io n - (2 ,2 3 7 ) (1 9 ,0 3 6 ) (1 9 ,4 6 2 ) (1 9 ,9 8 8 ) (6 0 ,7 2 3 )$ J o in t P o le - T ran s m is s io n - (2 7 4 ) (2 ,3 4 7 ) (2 ,3 8 5 ) (2 ,4 4 3 ) (7 ,4 4 9 )$ W o o d P o le D is p o s a l - 3 1 4 2 ,6 7 4 2 ,7 3 3 2 ,8 0 7 8 ,5 2 8$

T o ta l E x p e n d itu re s - $ 4 0 ,8 1 1 $ 3 4 2 ,4 7 1 $ 3 4 9 ,9 1 0 $ 3 5 9 ,3 5 2 $ 1 ,0 9 2 ,5 4 3 1. Comparison of 2012 GRC Authorized and Recorded 6

The activities represented in this chapter began after the 2012 GRC, are incremental to 7

pole replacements driven by inspections, relocations, claims, and storms, and therefore, no funding was 8

17 See SCE-03, Vol. 1 and SCE-10, Vol. 1, Pt. 2. SCE recommends creation of a Pole Loading Program Balancing

Account (PLPBA) to record the difference between recorded O&M and capital (including joint pole credits) incurred as part of this program and the authorized PLP revenue requirement adopted in this GRC.

19

requested in the 2012 GRC.18 As a result, there are no authorized amounts to compare for these 1

activities. The Commission did authorize $844 thousand in 2012 constant dollars for pole loading 2

assessments. Given the timing of the decision, this was not expended in 2012. Recorded expenses are 3

shown in the following sections. 4

B. O&M Expenses 5

1. Pole Loading Assessment FERC Account 6

The costs of conducting pole loading assessments as described in Section I.E.1.a) above 7

will record to FERC Account 583.125 for distribution poles and FERC Account 566.125 for 8

transmission poles. Assessments will be performed by contractors, and the costs will record as non-9

labor expenses in these accounts. In addition, SCE planning resources dedicated to this program will 10

review the results of assessments and determine the appropriate course of action: repair or replacement. 11

These resources will also integrate PLP work with other potential work proposed in the same area, such 12

as, but not limited to, overhead to underground conversions (Rule 20), systematic rebuild, other 13

infrastructure replacement and 4kV cutovers. The associated expenses will record as labor expenses in 14

these accounts. 15

In addition, labor and non-labor costs associated with the pole loading study required by 16

the 2012 GRC decision described above record to this account. 17

a) Cost Forecasts 18

Labor and non-labor expenses recorded in 2012 are associated with pole loading 19

studies performed prior to the initiation of the pole loading program. Forecast expenses in 2013 include 20

$753,000 in 2009 dollars ($844,000 in 2012 dollars) for the 2012 GRC pole loading study. This 21

statistically valid study provides information about the extent of the pole loading issue, and is used to 22

forecast repair and replacement rates. This study was authorized in D.12-11-051. The forecast 23

expenditures for 2015 are based on the 7-year pole loading assessment plan described in Section I.E.1, 24

which will begin in 2014. The count of pole assessments is derived from the estimated number of poles 25

included in the PLP scope divided by 7. The cost per pole of $111 is based on standard rates offered by 26

contractors and will record as non-labor. These costs have been adjusted for allocated overhead costs 27

18 See SCE-03, Vol. 6, Pt. 1. SCE’s forecast and historical costs for ongoing activities such as intrusive inspections and

pole replacements not related to the Pole Loading Program.

