Pg&e's Initial Compliance Plan 12-16-16

BEFORE THE PUBLIC UTILITIES COMMISSION
OF THE STATE OF CALIFORNIA

Order Instituting Investigation And Order to
Show Cause on the Commissions 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.
I.14-11-008
(Filed November 20, 2014)
PACIFIC GAS AND ELECTRIC COMPANYS

INITIAL COMPLIANCE PLAN
LISE H. JORDAN
ELIZABETH COLLIER
Law Department
Pacific Gas and Electric Company
77 Beale Street
San Francisco, CA 94105
Telephone: (415) 973-6965
Facsimile: (415) 973-0516
Email: lhj2@pge.com
Email: eacp@pge.com
MARIE L. FIALA
JOSHUA HILL
Sidley Austin LLP
555 California Street
Telephone: (415) 772-1200
Facsimile: (415) 772-2400
Email: mfiala@sidley.com
Email: jhill@sidley.com
Attorneys for
PACIFIC GAS AND ELECTRIC COMPANY
Dated: December 16, 2016
FILED
12-16-16
04:59 PM

Order Instituting Investigation And Order to
Show Cause on the Commissions 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.
I.14-11-008
PACIFIC GAS AND ELECTRIC COMPANYS

INITIAL COMPLIANCE PLAN
Pacific Gas and Electric Company (PG&E) hereby submits its Initial Compliance Plan
in accordance with D.16-08-020, Decision Regarding Investigation of Pacific Gas and Electric
Companys Gas Distribution Facilities Records, Ordering Paragraph 2.
PG&Es submission is organized as follows:
Appendix A PG&Es Initial Compliance Plan (Plan).
Appendix B, PG&Es Summary of the Meet-And-Confer Process and Efforts Undertaken
regarding the Plan.
Appendix C, Comments of Safety and Enforcement Division (SED) on the Plan.
Appendix D, Comments of Office of Ratepayer Advocates (ORA) on the Plan.
Appendix E, Comments of The Utility Reform Network (TURN) on the Plan.
Appendix F, Comments of PG&E on the Plan and Different and Additional Remedies
Proposed by SED, ORA, and TURN.
-1-
This Initial Compliance Plan, together with all Appendices, is being served on the service
list for this proceeding via Notice of Availability filed concurrently herewith.
Respectfully submitted,
/s/ Elizabeth Collier

LISE H. JORDAN
ELIZABETH COLLIER
Law Department
77 Beale Street
Telephone: (415) 973-6965
Facsimile: (415) 973-0516
Email: lhj2@pge.com
Email: eacp@pge.com
Attorneys for
Dated: December 16, 2016
-2-

APPENDIX A
PG&ES INITIAL COMPLIANCE PLAN (PLAN)
Appendix A
PG&Es Initial Compliance Plan
The following compliance plan was prepared by PG&E pursuant to D.16-08-020, dated August 18, 2016,
in the Order Instituting Investigation and Order to Show Cause on the Commissions 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, Investigation 14-11-008.
PG&Es Compliance Plan was developed following Ordering Paragraph 2 of D.16-08-020, requiring that
PG&E . . . convene, support, and report on a meet and confer process to consider and develop
additional measures necessary to address the issues identified in todays decision. PG&E began the
development of the plan with a review of the Gas Transmission Recordkeeping remedies contained in
Exhibit E of D.15-04-024 (the San Bruno Penalty Decision) to evaluate if they should be adopted for gas
distribution, or if more or different requirements were needed for the gas distribution system. PG&E
first evaluated the remedies to determine those that were applicable to the gas distribution system.
PG&E then compared the remedies applicable to the gas distribution system to the issues raised in the
Decision, both systemic and non-systemic. PG&E specifically looked for remedies that addressed causal
analysis, unmapped plastic inserts, missing paper A-forms, maps that match field conditions, mapping of
stubs, stub removal, and meeting with city officials. PG&E identified twelve remedies out of the 79 gas
transmission recordkeeping remedies that were relevant to gas distribution and specifically relevant to
the issues raised in the Decision. Some of those twelve remedies are being implemented across PG&Es
gas distribution system and are applicable to both gas transmission and distribution. An example of a
remedy implemented systemwide and adopted in this compliance plan is Remedy 1, which specifies that
PG&E will achieve a Level 3 information maturity score under Generally Accepted Records Keeping
Principles. During the Meet and Confer process, parties recommended that PG&E adopt additional
remedies from D.15-04-024. PG&E agreed to adopt an additional four remedies from D. 15-04-024 as
part of the meet-and-confer process.
In addition to reviewing the remedies documented in D.15-04-024, PG&E reviewed the remedies
proposed by parties to this proceeding prior to the final decision. PG&E adopted those remedies to the
extent that they were feasible, cost effective, and addressed an issue raised in the proceeding. Of the
remedies proposed by parties prior to issuance of the final Decision, PG&E identified six remedies that
met the criteria. PG&E added those remedies to its compliance plan. Finally, PG&E reviewed the issues
identified in the Decision independent from any proposed remedy and developed two additional
remedies for the plan.
As a result of the Meet and Confer PG&E agreed to 7 remedies proposed by parties, which are reflected
in four remedies contained in PG&Es initial compliance plan, 18 remedies stemming from the Gas
Transmission Recordkeeping OII, and created two additional remedies to address the decisions directive
to PG&E to identify what more PG&E could do to improve gas distribution records.
A-1
I.14-11-008
GAS DISTRIBUTION RECORD-KEEPING OII
DECEMBER 2016
Remedy 1
A.
REFERENCE
I.12-01-007; I.11-02-016; I.11-11-009, COMPLIANCE PLAN (D.15-04-024), JUNE 8, 2015 Record Keeping OII #1
B.
REMEDY
PG&Es gas distribution organization shall achieve at least a Level 3 information maturity
1
score under the Generally Accepted Records Keeping Principles within 3 years.
C.
REMEDY TERMS
DEFINED
The Generally Accepted Records Keeping Principles (GARP) developed by ARMA

International set forth the characteristics of an effective records and information
management program. ARMAs five scale Information Governance Maturity Model
(IGMM) measures the maturity of a RIM program relative to the eight principles.
D.
STATUS
(OPEN/CLOSED)
DATE OF CLOSURE
PG&E has adopted this Gas Transmission Records remedy in its entirety for Gas
Distribution. See PG&Es compliance plan activities for D.15-04-024 for status.
E.
COMPLIANCE
ACTION AND
SCHEDULE
See PG&Es compliance plan activities for D.15-04-024
F.
SUPPORTING
DOCUMENTATION
OF COMPLIANCE
G.
REMEDIES THAT
HAVE BEEN
ORDERED
ELSEWHERE
(INCLUDE SOURCE
AND PROGRESS TO
DATE)
H.
REMEDIES THAT
MODIFY OR
ELIMINATE
REMEDIES ORDERED
ELSEWHERE
(INCLUDE SOURCE)
I.
GAS DISTRIBUTION
RECORD-KEEPING
DECISION ISSUES
ADDRESSED BY THIS
REMEDY
Missing records; Maps in GD GIS that do not match field conditions
As included in the Gas Transmission Remedy, 3 years concludes in April 2018.
A-2
I.14-11-008
DECEMBER 2016
Remedy 2
A.
REFERENCE
I.12-01-007; I.11-02-016; I.11-11-009, COMPLIANCE PLAN (D.15-04-024), JUNE 8, 2015 Record Keeping OII #3a, b, c
B.
REMEDY
PG&E shall issue a corporate policy and standard that will:

