ORA recommends that the Commission specify the forum in which we will review and modify, where appropriate, inspection standards. The utilities propose that we include the new rules in existing General Order (G.O.) 95 and G.O.128 and employ the decision-making process already in place for those General Orders when considering modifications to the rules we adopt today. That decision-making process involves negotiations between members of a committee and modifications by way of Commission resolution.

We decline to employ the existing procedures for changing G.O. 95 and G.O. 128, as the utilities suggest. The Committee process used for G.O. 95 and G.O. 128 is appropriate where rules must apply to all utilities. By contrast, any deviations from inspection standards ought to be tailored to the conditions facing each utility, based on that utility's climate, operating experience, equipment and maintenance data, and other factors, based on cost-effectiveness analysis. We believe a highly public and visible process is required here, considering the introduction of competition and the heightened interest of the public and California legislature in matters relating to distribution system performance. Any proposals to change adopted standards should be based on data and analysis available to all parties.

We intend that this rulemaking be the forum for all such action in the future, as ORA proposes. We will reconsider the standards we adopt here, and related findings regarding maintenance of electric utility distribution systems, on our own motion or the motion of a party if it appears that circumstances have changed or the standards we adopt are inadequate.