20

based on 2012 recorded allocated cost ratios.19 The forecast for planning and analysis is based on the 1

total number of poles failing assessments and the number of poles an individual planner can triage into 2

repair or replacement categories per day. By 2015, SCE forecasts that it will need 14 planners, which 3

will require $1.8 million in the test year. Table II-4 summarizes the forecast assessment counts and unit 4

costs; Table II-5 and Table II-6 show the distribution and transmission portions of PLP assessment costs 5

separately. This split was calculated based on the ratio of forecast transmission and distribution pole 6

replacements. 7

Table II-4 Total PLP Assessment Counts and Costs, Transmission & Distribution

(Constant 2012 $000) 2014 2015 2016 2017 2018 2019 2020

AssessmentsAssessments Performed 205,754 205,754 205,754 205,754 205,754 205,754 205,754 Cost per Assessment (2012 $) 111$ 111$ 111$ 111$ 111$ 111$ 111$

Assessment Subtotal (2012 $000) 22,839$ 22,839$ 22,839$ 22,839$ 22,839$ 22,839$ 22,839$

Planning & Analysis Cost (2012 $000) 301$ 1,812$ 1,812$ 1,812$ 1,812$ 1,812$ 1,812$

Total Assessment Cost 23,140$ 24,651$ 24,651$ 24,651$ 24,651$ 24,651$ 24,651$

19 See Workpaper entitled “Pole Loading Assessment Costs.”

21

Table II-5 Pole Loading Assessments (Distribution)

Portion of FERC Account 583.125 Recorded and Adjusted 2008-2012/Forecast 2013-2015

(100% CPUC-Jurisdictional Constant 2012 $000)

2008 2009 2010 2011 2012 2013 2014 2015Labor $0 $0 $0 $0 $1,267 $0 $12,682 $13,510Non-Labor $0 $0 $0 $0 $787 $937 $7,912 $8,429 Total $0 $0 $0 $0 $2,054 $937 $20,594 $21,939

Basis of Forecast: See workpaper

Recorded Forecast

Table II-6 Pole Loading Assessments (Transmission)


(Total Company Constant 2012 $000)

2008 2009 2010 2011 2012 2013 2014 2015Labor $0 $0 $0 $0 $0 $0 $1,567 $1,670Non-Labor $0 $0 $0 $0 $0 $0 $978 $1,042 Total $0 $0 $0 $0 $0 $0 $2,545 $2,712

Basis of Forecast: See workpaper

Recorded Forecast

2. Pole Loading Repair Expenses, portion of FERC Accounts 571.125 and 593.125 1

The costs associated with designing and completing repairs identified through pole 2

assessments will record to FERC Account 571.125 for transmission poles and FERC Account 593.125 3

for distribution poles. Poles with non-compliant safety factors will either require repair or replacement 4

as discussed in Section I.E.1.b) above. Poles out of compliance due to a deficiency in a guy wire safety 5

factor will require O&M remediation to repair the guy. Also, about 40 percent of vertical or buckling 6

safety factor failures can be repaired by adding or modifying guy wires. SCE is responsible for guy 7

22

repair at electrical levels only. If guy repairs are required at communication levels (per G.O. 95 Rule 1

18B), the communication companies will be notified and will be responsible for the costs. Accordingly, 2

SCE has not included any costs for repairing communication guy wires in its forecast. SCE will perform 3

repairs of its facilities within 2 years of inspection. 4

a) Cost Forecasts 5

Based on studies conducted to date, 3 percent of the poles assessed for pole 6

loading are expected to need repairs.20 The unit counts are forecast as 3 percent of the number of 7

inspections shown in Table II-7. 8

The cost to plan a repair is forecast at $89 per pole based on standard rates 9

charged by contractors adjusted for allocated costs. The cost to repair each pole of $1,554 is based on 10

historical repair rates for similar work adjusted for allocated costs. The allocated expense rate has been 11

derived from 2012 recorded expenses.21 The cost forecasts for each year have been estimated by 12

multiplying the number of poles expected to require repair by the cost of planning and repairing each 13

pole. Table II-7 summarizes the repair cost forecast for all poles; Table II-8 and Table II-9 show the 14

costs divided between distribution and transmission poles. 15

Table II-7 Pole Loading Repair Costs (Distribution and Transmission) – Detailed Forecast


20 See Workpaper “PLP Pole Loading Study Summary.” 21 See Workpaper “PLP Repair Unit Rate.”

23

Table II-8 Pole Loading Repair Costs (Distribution)



