ABSTRACT: Re: BEFORE THE PUBLIC UTILITIES COMMISSION OF THE STATE OF CALIFORNIA Order Instituting Investigation And Order to Show Cause on the Commission’s Own Motion into the Operations and Practices of Pacific Gas and Electric Company with Respect to Facilities Records for its Natural Gas Distribution System Pipelines, the OPENING BRIEF OF THE SAFETY AND ENFORCEMENT DIVISION document copy is embedded. Importantly, Carmel House Explosion: Based on the available evidence, SED recommends that this violation be assessed from the plastic insert manufacturing date of July 17, 1997, until the incident date on March 3, 2014. From July 17, 1997 until December 31, 2011, SED recommends a maximum base fine of $20,000 per PU Code § 2107. From January 1, 2012 until March 3, 2014, SED recommends a maximum base fine of $50,000 per PU Code § 2107. Given the gravity of the explosion, SED recommends compounding the violation weekly, during the subject time period per PU Code § 2108. This results in a fine of $20.73 million. CONCLUSION For the abovementioned reasons, PG&E should be found in violation of the identified code sections, fined $111.926 million, and ordered to commence the identified remedial measures.
OPENING BRIEF OF THE SAFETY AND ENFORCEMENT DIVISION