of the proceeding. The scope of Phase 1 is as follows: (1) Whether any of the Threshold Issues serves as a bar to recovery; and (2) Whether operation, SDG&E’s engineering and management the facilities alleged to have been involved in the ignition of the fires was reasonable. Each of the three fires should be addressed separately. Scoping memo, p. 6 4. Foreseeability - UCAN SDG&E has been providing Verified argued that Santa Ana wind electric service to San Diego conditions are a known local County residents for over a condition and SDG&E was on century. Their managers should be notice that fires ignited by very familiar with how Santa Ana electrical equipment, in strong wind events, which occur every Santa Ana wind conditions, year, could down power lines and could have devastating ignite wildfires. In a Commission impacts. proceeding involving the 2003 Cedar fire that devastated San SDG&E should have been on Diego County, SDG&E sought notice from prior wildfires in recovery for costs incurred in its service territory (i.e., the restoring their system in the fires’ 2003 Cedar fire) that they can aftermath. Even though SDG&E’s lead to catastrophic damage. equipment was not involved in the ignition of the 2003 Cedar wildfire, SDG&E was put on UCAN argued that SDG&E notice years prior to the wildfires failed to prudently manage at issue in this proceeding that their facilities connected to the ignited wildfires 2007 wildfires and that cost recovery should be denied. UCAN opening brief, p. 3 MGRA, UCAN and “Henricks, POC assert that the fact that SDG&E had prior experience with D.17-11-033, p.25 catastrophic fires, renders SDG&E imprudent when SDG&E failed to adequately address the faults on TL 637.100
of the proceeding. The scope of Phase 1 is as follows: (1) Whether any of the Threshold Issues serves as a bar to recovery; and (2) Whether SDG&E’s operation, engineering and management the facilities alleged to have been involved in the ignition of the fires was reasonable. Each of the three fires should be addressed separately. Scoping memo, p. 6 4. Foreseeability - UCAN argued that Santa Ana wind conditions are a known local condition and SDG&E was on notice that fires ignited by electrical equipment, in strong Santa Ana wind conditions, could have devastating impacts. SDG&E should have been on notice from prior wildfires in its service territory (i.e., the 2003 Cedar fire) that they can lead to catastrophic damage. UCAN argued that SDG&E failed to prudently manage their facilities connected to the 2007 wildfires and that cost recovery should be denied. SDG&E has been providing electric service to San Diego County residents for over a century. Their managers should be very familiar with how Santa Ana wind events, which occur every year, could down power lines and ignite wildfires. In a Commission proceeding involving the 2003 Cedar fire that devastated San Diego County, SDG&E sought recovery for costs incurred in restoring their system in the fires’ aftermath. Even though SDG&E’s equipment was not involved in the ignition of the 2003 Cedar wildfire, SDG&E was put on notice years prior to the wildfires at issue in this proceeding that ignited wildfires UCAN opening brief, p. 3 “Henricks, MGRA, UCAN and POC assert that the fact that SDG&E had prior experience with catastrophic fires, renders SDG&E imprudent when SDG&E failed to adequately address the faults on TL 637.100 Verified D.17-11-033, p.25
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