(a) Communicate recordkeeping expectations that underlie its post-2010 Corporate
Records and Information Management Policy and Standard for all departments
and divisions across PG&E. These expectations shall be incorporated into
procedures specific to meet the needs of every Line of Business.
(b) The Information Management Compliance Department shall design a governance
controls catalog for recordkeeping practices to assess compliance with the
corporate policy and standard, consistency of behavior with official records being
stored in approved systems of record, and timeliness of addressing records during
their lifecycle.
(c) The retention schedule will support the policy by providing retention length for all
identified official records to meet legal and regulatory mandates.
C.
REMEDY TERMS
DEFINED
Information Management (IM) Compliance Department was reorganized as the Enterprise

Records and Information Management (ERIM) organization.
D.
STATUS
(OPEN/CLOSED)
DATE OF CLOSURE
COMPLIANCE
ACTION AND
SCHEDULE
SUPPORTING
DOCUMENTATION
OF COMPLIANCE
G.
REMEDIES THAT
HAVE BEEN
ORDERED
ELSEWHERE
(INCLUDE SOURCE
AND PROGRESS TO
DATE)
H.
REMEDIES THAT
MODIFY OR
ELIMINATE
REMEDIES ORDERED
ELSEWHERE
(INCLUDE SOURCE)
I.
GAS DISTRIBUTION
RECORD-KEEPING
DECISION ISSUES
ADDRESSED BY THIS
REMEDY
E.
F.
See PG&Es compliance plan activities for D.15-04-024. See also Attachment A-1 to
Appendix A.
Missing records
A-3
I.14-11-008
DECEMBER 2016
Remedy 3
A.
REFERENCE
B.
REMEDY
PG&E shall develop and implement an education and training program for the gas
distribution organization in Records and Information Management principles and
practices within an information governance framework. The education and training
program shall include the following:
4.a All staff shall receive training to understand the responsibilities and tasks that relate
to managing records. These education and training programs shall be updated and
offered at regular intervals, at least twice annually, to include amendments to the
records management program and for the benefit of new staff.
4.b There shall be specific and additional training for those staff (Gas Operations RIM
Coordinators) involved directly in the management of retention and disposal of
records. These education and training programs shall be offered at least annually.
4.c There shall be specific and additional training focusing on all of the recordkeeping
systems used within the Gas Operations Organization. Employees and PG&E
contractors who have duties using these programs shall be required to attend these
training sessions. These education and training programs shall be offered at least
annually.
C.
REMEDY TERMS
DEFINED
PG&E defines all staff to include employees who are within the Gas Operations Line of
Business.
PG&E defines staff involved in the management of retention and disposition of records to
be the Gas Operations Records and Information Management (RIM) organization
employees and field Gas Operations RIM Coordinators.
PG&E defines recordkeeping systems as electronic systems that store gas distribution
records including GIS, SAP and applicable electronic content management systems.
Records are defined in accordance with TD-4016S Gas Operations Records and
Information Management.
D.
STATUS
(OPEN/CLOSED)
DATE OF CLOSURE
E.
COMPLIANCE
ACTION AND
SCHEDULE
F.
SUPPORTING
DOCUMENTATION
OF COMPLIANCE
G.
REMEDIES THAT
HAVE BEEN
ORDERED
ELSEWHERE
(INCLUDE SOURCE
AND PROGRESS TO
DATE)
A-4
I.14-11-008
DECEMBER 2016
(CONTINUED)
Remedy 3
H.
REMEDIES THAT
MODIFY OR
ELIMINATE
REMEDIES ORDERED
ELSEWHERE
(INCLUDE SOURCE)
I.
GAS DISTRIBUTION
RECORD-KEEPING
DECISION ISSUES
ADDRESSED BY THIS
REMEDY
Missing records
A-5
I.14-11-008
DECEMBER 2016
Remedy 4
A.
REFERENCE
I.12-01-007; I.11-02-016; I.11-11-009, COMPLIANCE PLAN (D.15-04-024), JUNE 8, 2015 Record Keeping Oll #5
B.
REMEDY
PG&E shall develop and deploy the systems necessary to manage, maintain, access and
preserve records (physical and electronic, in all formats and media types); their related
data, metadata, and geographic location and geospatial content to the extent appropriate
in accordance with legal and business mandated rules, utilizing technology that includes
appropriate aids to help improve data and metadata quality.
C.
REMEDY TERMS
DEFINED
PG&E defines systems as electronic systems that store gas distribution records including
GIS, SAP and applicable electronic content management systems. Records are defined in
accordance with TD-4016S Gas Operations Records and Information Management.
PG&E defines records subject to this compliance plan consistent with the records
definition used in I.14-11-008: Plat maps in GD GIS, A forms, Gas Service Records, and gas
main as-builts.
D.
STATUS
(OPEN/CLOSED)
DATE OF CLOSURE
Closed: August 24, 2015.
E.
COMPLIANCE
ACTION AND
SCHEDULE
Gas Distribution Geographic Information System is the foundational system that

provides accessibility of the gas distribution system asset information. See Record
Keeping OII #14 for complete definition of job file.
In addition, PG&E transitioned the leak management process from IGIS to SAP for
distribution leak repair.
F.
SUPPORTING
DOCUMENTATION
OF COMPLIANCE
PG&E reported in I.14-11-008 Chapter 2 testimony on its GD GIS system conversion

completion as of August 24, 2015. See, p. 2-11 lines 30 33.
PG&E testified in in I.14-11-008 Chapter 6 testimony that its leak data is entered into SAP.
See p. 6-6, lines 28-32.
G.
REMEDIES THAT
HAVE BEEN
ORDERED
ELSEWHERE
(INCLUDE SOURCE
AND PROGRESS TO
DATE)
None
H.
REMEDIES THAT
None
MODIFY OR
ELIMINATE
REMEDIES ORDERED
ELSEWHERE
(INCLUDE SOURCE)
I.
GAS DISTRIBUTION
RECORD-KEEPING
DECISION ISSUES
ADDRESSED BY THIS
REMEDY
Missing records
A-6
I.14-11-008
DECEMBER 2016
Remedy 5
A.
REFERENCE
B.
REMEDY
PG&E shall establish accountability for development and implementation of a PG&E

governance strategy across gas distribution that shall rest with PG&E Senior Management
and a method of accountability shall be developed and implemented.
C.
REMEDY TERMS
DEFINED
PG&E defines senior management to be director and above.

PG&E defines governance strategy to apply to records and information governance
strategy.
D.
STATUS
(OPEN/CLOSED)
DATE OF CLOSURE
COMPLIANCE
ACTION AND
SCHEDULE
F.
SUPPORTING
DOCUMENTATION
OF COMPLIANCE
G.
REMEDIES THAT
HAVE BEEN
ORDERED
ELSEWHERE
(INCLUDE SOURCE
AND PROGRESS TO
DATE)
H.
REMEDIES THAT
MODIFY OR
ELIMINATE
REMEDIES
ORDERED
ELSEWHERE
(INCLUDE
SOURCE)
GAS
DISTRIBUTION
E.
I.
Missing records
RECORD-KEEPING
DECISION ISSUES
ADDRESSED BY THIS
REMEDY
A-7
I.14-11-008
DECEMBER 2016
Remedy 6
A.
REFERENCE
B.
REMEDY
PG&E shall identify and document the employees responsible for implementing the
Records and Information Management program for gas operations.
C.
REMEDY TERMS
DEFINED
PG&E defines implementation of the Gas Operations Records and Information