2 0 0 8 2 0 0 9 2 0 1 0 2 0 1 1 2 0 1 2 2 0 1 3 2 0 1 4 2 0 1 5L a b o r $ 0 $ 0 $ 0 $ 0 $ 0 $ 0 $ 1 ,8 9 1 $ 5 ,1 3 2N o n- L a b o r $ 0 $ 0 $ 0 $ 0 $ 0 $ 0 $ 1 ,1 8 0 $ 3 ,2 0 2 T o ta l $ 0 $ 0 $ 0 $ 0 $ 0 $ 0 $ 3 ,0 7 1 $ 8 ,3 3 4M a lib u se ttle m e nt (5 3 7 )$

A d jus te d T o ta l $ 7 ,7 9 7

R a tio o f L a b o r to T o ta l 6 2 % 6 2 %

B a s is o f F o re c a s t: P la nning c o sts + units re p a ire d * (d e s ign/re p a ir unit c o s ts )B a s is o f L a bo r/N o n-L a bo r S plit: L Y R L /N L ra tio fo r p re ve ntive m a inte na nc e

R e c o rd e d F o re c a st

Table II-9 Pole Loading Repair Costs (Transmission)



2008 2009 2010 2011 2012 2013 2014 2015Labor $0 $0 $0 $0 $0 $0 $234 $634Non-Labor $0 $0 $0 $0 $0 $0 $146 $396 Total $0 $0 $0 $0 $0 $0 $380 $1,030

Ratio of Labor to Total 62% 62%

Basis of Forecast: Planning costs + units repaired * (design/repair unit costs)Basis of Labor/Non-Labor Split: LYR L/NL ratio for preventive maintenance

Recorded Forecast

3. Related Expense, portion of FERC Accounts 571.125 and 593.125 1

A portion of the costs recorded in FERC Accounts 571.125 and 593.125 represent 2

expenses incurred for work that must be done when capital additions or replacements are being 3

performed, but do not qualify for capitalization under standard accounting guidelines. 4

24

a) Cost Forecasts 1

The forecast methodology for related expense incurred as a result of PLP capital 2

work is discussed by Ms. Reeves in Exhibit SCE-03, Vol. 10. Table II-10 and Table II-11 show the 3

forecast based on the methodology discussed in that volume. 4

Table II-10 PLP Related Expense – Distribution Portion of FERC Account 593.125

Recorded and Adjusted 2008-2012/Forecast 2013-2015 (100% CPUC-Jurisdictional Constant 2012 $000)

2008 2009 2010 2011 2012 2013 2014 2015Labor $0 $0 $0 $0 $0 $0 $89 $766Non-Labor $0 $0 $0 $0 $0 $0 $260 $2,233 Total $0 $0 $0 $0 $0 $0 $349 $2,999


Basis of Forecast: Historical related expense ratio * forecast capital expenditureBasis of Labor/Non-Labor Split: Historical L/NL ratio for related expense

Recorded Forecast

Table II-11 PLP Related Expense – Transmission



2008 2009 2010 2011 2012 2013 2014 2015Labor $0 $0 $0 $0 $0 $0 $11 $96Non-Labor $0 $0 $0 $0 $0 $0 $53 $452 Total $0 $0 $0 $0 $0 $0 $64 $548


Basis of Forecast: Historical related expense ratio * forecast capital expenditureBasis of Labor/Non-Labor Split: Historical L/NL ratio for related expense

Recorded Forecast

25

4. Joint Pole Organization (JPO) for Pole Loading, portion of FERC Account 583.125 1

As discussed in Exhibit SCE-03, Volume 06, Part 1, the JPO is responsible for the 2

execution and administration of all joint pole agreements where SCE shares the ownership of 3

distribution and transmission poles with other utilities. JPO is also responsible for the execution and 4

administration of agreements to lease pole space to other utilities. JPO also establishes, monitors, and 5

updates joint pole policies and procedures as they related to joint pole use and billings. JPO performs 6

audits on poles to identify safety deficiencies and unauthorized attachments. These expenses are 7

recorded to FERC Account 583.125, (Table II-12). 8

Table II-12 PLP JPO Expense



2008 2009 2010 2011 2012 2013 2014 2015Labor $0 $0 $0 $0 $0 $147 $1,037 $1,546Non-Labor $0 $0 $0 $0 $0 $16 $111 $166 Total $0 $0 $0 $0 $0 $163 $1,148 $1,712

