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INTERCONNECTION FACILITIES STUDY AGREEMENT,ATTACHMENT C LODI ENERGY CENTER permit from the CPUC on facilities over 200 kV provided the planned facilities involve the replacement of existing facilities or supporting structures with equivalent facilities or structures, the minor relocation of existing facilities, the conversion of existing facilities to underground or the placing of new or additional conductors, insulators, or their accessories on or replacement of structures already built. These exemptions do not apply under certain circumstances when significant environmental impacts may be caused by the work. If the project does not qualify for an exemption, PG&E will need to seek formal approval from the CPUC (i.e., Certificate of Public Convenience and Necessity) taking as much as 18 months or more since the CPUC may decide to conduct its own environmental evaluation (i.e., Negative Declaration or Environmental Impact Report). For cases where PG&E can claim a valid exemption, PG&E would file an Advice Letter with the CPUC and publish public notice of the proposed construction of the facilities. The noticing process takes about 90 days if no protests are filed, but should be done as early as possible so that a protest does not delay construction. PG&E has no control over the time it takes the CPUC to respond when issues arise. If the protest is granted, PG&E will then need to apply for a formal permit to construct the project (i.e., Certificate of Public Convenience and Necessity). Facilities built or modified under this procedure must also be designed to include electric and magnetic field (EMF) mitigation measures pursuant to PG&E. "EMF Design Guidelines of New Electrical Facilities: Transmission, Substation and Distribution". Please see Section III, B.1(f) in General Order 131-D. This document can be found in the CPUC's web page at: http://www.cpuc.ca.gov/PUBLISHED/GENERAL ORDER/589.htm 11.2 CPUC Section 851 Pacific Gas and Electric Company(PG&E) is subject to the jurisdiction of the California Public Utilities Commission (CPUC) and must comply with Public Utilities Code Section 851,which among other things requires CPUC approval of leases and licenses to use PG&E property. This includes rights-of-way granted to third parties for interconnection facilities. Obtaining CPUC approval for a Section 851 application can take several months, and requires compliance with the California Environmental Quality Act (CEQA). PG&E recommends that Section 851 issues be identified as early as possible so that the necessary application can be prepared and processed. 12