BEFORE THE PUBLIC UTILITIES COMMISSION

OF THE STATE OF CALIFORNIA

Application of San Diego Gas & Electric Company (U902M) for Authority, Among Other Things, to Increase Rates and Charge for Electric and Gas Service Effective on January 1, 2012 / Application 10-12-005

SIXTH SET OF DATA REQUESTS TO SAN DIEGO GAS & ELECTRIC

BY

THE COALITION OF CALIFORNIA UTILITY EMPLOYEES

The following data requests are submitted to San Diego Gas & Electric Company by the Coalition of California Utility Employees (“CUE”). Please provide your responses, via email, if available, by October 10, 2011 to each of the following people:

Rachael E. Koss
Adams Broadwell Joseph & Cardozo
601 Gateway Blvd., Suite 1000
South San Francisco, CA 94080
(650) 589-1660
/ David Marcus
P.O. Box 1287
Berkeley, CA 94701
(510) 528-0728

Please identify the person who prepared your responses to each data request. If you have any questions concerning the meaning of any data requests, please let us know.

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1. The testimony of Gayatri Schilberg for UCAN discusses SDG&E’s “RAT” and “technical review committee” (see p. 9, fn. 11 and p. 19, fn. 48 of her testimony). Please provide full copies of all meeting notes for the “RAT” and “technical review committee” and indicate the current confidentiality status of those meeting notes.

2. Please provide a count of how many distribution poles SDG&E has, by year of installation (e.g., X poles installed in 1970, Y poles installed in 1971, etc.).

3. The testimony of Gayatri Schilberg for TURN says SDG&E proposes to replace only 1,150 poles per year and reinforce another 600 poles per year.

a. Is this correct? If not, what are the correct numbers?

b. For each of the years 2001-2010, inclusive, please indicate how many poles SDG&E replaced each year, how many it reinforced each year, and how many new poles (that were not replacements) it installed each year.

Dated: September 26, 2011 Respectfully submitted,

/s/ Rachael E. Koss

Marc D. Joseph

Rachael E. Koss

Adams Broadwell Joseph & Cardozo

601 Gateway Boulevard, Suite 1000

South San Francisco, CA 94080

(650) 589-1660 Telephone

(650) 589-5062 Fax

Attorneys for the Coalition of

California Employees

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