Ratio of Labor to Total 90% 90% 90%

Basis of Forecast: Forecast head countBasis of Labor/Non-Labor Split: Forecast based

Recorded Forecast

a) Cost Forecasts 9

The expenses associated with the current JPO are included in Exhibit SCE-03, 10

Volume 06, Part 1. The expenses here represent the costs associated with 24 additional employees 11

required to support the increased work level of the Pole Loading Program. The Pole Loading Program is 12

anticipated to result in an additional 25,000 pole replacements annually in 2015 – 2017. Each pole 13

replacement requires a JPA to be executed and submitted to the joint owner or owners. The joint owners 14

will either approve the replacement design or suggest changes. Once a design is agreed upon and 15

construction is completed, notice is provided to the joint owner or owners so that they can transfer their 16

equipment. After SCE receives notice that the transfer is complete, invoicing and collection begins. 17

Furthermore, if the Pole Loading Program identifies poles that require a guy repair at the communication 18

26

level, JPO will determine who the affected joint owner is, and provide notification that remediation is 1

needed. 2

SCE will start staffing these additional positions in the second half of 2013. By 3

2014, SCE plans to add 16 employees, with an additional 8 in 2015.22 The labor costs are based on 4

average annual salaries for the planned positions. The non-labor expenses are based on the non-labor to 5

labor ratio for base JPO organization as shown in FERC Account 583.120 in Exhibit SCE-03, Volume 6

06, Part 1. 7

C. Capital Expenditures 8

1. Pole Loading Driven Replacements Capital Expenditures 9

As mentioned above, poles with noncompliant safety factor measurements will require 10

replacement. Due dates for replacement will be assigned based on the severity of the condition and will 11

range from immediate replacement to within 59 months of inspection in accordance with G.O. 95. 12


Based on preliminary results from the 2012 GRC Pole Loading Study, 19 percent 14

of poles assessed for pole loading are expected to require replacement.23 Since the pole loading 15

assessments program will commence in 2014, SCE expects to replace relatively few poles in 2014 based 16

on the typical lead time between assessment and construction. After the completion of a full year of 17

pole loading assessments, SCE expects 25,000 poles to be replaced each year from 2015-2017, which 18

will be a combination of poles that failed assessment in that year and in previous years.24 Table II-13 19

shows the detailed pole replacement forecast, including the number of transmission and distribution 20

poles replaced. 21

The unit cost of a pole replacement is equal to the cost of replacement under the 22

deteriorated pole program. The total costs are estimated by multiplying the pole replacement forecast 23

and the unit cost forecast. This is summarized in Table II-13. 24

22 See Workpaper “JPO costs for Pole Loading.” 23 See Workpaper “PLP Pole Loading Study Summary.” 24 See Workpaper “Pole Loading Replacement Forecast.”

27

Table II-13 Pole Loading Driven Pole Replacements

2013 2014 2015 2016 2017Distribution PLP Replacements

a Poles replaced 0 2,670 22,250 22,250 22,250b1 Cost per pole (2012, $) 12,130 12,130 12,130 12,130 12,130 b2 Cost per pole (nom., $) 12,394 12,703 12,972 13,262 13,621 c=a*b1 Total cost (2012, $000) - 32,387 269,893 269,893 269,893 d=a*b2 Total Cost (nom., $000) - 33,916 288,636 295,090 303,064

Transmission PLP Replacementse Poles replaced 0 330 2,750 2,750 2,750f1 Cost per pole (2012, $) 19,800 19,800 19,800 19,800 19,800 f2 Cost per pole (nom., $) 20,121 20,573 21,120 21,466 21,989 g=e*f1 Total cost (2012, $000) - 6,534 54,450 54,450 54,450 h=e*f2 Total Cost (nom., $000) - 6,789 58,080 59,032 60,469

All PLP Replacementsc+g Total cost (2012, $000) - 38,921 324,343 324,343 324,343 d+h Total Cost (nom., $000) - 40,705 346,716 354,122 363,533

28

Figure II-2 Pole Loading Driven Pole Replacements

WBS Elements CET-PD-IR-DL and CET-PD-IR-TL Recorded 2008-2012/Forecast 2013-2015 Capital Expenditures