Management program to be the responsibility of all Gas Operations employees.
PG&E further defines the group primarily responsible for developing and providing
oversight of the overall governance structure for gas distribution to be the Gas
Operations Records and Information Management (RIM) team.
D.
STATUS
(OPEN/CLOSED)
DATE OF CLOSURE
COMPLIANCE
ACTION AND
SCHEDULE
F.
SUPPORTING
DOCUMENTATION
OF COMPLIANCE
G.
REMEDIES THAT
HAVE BEEN
ORDERED
ELSEWHERE
(INCLUDE SOURCE
AND PROGRESS TO
DATE)
H.
REMEDIES THAT
MODIFY OR
ELIMINATE
REMEDIES
ORDERED
ELSEWHERE
(INCLUDE
SOURCE)
GAS
DISTRIBUTION
E.
I.
Missing records
RECORD-KEEPING
DECISION ISSUES
ADDRESSED BY THIS
REMEDY
A-8
I.14-11-008
DECEMBER 2016
Remedy 7
A.
REFERENCE
B.
REMEDY
PG&E shall develop consistent standard practices that include gas distribution records
management linked to corporate polices on information governance.
C.
REMEDY TERMS
DEFINED
Standard practices is defined as policies, standards, and procedures
D.
STATUS
(OPEN/CLOSED)
DATE OF CLOSURE
E.
COMPLIANCE
ACTION AND
SCHEDULE
F.
SUPPORTING
DOCUMENTATION
OF COMPLIANCE
G.
REMEDIES THAT
HAVE BEEN
ORDERED
ELSEWHERE
(INCLUDE SOURCE
AND PROGRESS TO
DATE)
H.
REMEDIES THAT
MODIFY OR
ELIMINATE
REMEDIES ORDERED
ELSEWHERE
(INCLUDE SOURCE)
I.
GAS DISTRIBUTION
RECORD-KEEPING
DECISION ISSUES
ADDRESSED BY THIS
REMEDY
Missing records
A-9
I.14-11-008
DECEMBER 2016
Remedy 8
A.
REFERENCE
B.
REMEDY
PG&E shall implement mandated retention periods for all records relevant to gas
distribution.
C.
REMEDY TERMS
DEFINED
PG&E defines the mandated retention periods for records relevant to gas distribution
through its Gas Operations Records Retention Schedule (RRS).
D.
STATUS
(OPEN/CLOSED)
DATE OF CLOSURE
Expected Completion Date: 12/30/2016
E.
COMPLIANCE
ACTION AND
SCHEDULE
F.
SUPPORTING
DOCUMENTATION
OF COMPLIANCE
G.
REMEDIES THAT
HAVE BEEN
ORDERED
ELSEWHERE
(INCLUDE SOURCE
AND PROGRESS TO
DATE)
H.
REMEDIES THAT
MODIFY OR
ELIMINATE
REMEDIES ORDERED
ELSEWHERE
(INCLUDE SOURCE)
I.
GAS DISTRIBUTION
RECORD-KEEPING
DECISION ISSUES
ADDRESSED BY THIS
REMEDY
Missing records
A-10
I.14-11-008
DECEMBER 2016
Remedy 9
A.
REFERENCE
B.
REMEDY
PG&E shall ensure that each gas distribution standard conforms with Records and
Information Management (RIM) policies for gas distribution.
C.
REMEDY TERMS
DEFINED
PG&E defines conform to mean consistent with TD-4016S Gas Operations Records and
Information Management Standard.
D.
STATUS
(OPEN/CLOSED)
DATE OF CLOSURE
E.
COMPLIANCE
ACTION AND
SCHEDULE
PG&E will review its gas distribution standards and procedures and revise any Gas Ops
RIM requirement from the respective standard or procedure that is inconsistent with
TD-4016S, 4016S Gas Operations Records and Information Management Standard, and
the Gas Operations Records Retention Schedule.
F.
SUPPORTING
DOCUMENTATION
OF COMPLIANCE
List of gas distribution standards and procedures updated to conform withTD-4016S will
be provided to SED at the completion of the steps outlined in the Compliance Action and
Schedule section above.
G.
REMEDIES THAT
HAVE BEEN
ORDERED
ELSEWHERE
(INCLUDE SOURCE
AND PROGRESS TO
DATE)
None
H.
REMEDIES THAT
MODIFY OR
ELIMINATE
REMEDIES ORDERED
ELSEWHERE
(INCLUDE SOURCE)
None
I.
GAS DISTRIBUTION
RECORD-KEEPING
DECISION ISSUES
ADDRESSED BY THIS
REMEDY
Missing records
A-11
I.14-11-008
DECEMBER 2016
Remedy 10
A.
REFERENCE
B.
REMEDY
PG&E shall include the treatment of active and inactive records in its Records and
Information Management (RIM) Policy for gas distribution.
C.
REMEDY TERMS
DEFINED
For this remedy, record is defined in TD-4016S Gas Operations Records and Information
Management as information created, received and maintained for a business purpose or
to comply with regulatory or legal requirements, including the documentation of a
specific action, a transaction, a decision, regulatory compliance requirement or a legal
commitment made by the Company during the course of its business activity.
Records and Information Management (RIM) Policy for gas distribution is defined to
include policies, standards or procedures governing gas distribution operations records.
Inactive Records for gas distribution are defined as a record no longer needed to conduct
current business, but preserved until it meets the end of its retention period.
Active Records for gas distribution are defined as a record related to current, ongoing or
in-process activity and referred to on a regular basis to respond to day-to-day operational
requirements.
Treatment is defined as specifying in PG&Es RIM Policy how active and inactive records
are to be managed.
D.
STATUS
(OPEN/CLOSED)
DATE OF CLOSURE
E.
COMPLIANCE
ACTION AND
SCHEDULE
F.
SUPPORTING
DOCUMENTATION
OF COMPLIANCE
G.
REMEDIES THAT
HAVE BEEN
ORDERED
ELSEWHERE
(INCLUDE SOURCE
AND PROGRESS TO
DATE)
H.
REMEDIES THAT
MODIFY OR
ELIMINATE
REMEDIES ORDERED
ELSEWHERE
(INCLUDE SOURCE)
I.
GAS DISTRIBUTION
RECORD-KEEPING
DECISION ISSUES
ADDRESSED BY THIS
REMEDY
Missing records
A-12
I.14-11-008
DECEMBER 2016
Remedy 11
A.
REFERENCE
B.
REMEDY
PG&Es records management processes shall be managed and maintained to support the
safe operation and maintenance of the gas distribution system and to retain physical and
digital distribution pipeline records for the life of the asset.
C.
REMEDY TERMS
DEFINED
Records are defined as records contained in PG&Es job files. See Remedy #15 for the
definition of job files, which consists of both as-built and non-as-built records.
Life of the asset is defined to begin at the time the asset becomes operational and end at
the point at which the gas distribution asset is retired from operations.
D.
STATUS
(OPEN/CLOSED)
DATE OF CLOSURE
Open
E.
COMPLIANCE
ACTION AND
SCHEDULE
Expected Completion Date: See compliance action and schedule activities for GD Records
Remedies 1 through 10.
F.
SUPPORTING
DOCUMENTATION
OF COMPLIANCE
Records_12_AttachmentGas Operations Records Retention Schedule

