Comment from Alexanderson, Steve, Central Lincoln

1. Should OSHA adopt MADs that are different from those proposed for voltages of 72.6 kV and higher (YES) and, if so, should it adopt the distances in Draft #9 or #10 of IEEE Standard 516?(NO) 2. Are there methods other than those in Drafts #9 and #10 of IEEE Standard 516 that would be more appropriate in the calculation of MAD for maximum transient overvoltages beyond existing data for rod-to-rod gaps? (YES, NESC 2007) 3. Should MAD for voltages of 72.6 kV and higher be based on the minimum tool insulation distance as is the case in the 2007 NESC? (YES) 4. Should the final rule include separate minimum approach distance tables for air gaps and for tools as is done in Drafts #9 and #10 of IEEE Standard 516? (NO, The added complexity is not needed. In addition, tools of some kind are needed for live line work. The 516 tables are not clear if any tool is considered, or insulated tools only.) Oregon adopts both OSHA and NESC. The existance of two rules will cause confusion and violation. Please keep OSHA consistent with NESC, which apears to be more conservative overall.