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DATE:
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October 11, 2007
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TO:
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Office of Commission Clerk (Cole)
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FROM:
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Division of Competitive Markets and
Enforcement (D. Rich, C.Vinson)
Office of General Counsel (A. Teitzman)
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RE:
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Docket No. 070634-EI – Staff
Proposal to Revise Annual Reporting Requirements for Commission-Ordered Wood
Pole Inspections by Investor-Owned Electric Utilities.
Docket No. 070635-TL –Staff Proposal to Revise Annual
Reporting Requirements for Commission-Ordered Wood Pole Inspections by
Incumbent Local Exchange Telecommunications Carriers.
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AGENDA:
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10/23/07 – Regular Agenda – Proposed Agency Action – Interested Persons May
Participate
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COMMISSIONERS ASSIGNED:
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All
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PREHEARING OFFICER:
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Administrative
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CRITICAL DATES:
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None
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SPECIAL INSTRUCTIONS:
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None
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FILE NAME AND LOCATION:
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S: \psc\CMP\WP\070634-070635.rcm.doc
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Case Background
On February 27, 2006, the Commission issued Order No. PSC-06-0144-PAA-EI in Docket No. 060078-EI, requiring each electric investor-owned utility (IOU)
to implement an eight-year wood pole inspection cycle. Similarly, the
Commission issued Order No. PSC-06-0168-PAA-TL on March 1, 2006, requiring the same in the telecommunications arena for incumbent local exchange carriers (ILECs.)
These orders also required companies to submit annual inspection reports.
Specifically, Order Nos. PSC-06-0144-PAA-EI and
PSC-06-0168-PAA-TL state: “All annual inspection reports, including the 2006
Pole Inspection Report, shall contain the following informational sections:
1. A
review of the methods the company used to determine NESC compliance for
strength and structural integrity of the wood poles included in the previous
year’s annual inspections, taking into account pole loadings, where required;
2. An
explanation of the inspected poles selection criteria, including, among other
things, geographic location and the rationale for including each such selection
criterion;
3. Summary
data and results of the company’s previous year’s wood pole inspections,
addressing the strength, structural integrity, and loading requirements of the
NESC; and
4. The
cause(s) of each pole failure for poles failing inspection, to the extent that
such cause(s) can be discerned in the inspection. Also, the specific actions
the company has taken, or will take, to correct each pole failure.
By March 31, 2007, all companies submitted a first annual
inspection report for the 2006 reporting year.
After a thorough review and compilation of these initial company
reports, staff determined that certain revisions to the required information
could help provide additional clarity to future reports.
To discuss possible revisions, staff facilitated an
informal teleconference with interested parties on September 13, 2007. Commission approval of these suggested changes is needed to amend the standing
orders.
Discussion
of Issues
Issue 1: Should the Commission revise the
annual reporting requirements for the wood pole inspection plan?
Recommendation: Yes. (Rich, Vinson)
Staff Analysis: Five items of information
not previously included in the Commission’s orders have been identified by
staff as necessary to ensure comprehensive pole inspection monitoring.
Additionally, a portion of one of the ordered elements of the annual pole
inspection report was determined by staff to be unnecessary for monitoring the companies’
programs.
Staff’s review of the first annual reports also revealed
that additional information would be beneficial to a fuller understanding of
company inspection programs. The additional information needed for each year
of reporting data consists of:
o
The number of poles failing inspection and designated for
replacement,
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The number of replacements made to date,
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The plan for replacement of the remaining poles that failed
inspection,
o
The projected number of poles to be inspected in the next annual
inspection cycle, and
o
The cumulative number and percentage of poles inspected in the eight-year
cycle.
Staff notes that several of the IOUs and ILECs provided
some, or all, of this additional information in their 2006 activity reports.
Additionally, staff’s review of the first annual reports
led to a conclusion that the portions of Requirement 4, that companies provide to
the Commission “the cause of each failure for poles failing inspection” and
“the specific actions…to correct each pole failure” are unnecessary and
burdensome (emphasis added.) Staff believes this level of detail in the annual
report is unnecessary. Instead, staff proposes that the companies gather and
retain this data for “each pole,” but that the requirement to annually provide
data on each pole be removed. If staff discovers a need for this data, or
aggregated data such as total poles failing due to decay or overload, the
companies could then provide the requested data as a report supplement.
Staff believes modifying future reports in this manner
would allow the Commission to more accurately gauge the status of pole
inspection efforts and progress. This revision would provide staff a clearer,
more comprehensive indication whether companies are on track to complete 100
percent of the required inspection in eight years.
Staff presented these recommended changes in an informal
conference call held on September 13, 2007. The teleconference was formally
noticed and well-attended by the IOUs and ILECs impacted by the proposed changes.
The participants made no objections. Staff recommends the proposed revisions be
approved by the Commission.
Issue 2: Should the reporting format, as
shown in Attachment 1, be adopted as the new standard for reporting companies?
Recommendation: Yes. (Rich, Vinson)
Staff Analysis: The proposed changes in
reporting requirements described in Issue 1 are reflected in Attachment 1. The
proposed additions are shaded. Staff recommends that the proposed template be
adopted as the format for future annual pole inspection reports.
Issue 3: Should this docket be closed?
Recommendation: Yes. (Teitzman)
Staff Analysis:
Analysis of results, annual reporting, and monitoring of plan adherence by
staff can be accomplished without an open docket. Should any issues arise, a
new docket could be intiated at a future date.