Records_12_AttachmentTD-4016S Gas Operations Records and Information Management
When complete, report summarizing PG&Es efforts to digitize its gas distribution mains
As-Built
G.
REMEDIES THAT
HAVE BEEN
ORDERED
ELSEWHERE
(INCLUDE SOURCE
AND PROGRESS TO
DATE)
H.
REMEDIES THAT
MODIFY OR
ELIMINATE
REMEDIES ORDERED
ELSEWHERE
(INCLUDE SOURCE)
None
I.
GAS DISTRIBUTION
RECORD-KEEPING
DECISION ISSUES
ADDRESSED BY THIS
REMEDY
Maps in GD GIS that do not match field conditions
A-13
I.14-11-008
DECEMBER 2016
Remedy 12
A.
REFERENCE
NUMBER
GD Records OII SED #a, c
B.
REMEDY
PG&E should conduct a systemic review of its records to determine if there are other
categories of missing records of the same magnitude as the missing De Anza records.
PG&E should file a report that documents the review that was performed and identifies
all of the categories of missing records defined below for its gas distribution system
identified in this review.
C.
REMEDY TERMS
DEFINED
Records are defined as Gas Service Records (GSR) for gas services and As-Builts records for
gas distribution mains.
D.
STATUS
(OPEN/CLOSED)
DATE OF CLOSURE
Open
E.
COMPLIANCE
ACTION AND
SCHEDULE
(1) PG&E will compare its Customer Care and Billing records, the GD GIS Gas Service
Record inventory, and the gas main as-built inventory to GD GIS to identify
potentially missing records of the same magnitude as the missing De Anza records.
(2) File a report based on item (1) with recommended actions
F.
SUPPORTING
DOCUMENTATION
OF COMPLIANCE
Documented activities to perform a review for potential missing GSRs and as-built records
for gas distribution mains
G.
REMEDIES THAT
HAVE BEEN
ORDERED OR
SUGGESTED
ELSEWHERE
(INCLUDE SOURCE
AND PROGRESS TO
DATE)
PG&Es I.14-11-008 April 1, 2016 Brief, addressed the proposed SED A and C remedies on
pp. C-5 to C-7 and C-10.
REMEDIES THAT
MODIFY OR
ELIMINATE
REMEDIES ORDERED
ELSEWHERE
(INCLUDE SOURCE)
None
I.
GAS DISTRIBUTION
RECORD-KEEPING
DECISION ISSUES
ADDRESSED BY THIS
REMEDY
Document findings from the review with recommended actions.
A-14
I.14-11-008
DECEMBER 2016
Remedy 13
A.
REFERENCE
B.
REMEDY
When errors or changed field conditions or incomplete records are discovered, the record
shall be corrected as soon as correct information is available and the reason(s) for each
change shall be documented and kept with the record to support the safe operation and
maintenance of the gas distribution system.
C.
REMEDY TERMS
DEFINED
PG&E defines errors as data later found to be incorrect regarding installed material type
or diameter or location.
PG&E defines kept with the record to mean that the CAP Notification number
generating the record correction is cross-referenced in the GD GIS system to the asset
subject to the correction. The GD GIS system is also visually updated to reflect the change
to the asset.
D.
STATUS
(OPEN/CLOSED)
DATE OF CLOSURE
Open
E.
COMPLIANCE
ACTION AND
SCHEDULE
PG&E has an existing process to update or to make other changes to a gas distribution
records allowing for both timely updates and retention of the reasons for the changes.
Mapping Correction
PG&E upgraded and documented a new Map Correction procedure TD- 4460P-11
Gas Map Corrections, effective October 13, 2014. This new process allows any
PG&E employee to submit map corrections directly to mapping through the
Corrective Action Program (CAP) via a mobile application, web page, or directly
into SAP. These are then tracked, completed by mapping, and closed. The record
from the field (e.g. correction form or drawing) is stored within SAP under the CAP
notification number.
F.
SUPPORTING
DOCUMENTATION
OF COMPLIANCE
Records_13_Attachment CAP Program Mobile Application Announcement
G.
REMEDIES THAT
HAVE BEEN
ORDERED
ELSEWHERE
(INCLUDE SOURCE
AND PROGRESS TO
DATE)
None
H.
REMEDIES THAT
MODIFY OR
ELIMINATE
REMEDIES ORDERED
ELSEWHERE
(INCLUDE SOURCE)
None
Records_13_Attachment 4460P-11, Gas Map Corrections
A-15
I.14-11-008
DECEMBER 2016
(CONTINUED)
Remedy 13
I.
GAS DISTRIBUTION
RECORD-KEEPING
DECISION ISSUES
ADDRESSED BY THIS
REMEDY
A-16
I.14-11-008
DECEMBER 2016
Remedy 14
A.
REFERENCE
I.12-01-007; I.11-02-016; I.11-11-009, COMPLIANCE PLAN (D.15-04-024), JUNE 8, 2015 Record Keeping OII #16 a,b,c
B.
REMEDY
The information that was contained in PG&E's historic records and documents, and that
has been identified as 'missing or disposed of,' and is necessary to be retained for the safe
operation of the pipelines shall be recovered.
When PG&E cannot locate records, it may apply conservative assumptions. PG&E shall
document any engineering-based assumptions it makes for data that has been identified
as missing or disposed of. Such assumptions must be clearly identified and justified.
C.
REMEDY TERMS
DEFINED
Records are defined as Gas Service Records (GSR) for gas services and As-Builts records for
gas distribution mains.
D.
STATUS
(OPEN/CLOSED)
DATE OF CLOSURE
Open
E.
COMPLIANCE
ACTION AND
SCHEDULE
PG&E will develop a procedure stating when conservative assumptions should be applied
to gas distribution assets subject to missing or disposed of records that were necessary to
retain for the safe operation of pipelines. The procedure will explain how to apply
conservative assumptions to gas distribution assets, where warranted.
F.
SUPPORTING
DOCUMENTATION
OF COMPLIANCE
Once completed, PG&E will provide the procedure for the use of conservative
assumptions for missing data in Gas Distribution records.
G.
REMEDIES THAT
HAVE BEEN
ORDERED
ELSEWHERE
(INCLUDE SOURCE
AND PROGRESS TO
DATE)
None
H.
REMEDIES THAT
MODIFY OR
ELIMINATE
REMEDIES ORDERED
ELSEWHERE
(INCLUDE SOURCE)
None
I.
GAS DISTRIBUTION
RECORD-KEEPING
DECISION ISSUES
ADDRESSED BY THIS
REMEDY
A-17
I.14-11-008
DECEMBER 2016
Remedy 15
A.
REFERENCE
B.
REMEDY
PG&E shall create a standard format for the organization of a job file so that PG&E
personnel will know exactly where to look in a file folder, or set of file folders, to find each
type of document associated with a job file.
C.
REMEDY TERMS
DEFINED
Job File is defined as an electronic file that contains scanned as-built records and
construction job package associated with new main construction project or gas service
installation records.
D.
STATUS
(OPEN/CLOSED)
DATE OF CLOSURE
Open
E.
COMPLIANCE
ACTION AND
SCHEDULE
PG&E will develop a procedure to define the records needed in a new gas distribution job
file. The job file procedure will include the reference procedures for as-builts records, and
construction job package. PG&E will establish controls for use and adherence to the
procedure developed.
See remedy #12.
F.
SUPPORTING
DOCUMENTATION
OF COMPLIANCE
PG&E will provide to SED the newly created procedure to define the records needed in a
gas distribution job file.
G.
REMEDIES THAT
HAVE BEEN
ORDERED
ELSEWHERE
(INCLUDE SOURCE
AND PROGRESS TO
DATE)
None
H.
REMEDIES THAT
MODIFY OR
ELIMINATE
REMEDIES ORDERED
ELSEWHERE
(INCLUDE SOURCE)
None
I.
GAS DISTRIBUTION
RECORD-KEEPING
DECISION ISSUES
ADDRESSED BY THIS
REMEDY
A-18
I.14-11-008
DECEMBER 2016
A.
REFERENCE
Remedy 16
I.12-01-007; I.11-02-016; I.11-11-009, COMPLIANCE PLAN (D.15-04-024), JUNE 8, 2015 PWC Recommendation C.11
On November 20, 2014, the CPUC opened an Order Instituting Investigation (OII)
I.14-11-008 pertaining to PG&Es recordkeeping for its gas distribution system. Because
the above PWC recommendation relates solely to gas distribution personnel and
processes, it will be addressed in conjunction with the outcome of OII I.14-11-008.
B.
REMEDY
Consider consolidating Gas Distribution Mappers to centralized location to facilitate