(Total Company Nominal and Constant 2012 $000)

2. Pole Loading Program Driven Distribution Transformers 1

Pole replacements under the Pole Loading Program will also result in transformer 2

replacements for a portion of poles. As discussed by Mr. Ferree in Exhibit SCE-03, Volume 05, an 3

inventory of distribution transformers is maintained to facilitate easy access when needed. This section 4

discusses the transformer costs driven by the pole replacements in the pole loading program. 5

a) Cost Forecast 6

On average, one distribution transformer is replaced for every three wood pole 7

replacements. SCE translated the forecast number of pole replacements in this program to a forecast 8

number of transformers that will need to be replaced. SCE then applied the average acquisition lag time 9

to develop the forecast count of transformers that need to be purchased into inventory for 2013-2017. 10

The transformer acquisition costs times the count of transformers per year for 2013-2017 provide the 11

29

total transformer expenditure forecasts. Figure II-3 shows the distribution transformer replacements 1

driven by PLP pole replacements.25 2

Figure II-3 Distribution Transformers, PLP portion

Recorded 2008-2012/Forecast 2013-2017Capital Expenditures (100% CPUC-Jurisdictional Nominal and Constant 2012 $000)

3. Pole Loading Program Driven Prefabrication26 3

As discussed by Mr. Ferree in Exhibit SCE-03, Volume 05, each of SCE’s 35 service 4

centers has a prefabrication operation that is responsible for staging material for the construction crews, 5

assembling prepackaged kits, and properly disposing of materials removed from jobsites. The pole 6

loading program will drive an increase in the costs for this activity. This section presents the 7

prefabrication forecast specifically attributable to pole replacements as part of the Pole Loading 8

Program. 9


The cost forecast methodology, which is discussed by Mr. Ferree in Exhibit SCE-11

03, Volume 05, describes that SCE is using a five-year average of 2.27 percent of the capital costs to 12

25 See Workpaper entitled “PLP Portion of Distribution Transformer Replacements.” 26 WBS Element CET-PD-OT-PF-PL.

30

forecast the prefabrication expenditures associated with the Pole Loading program (Table II-14).27 The 1

capital expenditure forecast in this category was developed by multiplying 2.27 percent by the forecast 2

expenditures for pole replacements and wood pole disposal. Figure II-4 shows the portion of 3

prefabrication expenditures driven by Pole Loading Program pole replacements. 4

Table II-14 Historical Prefabrication Capital Expenditures

(100% CPUC-Jurisdictional Nominal $000) 2008 2009 2010 2011 2012

Prefab-related Distribution Expenditures 725,056 751,177 798,231 832,593 793,492 Prefab District Stores Nominal Recorded 18,323 18,149 16,411 16,583 18,618 Prefab ratio 2.53% 2.42% 2.06% 1.99% 2.35%

5 year average 2.27%

27 See Workpaper entitled “Prefabrication Forecast.”

31

Figure II-4 Prefabrication, PLP portion

WBS Element CET-PD-OT-PF-DL Recorded 2008-2012/Forecast 2013-2017Capital Expenditures (100% CPUC-Jurisdictional Nominal and Constant 2012 $000)

4. Pole Loading Program Driven Joint Pole Credits 1

As discussed in Exhibit SCE-03 Vol. 06, Part 1, joint pole credits represent contributions 2

of joint pole owners for pole replacements. SCE tracks and records the net annual debits and credits 3

between SCE and other participants in accordance with joint pole agreements. 4

a) Cost Forecasts 5

Figure II-5 shows the portion of joint pole credits associated with PLP distribution 6

pole replacements. Figure II-6 shows the portion of joint pole credits associated with PLP transmission 7

pole replacements. As discussed in Exhibit SCE-03, Volume 6, Part 1, the average credit per pole from 8

2008 through 2012 was $765 in constant 2012 dollars. SCE used $800 as the forecast credit per pole 9

replaced. The total forecasts in this category were developed by multiplying the forecast count of pole 10

replacements by $800. 11

32

Figure II-5 Joint Pole Credits – Distribution, PLP portion

WBS Element CET-PD-CR-JD-PL Recorded 2008-2012/Forecast 2013-2017Capital Expenditures (100% CPUC-Jurisdictional Nominal and Constant 2012 $000)

