Proceeding Number I.14-11-008 OPENING BRIEF OF THE UTILITY REFORM NETWORK

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 UTILITY REFORM NETWORK document copy is embedded. CONCLUSION For the reasons set forth above, TURN urges the Commission to adopt each of the recommendations set forth in TURN’s Summary of Recommendations in Appendix A.

Appendix A

TURN’s SUMMARY OF RECOMMENDATIONS

1. The Commission should extend to gas distribution recordkeeping each of the 21 transmission recordkeeping remedies adopted by the Commission in D.15-04-024. 24
2. The Commission should order PG&E to undertake proactive and systematic efforts to identify and correct in its maps and records all unmapped or inaccurately mapped records of plastic inserts in its distribution system and order this work to be completed within three years.
3. The Commission should order PG&E to undertake proactive and systematic efforts to identify and correct in its maps and records all unmapped or inaccurately mapped stubs in its distribution system and order this work to be completed within three years.
4. The Commission should order PG&E to take the necessary steps to establish MAOP in compliance with applicable law and, within 90 days, to submit a compliance plan for Commission approval, via a Tier 3 advice letter.
5. The Commission should order that costs incurred by PG&E related to any remedies ordered in the proceeding be paid by PG&E’s shareholders and not be recovered from ratepayers.
24 These remedies appear in Appendix E to D.15-4-024, pages 7-11 under the heading “Adopted Remedies Proposed by CPSD in I.11-02-016 (Recordkeeping OII)”.
NOTE: maximum allowable operating pressure (“MAOP”)

Opening Brief of the Utility Reform Network 2-26-16

Filing Date 2-26-16

OPENING BRIEF OF THE UTILITY REFORM NETWORK

Investigation 11-11-009 CPUC 4-09-15

Date of Issuance April 9, 2015

DECISION ON FINES AND REMEDIES TO BE IMPOSED ON PACIFIC GAS AND ELECTRICCOMPANY FOR SPECIFIC VIOLATIONS IN CONNECTION WITH THE OPERATION AND PRACTICES OFITS NATURAL GAS TRANSMISSION SYSTEM PIPELINES