consistency and controls. Retain 1-2 local field resources for local requests and M&C
assistance.
C.
REMEDY TERMS
DEFINED
None
D.
STATUS
(OPEN/CLOSED)
DATE OF CLOSURE
Closed
E.
COMPLIANCE
ACTION AND
SCHEDULE
PG&E implemented this remedy as stated in testimony.
F.
SUPPORTING
DOCUMENTATION
OF COMPLIANCE
I.14-11-008 Exhibit 4 at p. 4-3, line 1 to page 4-4, line 18, PG&E Reply Testimony, Trevino
G.
REMEDIES THAT
HAVE BEEN
ORDERED
ELSEWHERE
(INCLUDE SOURCE
AND PROGRESS TO
DATE)
None
H.
REMEDIES THAT
MODIFY OR
ELIMINATE
REMEDIES ORDERED
ELSEWHERE
(INCLUDE SOURCE)
None
I.
GAS DISTRIBUTION
RECORD-KEEPING
DECISION ISSUES
ADDRESSED BY THIS
REMEDY
None
A-19
I.14-11-008
DECEMBER 2016
Remedy 17
A.
REFERENCE
I.12-01-007; I.11-02-016; I.11-11-009, COMPLIANCE PLAN (D.15-04-024), JUNE 8, 2015 PWC Recommendation D.19
B.
REMEDY
Address known challenges and backlog of Gas Maps.
C.
REMEDY TERMS
DEFINED
PG&E defines addressing the known challenges as taking actions to reduce the time
between a gas distribution job being completed in the field and the time it takes to
update GD GIS.
D.
STATUS
(OPEN/CLOSED)
DATE OF CLOSURE
Closed. 12/31/14 with reduction of time required to update capital jobs in mapping after
construction complete
E.
COMPLIANCE
ACTION AND
SCHEDULE
PG&E instituted a weekly order by order tracking process (as-built dashboard) to monitor
the time for the documentation to go through the As-Built process.
F.
SUPPORTING
DOCUMENTATION
OF COMPLIANCE
PWC_D.19_Attachment See Our Progress update reflecting improvements through 2013

PWC_D.19_Attachment Copy of as-built dashboard
G.
REMEDIES THAT
HAVE BEEN
ORDERED
ELSEWHERE
(INCLUDE SOURCE
AND PROGRESS TO
DATE)
None
H.
REMEDIES THAT
MODIFY OR
ELIMINATE
REMEDIES ORDERED
ELSEWHERE
(INCLUDE SOURCE)
None
I.
GAS DISTRIBUTION
RECORD-KEEPING
DECISION ISSUES
ADDRESSED BY THIS
REMEDY
A-20
I.14-11-008
DECEMBER 2016
Remedy 18
A.
REFERENCE
NUMBER
GD Records OII #1
B.
REMEDY
Validate that as-built main and gas service records reasonably represent asset location
and that locating wire is functional. PG&E will continue to use the Map Correction
procedure to submit record corrections through CAP when field conditions do not match
records.
C.
REMEDY TERMS
DEFINED
None
D.
STATUS
(OPEN/CLOSED)
DATE OF CLOSURE
Open
E.
COMPLIANCE
ACTION AND
SCHEDULE
PG&E will develop a quality management procedure to perform a locate and mark in the
field upon completion of construction to validate that as-built records reasonably
represent field conditions and that locating wire is functional.
F.
SUPPORTING
DOCUMENTATION
OF COMPLIANCE
The procedure created for quality assurance in the field upon completion of construction
to validate that as-built records are created correctly will be provided to SED.
PG&E will provide a copy of its Copy of Map Correction procedure TD- 4460P-11 Gas
Map Corrections, effective October 13, 2014.
G.
REMEDIES THAT
HAVE BEEN
ORDERED OR
SUGGESTED
ELSEWHERE
(INCLUDE SOURCE
AND PROGRESS TO
DATE)
None
H.
REMEDIES THAT
MODIFY OR
ELIMINATE
REMEDIES ORDERED
ELSEWHERE
(INCLUDE SOURCE)
None
I.
GD RECORDS OII
Maps in GD GIS that do not match field conditions/support the safe operation and
DECISION ISSUE THAT maintenance of the gas distribution system
REMEDY
ADDRESSES/REMEDY
INTENT
A-21
I.14-11-008
DECEMBER 2016
Remedy 19
A.
REFERENCE
NUMBER
GD Records OII #2
B.
REMEDY
Formalize the role of Gas Carrier Pipe checklist and the use of the Continental Bolt-On
fitting in a work procedure that is a part of the O&M Manual.
C.
REMEDY TERMS
DEFINED
None
D.
STATUS
(OPEN/CLOSED)
DATE OF CLOSURE
Open
E.
COMPLIANCE
ACTION AND
SCHEDULE
Incorporate the Gas Carrier Pipe checklist and the use of the Continental Bolt-On fitting in
a work procedure that is part of the O&M manual.
F.
SUPPORTING
DOCUMENTATION
OF COMPLIANCE
Provide a copy of the procedure developed.
G.
REMEDIES THAT
HAVE BEEN
ORDERED OR
SUGGESTED
ELSEWHERE
(INCLUDE SOURCE
AND PROGRESS TO
DATE)
None
H.
REMEDIES THAT
MODIFY OR
ELIMINATE
REMEDIES ORDERED
ELSEWHERE
(INCLUDE SOURCE)
None
I.
GD RECORDS OII
Unmapped plastic inserts/support the safe operation and maintenance of the gas
DECISION ISSUE THAT distribution system
REMEDY
ADDRESSES/REMEDY
INTENT
A-22
I.14-11-008
DECEMBER 2016
Remedy 20
A.
REFERENCE NUMBER
GD Records OII PWA#1
B.
REMEDY
PWA recommends that PG&E examine the costs and benefits associated with
undertaking a systematic identification and correction effort for unmapped plastic
inserts and stubs, relying on the experiences of other utilities in dealing with these
issues.
C.
REMEDY TERMS
DEFINED
PG&E defines examining the costs and benefits associated with undertaking a
systematic identification and correction effort for unmapped plastic inserts and stubs
consistent with I. 14-11-008 Chapter 6 Reply Testimony stating, PG&E . . . will conduct
benchmarking analysis to identify industry best practices in addressing unmapped stubs
and plastic inserts.
D.
STATUS
(OPEN/CLOSED)
DATE OF CLOSURE
Open
E.
COMPLIANCE ACTION
AND SCHEDULE
Complete industry benchmarking to identify practices used by other utilities for the
systematic identification and correction efforts for unmapped plastic inserts and stubs.
If effective practices are identified that PG&E has not already implemented, perform a
cost benefit analysis for PG&E to implement.
Implement cost effective practices identified from the benchmark.
F.
SUPPORTING
DOCUMENTATION OF
COMPLIANCE
To the extent benchmark participants agree to release the practices they share with
PG&E, PG&E will summarize its plastic inserts and stubs findings including identification
of any practices that were identified, PG&Es assessment of the benefit, and if
implemented.
G.
REMEDIES THAT HAVE