33

Figure II-6 Joint Pole Credits – Transmission – PLP portion

WBS Element CET-PD-CR-JT-PL Recorded 2008-2012/Forecast 2013-2017 Capital Expenditures (100% CPUC-Jurisdictional Nominal and Constant 2012 $000)

5. Pole Loading Program Driven Wood Pole Disposal 1

When wood poles are removed from service, they must be appropriately disposed of to 2

mitigate adverse environmental impact. This section includes the wood pole disposal expenditures 3

driven by the Pole Loading Program. 4

a) Cost Forecasts 5

As discussed in Exhibit SCE-03 Vol. 06, Part 1, SCE utilized the five-year 6

average cost of $101 per pole, rounded to $100 for forecasting purposes, as the basis for the forecast. 7

The forecasts were developed by multiplying the forecast count of pole replacements by $100. Figure 8

II-7 shows the portion of wood pole disposal associated with PLP pole replacements. 9

34

Figure II-7 Wood Pole Disposal, PLP portion

WBS Element CET-PD-OT-WP-PL Recorded 2008-2012/Forecast 2013-2017Capital Expenditures (100% CPUC-Jurisdictional Nominal and Constant 2012 $000)

35

III. 1

O&M ACCOUNT SUMMARIES 2

A. FERC Account 566.125 3

Figure III-8 Summary of FERC Account 566.125

Recorded and Adjusted 2008-2012/Forecast 2013-2015 (Total Company Constant 2012 $000)

2 0 0 8 2 0 0 9 2 0 1 0 2 0 1 1 2 0 1 2 2 0 1 3 2 0 1 4 2 0 1 5T ra ns m is s io n P o le A s s e s s m e nts L a b o r $ 0 $ 0 $ 0 $ 0 $ 0 $ 0 $ 1 ,5 6 7 $ 1 ,6 7 0 N o n -L a b o r $ 0 $ 0 $ 0 $ 0 $ 0 $ 0 $ 9 7 8 $ 1 ,0 4 2 S ub-T o ta l $ 0 $ 0 $ 0 $ 0 $ 0 $ 0 $ 2 ,5 4 5 $ 2 ,7 1 2

T o ta l 5 6 6 .1 2 5 L a b o r $ 0 $ 0 $ 0 $ 0 $ 0 $ 0 $ 1 ,5 6 7 $ 1 ,6 7 0 N o n -L a b o r $ 0 $ 0 $ 0 $ 0 $ 0 $ 0 $ 9 7 8 $ 1 ,0 4 2 T o ta l E x pe ns e s $ 0 $ 0 $ 0 $ 0 $ 0 $ 0 $ 2 ,5 4 5 $ 2 ,7 1 2

R e c o rde d F o re c a s t

$

$500

$1,000

$1,500

$2,000

$2,500

$3,000

36

B. FERC Account 571.125 1


Recorded and Adjusted 2008-2012/Forecast 2013-2015 (Total Company Constant 2012 $000)

2008 2009 2010 2011 2012 2013 2014 2015Transmission Pole Repairs Labor $0 $0 $0 $0 $0 $0 $234 $634 Non-Labor $0 $0 $0 $0 $0 $0 $146 $396 Sub-Total $0 $0 $0 $0 $0 $0 $380 $1,030

Transmission Pole Related Expense Labor $0 $0 $0 $0 $0 $0 $11 $96 Non-Labor $0 $0 $0 $0 $0 $0 $53 $452 Sub-Total $0 $0 $0 $0 $0 $0 $64 $548

Total 583.120 Labor $0 $0 $0 $0 $0 $0 $245 $730 Non-Labor $0 $0 $0 $0 $0 $0 $199 $848 Total Expenses $0 $0 $0 $0 $0 $0 $444 $1,578

Recorded Forecast

$

$500

$1,000

$1,500

$2,000

37

C. FERC Account 583.125 1



2008 2009 2010 2011 2012 2013 2014 2015Distribution Pole Assessments Labor $0 $0 $0 $0 $1,267 $0 $12,682 $13,510 Non-Labor $0 $0 $0 $0 $787 $937 $7,912 $8,429 Sub-Total $0 $0 $0 $0 $2,054 $937 $20,594 $21,939

