Phase Two of the SMAP to develop a steps” methodology. In the “next shortterm, utilities believe a more modest approach is in order: focus on comparable risks and risk tolerances, rather than comparable risk scores; limit SMAP/RAMP proceeding to those risks that may have a severe impact (fatalities or life-threatening injuries), and work with utilities and other stakeholders to develop risk tolerances over time. Utilities generally support pilots, they do not think that timeconsuming runs” are necessary to prove the value of a “test proposed methodology as suggested by other parties. Pace of Change CUE agrees with the IOU’s approach as described above. It emphasizes that Commission should focus Phase Two of this proceeding on collecting “the better data, and refining and improving the utilities’ models.” It agrees with the SED Staff Report that is the time to identify the most effective features “now from the risk models for possible adoption in the next SMap or Phase Two” [of this SMAP]. ORA suggests a fiveyear timeline (or the third SMAP cycle) to come to a common methodology that is shared by all utilities. UCAN that the “suggests time frame ORA proposes (up to 5 years) for implementing a common and more quantitative methodology is unnecessarily too long.” Similarly, MGRA believes that is not a sufficiently aggressive goal, “this and that by adopting a time line important decisions that should be addressed soon may be deferred.” a timeline would only be acceptable if it were “Such accompanied by very specific intermediate milestones for achieving all required
Phase Two of the SMAP to develop a “next steps” methodology. In the shortterm, utilities believe a more modest approach is in order: focus on comparable risks and risk tolerances, rather than comparable risk scores; limit SMAP/RAMP proceeding to those risks that may have a severe impact (fatalities or life-threatening injuries), and work with utilities and other stakeholders to develop risk tolerances over time. Utilities generally support pilots, they do not think that timeconsuming “test runs” are necessary to prove the value of a proposed methodology as suggested by other parties. Pace of Change CUE agrees with the IOU’s approach as described above. It emphasizes that “the Commission should focus Phase Two of this proceeding on collecting better data, and refining and improving the utilities’ models.” It agrees with the SED Staff Report that “now is the time to identify the most effective features from the risk models for possible adoption in the next SMap or Phase Two” [of this SMAP]. ORA suggests a fiveyear timeline (or the third SMAP cycle) to come to a common methodology that is shared by all utilities. UCAN “suggests that the time frame ORA proposes (up to 5 years) for implementing a common and more quantitative methodology is unnecessarily too long.” Similarly, MGRA believes that “this is not a sufficiently aggressive goal, and that by adopting a time line important decisions that should be addressed soon may be deferred.” “Such a timeline would only be acceptable if it were accompanied by very specific intermediate milestones for achieving all required