BEEN ORDERED OR
SUGGESTED
ELSEWHERE (INCLUDE
SOURCE AND
PROGRESS TO DATE)
None
H.
REMEDIES THAT
MODIFY OR ELIMINATE
REMEDIES ORDERED
ELSEWHERE (INCLUDE
SOURCE)
None
I.
GD RECORDS OII
DECISION ISSUE THAT
REMEDY ADDRESSES
Unmapped plastic inserted mains and services; mapping of stubs; stub removal
A-23
I.14-11-008
DECEMBER 2016
Remedy 21
A.
REFERENCE
NUMBER
B.
REMEDY
PWA recommends that PG&E, considering the risk trade-offs, re-examine more
aggressively eliminating existing stubs.
C.
REMEDY TERMS
DEFINED
None
D.
STATUS
(OPEN/CLOSED)
DATE OF CLOSURE
Open
E.
COMPLIANCE
ACTION AND
SCHEDULE
PG&E will review its stub management practices and evaluate if changes are appropriate
based on the risk associated with stubs.
PG&E will document its control process regarding the use and adherence to stub
monitoring and removal.
F.
SUPPORTING
DOCUMENTATION
OF COMPLIANCE
PG&E will report the findings of its review and any actions it intends to take.
PG&E I.14-11-008 Brief, Appendix C, p. C-2
SEDs response to PG&Es I.14-11-008 data requests Set 2 and 3, Attachment W095,
I.14-11-008 PG&E Reply Testimony
PG&Es documentation of its control process regarding the use and adherence to stub
monitoring and removal procedure.
G.
REMEDIES THAT
HAVE BEEN
ORDERED
ELSEWHERE
(INCLUDE SOURCE
AND PROGRESS TO
DATE)
None
H.
REMEDIES THAT
MODIFY OR
ELIMINATE
REMEDIES ORDERED
ELSEWHERE
(INCLUDE SOURCE)
None
I.
GD RECORDS OII
Individual gas stub dig-in events
DECISION ISSUE THAT
REMEDY ADDRESSES
A-24
I.14-11-008
DECEMBER 2016
Remedy 22
A.
REFERENCE
NUMBER
B.
REMEDY
PWA recommends that PG&E consider re-examining both how it defines root cause and
how it integrates corrective actions related to those root causes into existing
management practices.
C.
REMEDY TERMS
DEFINED
Root Cause: PG&E defines root cause to be a method of causal analysis.
D.
STATUS
(OPEN/CLOSED)
DATE OF CLOSURE
Closed
E.
COMPLIANCE
ACTION AND
SCHEDULE
PG&E reviewed its causal analysis procedure to evaluate its similarity to the policy that
PWA recommends
F.
SUPPORTING
DOCUMENTATION
OF COMPLIANCE
I.11-14-008, Ex. 1, PWA Report dated September 30, 2015, p. 76, lines 14 29,
April 1, 2016
Utility Standard GOV-6102S, Enterprise Causal Evaluation

I.11-14-008, Ex. 4, Singh Reply Testimony at p. 5-30, line 26 to p. 5-31, line 10
G.
REMEDIES THAT
HAVE BEEN
ORDERED OR
SUGGESTED
ELSEWHERE
(INCLUDE SOURCE
AND PROGRESS TO
DATE)
None
H.
REMEDIES THAT
MODIFY OR
ELIMINATE
REMEDIES ORDERED
ELSEWHERE
(INCLUDE SOURCE)
None
I.
GD RECORDS OII
Causal analysis
DECISION ISSUE THAT
REMEDY ADDRESSES
A-25
I.14-11-008
DECEMBER 2016
Remedy 23
A.
REFERENCE
NUMBER
GD Records OII SED #b
B.
REMEDY
PG&E should leverage information gathered from its field personnel and various sources,
such as its Corrective Action Program (CAP), to determine any negative trends that impact
the completeness and accuracy of its records and maps.
C.
REMEDY TERMS
DEFINED
Records are defined as Gas Service Records (GSR), Plat Maps in GD GIS, and As-Builts for
gas distribution main.
D.
STATUS
(OPEN/CLOSED)
DATE OF CLOSURE
PG&E upgraded and documented a new Map Correction procedure TD- 4460P-11 Gas
Map Corrections, effective October 13, 2014. This new process allows any PG&E
employee to submit map corrections directly to mapping through the Corrective Action
Program (CAP) using a mobile application, web page, or directly into SAP. These are then
tracked, completed by mapping, and closed. The record from the field (e.g., correction
form or drawing) is stored within SAP under the CAP notification number.
Open
E.
COMPLIANCE
ACTION AND
SCHEDULE
(1) Conduct a trending analysis of CAP mapping correction notifications and CAP Quality
Management findings to determine any potential trends in the submission of map
updates between October 2014 and the time of the Commission decision. The trending
analysis will focus on identifying process gaps that could impact records accuracy
F.
SUPPORTING
DOCUMENTATION
OF COMPLIANCE
Report summarizing findings from trend analysis of CAP mapping correction notifications
to determine any potential trends in the submission of the type of map updates between
October 2013 and the Commission decision
(3) Copy of Map Correction procedure TD- 4460P-11 Gas Map Corrections, effective
October 13, 2014.
G.
REMEDIES THAT
HAVE BEEN
ORDERED OR
SUGGESTED
ELSEWHERE
(INCLUDE SOURCE
AND PROGRESS TO
DATE)
PG&Es I.14-11-008 April 1, 2016 Brief, addressed the proposed SED B remedy on p. C-8
to C-9.
H.
REMEDIES THAT
MODIFY OR
ELIMINATE
REMEDIES ORDERED
ELSEWHERE
(INCLUDE SOURCE)
None
I.
GD RECORDS OII
DECISION ISSUE THAT
REMEDY ADDRESSES
A-26
I.14-11-008
DECEMBER 2016
Remedy 24
A.
REFERENCE
NUMBER
GD Records OII SED #d
B.
REMEDY
PG&E will evaluate whether there is anything more it can do to identify unmapped plastic
inserts in its gas distribution system. PG&E will assess whether those actions are
reasonable and cost effective. PG&E should file a report describing the evaluation for
program need, and the basis for why a proactive program is or is not needed. PG&E
should also describe any additional measures it is taking to address the risk of unknown
plastic inserts.
C.
REMEDY TERMS
DEFINED
PG&E defines evaluation for a proactive program to identify unknown plastic inserts in its
distribution system as comparing GD GIS to SAP leak data to identify potential unmapped
plastic inserts.
D.
STATUS
(OPEN/CLOSED)
DATE OF CLOSURE
Open
E.
COMPLIANCE
ACTION AND
SCHEDULE
PG&E will prepare a report documenting its evaluation of whether there is anything more
it can do to identify unmapped plastic inserts in its gas distribution systems and whether
those actions are reasonable and cost effective.
PG&E will prepare a report of its findings to identify unknown plastic inserts in its
distribution system by comparing GD GIS to SAP leak data. GD GIS will be updated as
necessary.
Use CAP mapping correction notifications to detect evidence of potential unmapped stubs
or inserts.
F.
SUPPORTING
DOCUMENTATION
OF COMPLIANCE
PG&E to provide a copy of the report of its findings to identify unknown plastic inserts in
its distribution system, including its use of CAP to detect evidence of potential unmapped
stubs or inserts, and to evaluate whether there is anything more it can do to identify
unmapped plastic inserts and whether those actions are reasonable and cost effective.
PG&E to provide a record of the updates made to its GD GIS system as a result of the
report.
G.
REMEDIES THAT
HAVE BEEN
ORDERED OR
SUGGESTED
ELSEWHERE
(INCLUDE SOURCE
AND PROGRESS TO
DATE)
GD Records PWA #1, GD Records SED #b

PG&Es I.14-11-008 April 1, 2016 Brief, addressed proposed SED B remedy on p. C-11
H.
REMEDIES THAT
MODIFY OR
ELIMINATE
REMEDIES ORDERED
ELSEWHERE
(INCLUDE SOURCE)
None
A-27
I.14-11-008
DECEMBER 2016
(CONTINUED)
Remedy 24
I.
GD RECORDS OII
Maps in GD GIS that do not match field conditions; Unmapped plastic inserts
DECISION ISSUE THAT
REMEDY ADDRESSES
A-28