Joint Pole PLIP Support Labor $0 $0 $0 $0 $0 $147 $1,037 $1,546 Non-Labor $0 $0 $0 $0 $0 $16 $111 $166 Sub-Total $0 $0 $0 $0 $0 $163 $1,148 $1,712

Total 583.120 Labor $0 $0 $0 $0 $1,267 $147 $13,719 $15,056 Non-Labor $0 $0 $0 $0 $787 $953 $8,023 $8,595 Total Expenses $0 $0 $0 $0 $2,054 $1,100 $21,742 $23,651

Recorded Forecast

$

$5,000

$10,000

$15,000

$20,000

$25,000

38

D. FERC Account 593.125 1



2008 2009 2010 2011 2012 2013 2014 2015Distribution Pole Repairs Labor $0 $0 $0 $0 $0 $0 $1,891 $5,132 Non-Labor $0 $0 $0 $0 $0 $0 $1,180 $3,202 Sub-Total $0 $0 $0 $0 $0 $0 $3,071 $8,334

Distribution Pole Related Expense Labor $0 $0 $0 $0 $0 $0 $89 $766 Non-Labor $0 $0 $0 $0 $0 $0 $260 $2,233 Sub-Total $0 $0 $0 $0 $0 $0 $349 $2,999

Malibu Fire Settlement Labor $0 $0 $0 $0 $0 $0 $0 $0 Non-Labor $0 $0 $0 $0 $0 $0 $0 (537)$ Sub-Total $0 $0 $0 $0 $0 $0 $0 (537)$

Total 583.120 Labor $0 $0 $0 $0 $0 $0 $1,980 $5,898 Non-Labor $0 $0 $0 $0 $0 $0 $1,440 $4,898 Total Expenses $0 $0 $0 $0 $0 $0 $3,420 $10,796

Recorded Forecast

$

$2,000

$4,000

$6,000

$8,000

$10,000

$12,000

Appendix A

WITNESS QUALIFICATION

A-1

SOUTHERN CALIFORNIA EDISON COMPANY 1

QUALIFICATIONS AND PREPARED TESTIMONY 2

OF KEN TRAINOR 3

Q. Please state your name and business address for the record. 4

A. My name is Ken Trainor, and my business address is 3 Innovation Way, Pomona, California 5

91768. 6

Q. Briefly describe your present responsibilities at the Southern California Edison Company. 7

A. I am the Director of the Pole Assessment and Remediation (PAR) organization for Southern 8

California Edison Company’s Transmission and Distribution Operating Unit. PAR is 9

responsible for the inspection, assessment and remediation of the over 1.4 million poles in the 10

SCE distribution and transmission grid. 11

Q. Briefly describe your educational and professional background. 12

A. I have a Bachelor of Science Degree in Mechanical Engineering from California State University 13

of Long Beach. I joined Southern California Edison in 1985 and held a variety of Distribution 14

design, engineering, and construction positions before being promoted to Director of Design in 15

2001. I assumed the role of Director of Distribution Construction and Maintenance (DC&M) in 16

2004. I assumed the position of Power Delivery (PWRD), Chief of Staff in 2005. I assumed the 17

position of Director of Substation Construction and Maintenance (SC&M) in 2008 and in March 18

2013, I assumed my present position at Southern California Edison. 19

Q. What is the purpose of your testimony in this proceeding? 20

A. The purpose of my testimony in this proceeding is to sponsor portions of Exhibit SCE-03, 21

Volume 6, Part 1, entitled Transmission and Distribution – Distribution Maintenance, and 22

Exhibit SCE-03, Volume 6, Part 2, entitled Transmission and Distribution - Pole Loading, as 23

identified in the Table of Contents thereto. 24

Q. Was this material prepared by you or under your supervision? 25

A. Yes, it was. 26

Q. Insofar as this material is factual in nature, do you believe it to be correct? 27

A-2

A. Yes, I do. 1

transmission and distribution (t&d) volume 6, part 2 – pole...

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