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 CITY OF CARMEL-BY-THE-SEA OPENING BRIEF document copy is embedded. CONCLUSION The explosion in Carmel was caused by multiple mistakes and failures to act. PG&E's testimony does not dispute the facts. Instead, the utility stresses its corrective actions it has done. It's too little too late, promises do not negate what happened in Carmel. PG&E's proffered improvements may help to reduce the severity in the fines and hopefully will prevent future incidents, but it does not change the fact that violations of federal and state law occurred on March 3, 2014.
The Mountain View incident should have been a key warning sign. It was a similar situation of welding on steel pipe with an unmapped plastic inserted causing a gas leak. After the Mountain View incident, PG&E internal investigation concluded more work needed to be done in the field to prevent futures incidents from occurring. Yet PG&E did nothing. PG&E's inaction, along with many other layers of weakness in their protocol and records, caused this explosion in Carmel's backyard. PG&E justified its inactions by claiming Mountain View was perceived as an isolated event that caused no major property damage. In other words, PG&E's plan was to also wait until severe property damage or death occurred in order to take corrective action. The law requires more.
Carmel cannot stress enough the serious anxiety this caused the residents of Carmel. This explosion due to shoddy risk analyses and records management has put this community on edge. Carmel's city staff and electric officials have spent hundreds of hours in response to this explosion. Carmel did not want to become involved in PG&E's distribution system problems, but was forced into this proceeding in response to its residents' concerns over their health and safety. Therefore, Carmel asks that the Commission issue the fines and remedies outlined in SED and Carmel's brief. Carmel is hopeful that these fines and penalties will help to prevent future threats to life and limb.
CITY OF CARMEL-BY-THE-SEA OPENING BRIEF
The Mountain View incident should have been a key warning sign. It was a similar situation of welding on steel pipe with an unmapped plastic inserted causing a gas leak. After the Mountain View incident, PG&E internal investigation concluded more work needed to be done in the field to prevent futures incidents from occurring. Yet PG&E did nothing. PG&E's inaction, along with many other layers of weakness in their protocol and records, caused this explosion in Carmel's backyard. PG&E justified its inactions by claiming Mountain View was perceived as an isolated event that caused no major property damage. In other words, PG&E's plan was to also wait until severe property damage or death occurred in order to take corrective action. The law requires more.
Carmel cannot stress enough the serious anxiety this caused the residents of Carmel. This explosion due to shoddy risk analyses and records management has put this community on edge. Carmel's city staff and electric officials have spent hundreds of hours in response to this explosion. Carmel did not want to become involved in PG&E's distribution system problems, but was forced into this proceeding in response to its residents' concerns over their health and safety. Therefore, Carmel asks that the Commission issue the fines and remedies outlined in SED and Carmel's brief. Carmel is hopeful that these fines and penalties will help to prevent future threats to life and limb.
Exhibit
A (excerpts)
CARMEL'S
VIOLATION CALCULATIONS
1.)
Castro Valley-Incident Date: 9/17/201 TOTAL FINES $40.400 million
2.)
Morgan Hill-Incident Date: 6/21/2012 TOTAL
FINES $170.434 million
3.)
Montague Expressway and Great Mall Parkway, Milpitas-Incident Date: 10/10/2012 TOTAL FINES $2.05 million
4.)
Great Mall Parkway, Milpitas-Incident Date: 3/4/2013 TOTAL FINES $127,510 million
5.)
Mountain View-Incident Date: 7/30/2013 TOTAL
FINES $174.746 million
6.) Carmel-Incident Date: 3/3/2014
TOTAL FINES
$136.630 million
TOTAL FOR ALL $651.770 million
CITY OF CARMEL-BY-THE-SEA OPENING BRIEF
Filing Date 02-26-16
CITY OF CARMEL-BY-THE-SEA'S REQUEST FOR OFFICIAL NOTICE IN SUPPORT OF ITS OPENING BRIEF
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