APPENDIX A
ATTACHMENT 1
ENTERPRISE RECORDS AND INFORMATION MANAGEMENT
STANDARD (GOV-7101S)
ATTACHMENT PUBLICATION DATE: 9/2/2016 REV. 3
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-7101S
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A-Atch1-2
Retention Period:
Retention Period:
Vital
Vital
Vital
Retention Period: The length of time a record must be kept, after which the record can be dispositioned
(destroyed or preserved as a historical document)
Retention Period:
Trigger Event: An occurrence, either calendar or event based (for example: end of year,
termination date, end of matter, end of project), that begins the retention period.
Examples:
Comment:
Description:
Trigger Event:
Record Category ID: EDC0610 | Record Category Name: Locating Records - 811 - Gas
Examples:
Comment:
Description:
Trigger Event:
Record Category ID: EDC0500 | Record Category Name: Leak Survey & Inspection Records - Gas
Examples:
Comment:
Description:
Trigger Event:
Record Category ID: EDC0400 | Record Category Name: Integrity Management Records - Gas
A-Atch1-3
Retention Period:
Vital
Retention Period:
Vital
Vital
Retention Period:
Examples:
Comment:
Description:
Trigger Event:
Record Category ID: EDC1100 | Record Category Name: Quality Control & Improvement Records - Gas
Examples:
Comment:
Description:
Trigger Event:
Record Category ID: EDC1010 | Record Category Name: Policies, Procedures & Standards - Operational & Technical - Gas
Examples:
Comment:
Description:
Trigger Event:
Record Category ID: EDC0710 | Record Category Name: Locate and Mark Records - Gas
A-Atch1-4
Retention Period:
Retention Period:
Vital
Vital
Vital
Retention Period:
Examples:
Comment:
Description:
Trigger Event:
Record Category ID: OPS0210 | Record Category Name: Outage Records - Gas
Examples:
Comment:
Description:
Trigger Event:
Record Category ID: OPS0110 | Record Category Name: Maintenance Records - Gas
Examples:
Comment:
Description:
Trigger Event:
Record Category ID: OPS0055 | Record Category Name: Incident Reporting Records - Gas
A-Atch1-5
Retention Period:
Retention Period:
Vital
Vital
Vital
Retention Period:
Examples:
Comment:
Description:
Trigger Event:
Record Category ID: OPS0610 | Record Category Name: Research and Development Records - Not Approved - Gas
Examples:
Comment:
Description:
Trigger Event:
Record Category ID: OPS0510 | Record Category Name: Research and Development Records - Approved - Gas
Examples:
Comment:
Description:
Trigger Event:
Record Category ID: OPS0310 | Record Category Name: Permits - Temporary - Gas
A-Atch1-6
Retention Period:
Vital
Vital
Retention Period:
Examples:
Comment:
Description:
Trigger Event:
Record Category ID: OPS1210 | Record Category Name: Usage Records - Gas
Examples:
Comment:
Description:
Trigger Event:
Record Category ID: OPS1000 | Record Category Name: Supply & Forecasting Records - Gas
A-Atch1-7
Retention Period:
Retention Period:
Vital
Vital
Vital
Retention Period:
Examples:
Comment:
Description:
Trigger Event:
Record Category ID: PLN0720 | Record Category Name: Strategic Planning Records - Gas
Examples:
Comment:
Description:
Trigger Event:
Record Category ID: OPS1300 | Record Category Name: Work Orders & Maintenance Records - Gas
Examples:
Comment:
Description:
Trigger Event:
Record Category ID: OPS1250 | Record Category Name: Digital Audio, Audiovisual or Imagery Records (Supporting) - Gas
A-Atch1-8
Retention Period:
Vital
Vital
Retention Period:
Examples:
Comment:
Description:
Trigger Event:
Record Category ID: REG0420 | Record Category Name: Regulatory Reporting Records - Gas
Examples:
Comment:
Description:
Trigger Event:
Record Category ID: PLN0800 | Record Category Name: Wholesale Marketing Records - Gas
A-Atch1-9
Trigger Event:
Description:
Record Category:
Trigger Event:
Description:
Record Category:
Trigger Event:
Description:
Record Category:
Trigger Event:
Description:
Record Category:
Trigger Event:
Description:
Record Category:
Trigger Event:
Description:
Record Category:
Vital:
Vital:
Vital:
Vital:
Vital:
Vital:
Retention Period
Retention Period
Retention Period
Retention Period
Retention Period
Retention Period
A-Atch1-10
Accounts Payable Records
Record Category: FIN0100
Trigger Event:
Description:
Record Category:
Trigger Event:
Description:
Record Category:
Trigger Event:
Description:
Record Category:
Trigger Event:
Description:
Record Category:
Trigger Event:
Description:
Record Category:
Vital:
Vital:
Vital:
Vital:
Vital:
Retention Period
Retention Period
Retention Period
Retention Period
Retention Period
A-Atch1-11
Business Development Records
Examples:
Record Category: GOV0300 Contract & Agreement Records - Corporate
Examples:
Record Category: PLN0100
Examples:
Record Category: GOV0100 Audit and CAP Records
Examples:
A-Atch1-12
Payroll Records
Office Administration Records
Corporate Relations Records - Internal
Examples:
Examples:
Record Category: SER1300
Examples:
Record Category: CAF0400
A-Atch1-13
Policies, Procedures & Standards - Environment, Health & Safety
Examples:
Examples:
Personnel Records
Permits - Permanent - Corporate
Records related to an individuals work history with PG&E, including employment information, work status, performance assessments, etc.
Record Category: HRS1000
Examples:
A-Atch1-14
Project Management Records - Corporate (Non-Utility)
Policies, Procedures, & Standards - Administrative
Record Category: GOV1000 Records Management Records - Data & Document Inventories
Record Category: GOV0900 Records Management Records - Operations
Examples:
Examples:
A-Atch1-15
Recruiting Records
Examples:
Examples:
Record Category: GOV1200 Records Management Records - Retention
Examples:
Record Category: GOV1100 Records Management Records - Destruction
A-Atch1-16
Timekeeping Records
Strategic Planning Records - Corporate
Sourcing Records
Examples:
Examples:
Record Category: PLN0700
Examples:
Examples:
Record Category: GOV1300 Emergency Preparedness & Response
A-Atch1-17
Training Records - Environment, Health & Safety Training & Certifications
Training Records - Corporate Training & Certifications
Training Records - Career Development
Examples:
Examples:
Examples:
A-Atch1-18
Information Technology Records - Application Development and Operations
Work Orders & Maintenance Records - Corporate (Non Utility)
Training Records - Operational & Technical Training & Certifications
Revision Notes
Examples:
Record Category: ITS0100
Examples:
Examples:

APPENDIX B
PG&ES SUMMARY OF THE MEET-AND-CONFER PROCESS
AND EFFORTS UNDERTAKEN REGARDING THE INITIAL
COMPLIANCE PLAN
Appendix B
PG&Es Summary of the Meet and Confer Process
The following summarizes the meet-and-confer process undertaken by the parties in
conformance with Decision (D.) 16-08-020.
Invitation to Participate: On October 11, 2016, Pacific Gas and Electric Company (PG&E)
issued a notice inviting all parties to this proceeding (Investigation (I.) 14-11-008), all parties to
PG&Es most recent General Rate Case, and all parties to the Gas Transmission Records
Order Instituting Investigation (OII) (I.11-02-016) to participate in an initial meet and confer
session scheduled to take place on October 24, 2016 regarding its Gas Distribution Records
Compliance Plan (Compliance Plan). Attached as Attachment B-1 is a copy of the
meet-and-confer notice sent to the parties. The Safety Enforcement Division (SED), Office of
Ratepayer Advocates (ORA), The Utility Reform Network (TURN), and City of Carmel-by-theSea (Carmel) indicated interest in participating in the meet-and-confer process.
First Meet-and-Confer Session: SED, ORA, TURN and Carmel attended the first Meet and
Confer held on October 24, 2016. During that session, PG&E presented its draft Initial
Compliance Plan and reviewed the process it took to develop the first draft. This included a
review of Attachment A to D.16-08-020, which reproduced remedies ordered in the Gas
Transmission Records OII D.15-04-024 to determine applicable remedies that could be applied
to Gas Distribution records and/or address findings in D.16-08-020. PG&E walked through each
of the proposed remedies with the attendees and solicited feedback.
Second Draft of Initial Compliance Plan: PG&E incorporated feedback provided during the First
Meet-and-Confer session into a second draft of the compliance plan. On November 9, 2016,
PG&E sent SED, ORA, TURN, and Carmel the second draft and requested written feedback on
the second draft by November 21. SED, ORA and TURN provided written feedback.
Second Meet-and-Confer Session: On November 30, 2016, PG&E hosted a Second
Meet-and-Confer session. SED, ORA and TURN attended. During this session, PG&E
distributed a summary of the 21 comments submitted on November 21, 2016. PG&E, SED,
ORA and TURN then went through all comments and aligned on the process and schedule to
finalize PG&Es Initial Compliance Plan.
B-1

