Q1:  In the draft Standards, CPS Energy proposes four (4) different Permit Application processes, each designed to best meet the business needs of a diverse set of Attaching Entities.  Do you agree with the eligibility thresholds for each process?  If no, what would you recommend and why?

Q2:  Safety is a core value of CPS Energy.  CPS Energy and each Attaching Entity have a duty and obligation to keep their facilities safe for their employees and the general public.  The draft Standards propose a Safety Violation Fee as part of CPS Energy’s efforts to address and work to eliminate violations of the Applicable Engineering Standards which may pose a danger to the public.  CPS Energy seeks comments on the appropriate amount of the Safety Violation Fee to encourage Attaching Entities to self-identify and remedy any potential Safety Violations on their own Attachments and/or Overlashings.

Q3:  The Standards introduce a One-Touch Transfer Process limited to the Simple Transfer of Attachments, and a separate process for Complex Transfers which addresses the relocation of Attachments that require the splicing or cutting of the Attachment.  CPS Energy seeks comments on the escalation process for Complex Transfers applicable to Attaching Entities that fail to relocate their own lines in a timely basis.

Q4:  The One-Touch Transfer Process in the Standards requires that only contractors certified by CPS Energy to perform communications work be permitted to do Simple Transfers.  CPS Energy seeks comments on the specific qualifications to consider in developing the certification criteria in order to ensure qualified contractors are used to undertake and complete Simple Transfers on behalf of the Attaching Entities.  CPS Energy also welcomes recommendations of communication contractors in the San Antonio area to consider for certification.

Q5:  The draft Standards contemplate the use the National Joint Utilities Notification System (NJUNS) as a notification system to track Pole Attachment activities.  NJUNS provides for a universal, independent, and documentation-based process management system for Pole Attachment transfer notifications.  Do you support the use of NJUNS for this purpose?  If no, please recommend another industry standard notification system that CPS Energy may adopt.  

Q6:  The Standards provide for a series of timelines for either action and/or response on the part of both CPS Energy and an Attaching Entity in the Pole Attachment Application process.  In the development of the various timelines, CPS Energy strived to balance the business needs of both CPS Energy and Attaching Entities.  CPS Energy seeks comments as to the appropriate duration of the timeframes proposed in the Standards.  

Q7:  In the development of the Standards, CPS Energy strived to develop a process that is fair, equitable, and non-discriminatory regarding the instance of multiple Attaching Entities seeking access to the same Pole.  Do you agree with approach adopted in the draft Standards?  If no, please describe the methodology you would support that meets the fair, equitable, and non-discriminatory treatment of competing Attaching Entities seeking access to the same Pole.

Q8:  In considering the overall Pole Attachment program, CPS Energy seeks comments as to any perceived burdens imposed on small Attaching Entities.  Please be specific in your response. 

Q9:  Please provide any comments you may have that may improve the draft Pole Attachment Agreement.

Q10:  Please provide any additional comments you may have regarding the draft Standards.