This OII (Order Instituting Investigation) must assist to prevent, whenever possible, future leaks and loss of property, as witnessed by Carmel residents on March 3, 2014 when a gas explosion occurred due to PG&E error. The federal National Transportation & Safety Board (NTSB) found in its August 30, 2011 accident report that one of the causes of the deadly 2010 San Bruno blast was PG&E's "deficient and ineffective" gas transmission integrity management program.6 The NTSB report recommended that PG&E "aggressively and diligently" search "all records" relating to its pipeline system, explaining that these records "should be traceable, verifiable, and complete."7
The Presiding Officers' Decision in the OII investigating PG&E's facilities records post-San Bruno concluded that many PG&E pipeline records were lost, misplaced, destroyed, or missing, even though PG&E has a statutory obligation to preserve them.8 The decision also concluded that PG&E knew of its deficiencies in its record management programs as far back as 1984, but failed to adequately respond to the problems.9 The Commission determined that PG&E committed 33 separate violations with respect to its recordkeeping failures, which amounted to 350,189 total days in violation of the law.
Californians would hope that the tragedy of San Bruno would have some semblance of a silver lining as a means to prevent future tragedy. Sadly, over three and-a-half years later, another gas explosion occurred in Carmel due to PG&E recordkeeping lapses. This repetition of error makes Carmel worry whether PG&E's self-proclaimed "substantial efforts to improve the accuracy of its gas distribution asset data"11 has sufficiently minimized risk to protect its customers.
We are fortunate that the home that exploded in Carmel was vacant on the day PG&E's crews performed work on its distribution line. The doubt and fear of Carmel residents regarding the safety of nearby gas lines nonetheless remains. The residents of Castro Valley, Morgan Hill, Milpitas, and Mountain View may have similar doubts and fears in response to the incidents that occur in their towns. Why did these accidents happen, did violations occur, and how can we prevent such accidents in the future? Carmel respectfully asks that it participate in answering these questions. Carmel respectfully submits this statement so that the issues discussed will facilitate in the investigation into these questions.
Prehearing Conference Statement 03-05-15
CITY OF CARMEL-BY-THE-SEA'S PREHEARING CONFERENCE STATEMENT