APPENDIX B
ATTACHMENT 1
PG&ES NOTICE TO MEET AND CONFER
From: Cotroneo, Eileen

Sent: Tuesday, October 11, 2016 1:38 PM
To: nsuetake@turn.org; p.duller@btinternet.com; Paul.Fremont@nexus-cap.com;
paulschaafsma@yahoo.com; pbelonick@sidley.com; PhilM@SCDenergy.com; ppatterson2@nyc.rr.com; Van
Mieghem II, Peter (Law); pucservice@dralegal.org; rafferty@gmail.com; ram@cpuc.ca.gov;
randall@nexusamllc.com; RegRelCPUCCases; regulatory@mceCleanEnergy.org; rfant@sidley.com;
rkoss@adamsbroadwell.com; RL@eslawfirm.com; Rmccann@umich.edu; rmp@cpuc.ca.gov;
RobertGnaizda@gmail.com; rochelle@a4nr.org; RPrince@SempraUtilities.com;
SAmrany@SempraUtilities.com; scott.senchak@decade-llc.com; scr@cpuc.ca.gov; service@cforat.org;
sfleishman@wolferesearch.com; SGM@cpuc.ca.gov; sgriffin@meyersnave.com; sgs@dcbsf.com;
Shinjini.Menon@sce.com; SHruby@SempraUtilities.com; skh@cpuc.ca.gov;
SLudwick@zimmerpartners.com; SMeyers@MeyersNave.com; smn@dwgp.com; sophie.karp@citi.com;
Sharp, Shelly; StephanieC@greenlining.org; Stough@BraunLegal.com; sue.mara@RTOAdvisors.com; Frank,
Steven; SYang@SempraUtilities.com; Carlberg, Tessa; tbo@cpuc.ca.gov; tcr@cpuc.ca.gov;
tdp@cpuc.ca.gov; ted@PointState.com; terence.healey@cwt.com; TGondai@NAAC.org
Subject: PG&E's Notice of Meet and Confer Regarding Gas Distribution Records Compliance Plan (D.16-08020)
To the Parties and Service Lists of I.14-11-008, I.11-02-016 and A.15- 09-001:
On Monday, October 24, 2016, Pacific Gas and Electric Company will host a Meet and Confer
with parties to consider and develop additional remedial measures necessary to address issues
identified in the Commissions Decision (D.16-08-020) regarding its Investigation of PG&Es Gas
Distribution Facilities Records issued on August 28, 2016.
The objective of this discussion is to meet and confer to develop any additional remedial measures
necessary to address the issues identified in the Decision with the objective of establishing a
compliance plan that includes all feasible and cost-effective measures necessary to improve
PG&Es natural gas distribution system recordkeeping.
As required by D.16-08-020, the participants will begin their review with Exhibit E to D.15-04024 (Attachment A) to evaluate those remedial measures to determine whether more or different
requirements are needed for the gas distribution system. The Commissions Safety and
Enforcement Division will participate and monitor this workshop.
The Compliance Plan PG&E submits to the Commission will include statements from any party
disagreeing with any aspect of Compliance Plan, including any omission, along with alternative
recommendations and supporting rationale.
If any party wishes to participate, please confirm your participation by sending an email with your
contact information and the number of attendees to Eileen Cotroneo at efm2@pge.com by
Wednesday, October 19, 2016.
Meet and Confer Date:
Monday, October 24, 2016
Meeting Location:
Pacific Energy Center (PEC)

851 Howard Street
Directions to Pacific Energy Center
Time:
9:30 am 4:00 pm
B-Atch1-1
PG&Es presentation materials will be circulated to workshop participants in advance of the

meeting.
Regards,
Eileen Cotroneo
Regulatory Affairs
415.973.2751
Attachment A (Reproduced Exhibit E, D.15-04-024)
________________________
NOTE: The recipient portion of this e-mail may not reflect all the addressees who are being
served. The service list has been split into 50-addressee groups, to avoid rejection by CPUC and
other e-mail servers.
If you would no longer like to receive documents regarding this docket, please contact the CPUC
Process Office directly via email at Process_Office@cpuc.ca.gov or by phone at 415-703-2021 to
remove yourself from the official service list.
B-Atch1-2

APPENDIX B
ATTACHMENT 2
DECISION 16-08-020, ATTACHMENT A
B-Atch2-1
B-Atch2-2
B-Atch2-3
B-Atch2-4

APPENDIX C
COMMENTS OF SAFETY AND ENFORCEMENT DIVISION (SED)
ON PG&ES INITIAL COMPLIANCE PLAN
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-1

Order Instituting Investigation and
Order to Show Cause on the
Commissions 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.
Investigation 14-11-008
COMMENTS OF THE SAFETY AND ENFORCEMENT DIVISION

TO THE COMPLIANCE PLAN OF PACIFIC GAS & ELECTRIC
COMPANY
Pursuant to Decision 16-08-020, Ordering Paragraph 2, the Safety and
Enforcement Division (SED) hereby provides comments on the Compliance Plan
presented by Pacific Gas & Electric Company (PG&E) in Investigation 14-11-008.
Regarding the process by which PG&Es proposed Compliance Plan was to be
developed, Decision 16-08-020, Ordering Paragraph 2, specifies that [t]he
Commissions Safety and Enforcement Division shall participate and monitor this
process.1 SED advises that it has participated and monitored the process.
A central premise, which PG&E placed on this process, was that an adverse
Commission finding regarding a specific violation would be a prerequisite for including
remedial action on that issue in the Compliance Plan. In SEDs view, a broader process
was contemplated:
The objective of this process will be a comprehensive
compliance plan that includes all feasible and cost-effective
measures necessary to improve PG&Es natural gas
distribution system record-keeping. The participants shall
1
D.16-08-020, OP 2.
C-2
begin their review with Exhibit E to Decision 15-04-024 to

evaluate those remedial measures to determine whether more
or different requirements are needed for the gas distribution
system.2
SED believes that PG&E should include a remedy in its Compliance Plan for
correcting deficiencies in recordkeeping learned as a result of each SED audit, ordered in
D.1504024, that also applies to gas distribution system recordkeeping. PG&E should
include in its reports to SED when such deficiencies in its gas distribution recordkeeping
were corrected. This improves safety by taking a more comprehensive view of learned
deficiencies.
SED also believes that PG&E should avoid using permissive language in its
Compliance Plan. For example, each instance of the word should that appears in
Remedy 24 should be changed to the word will. This improves the enforceability of
the Compliance Plan by preventing future disputes regarding whether a particular aspect
of a given remedy was mandatory.
In any event, SEDs proposed remedial measures are detailed in its Opening Brief
at pages 94-96.3 PG&Es practices regarding gas distribution recordkeeping warrant
those remedial measures, in order to improve the safety and compliance of PG&Es gas
distribution system.4 SEDs participation and monitoring of the development of PG&Es
proposed Compliance Plan does not constitute SEDs acceptance of the omission of any
of SEDs proposed remedial measures.
///
///
///
D.16-08-020, OP 2.
See SED Opening Brief, dated: 2/26/16, at 94-96.
See generally SED Opening Brief.
C-3
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-4

APPENDIX D
COMMENTS OF OFFICE OF RATEPAYER ADVOCATES (ORA)
ON PG&ES INITIAL COMPLIANCE PLAN

Order Instituting Investigation and Order to

Show Cause on the Commissions 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.
Investigation 14-11-008
STATEMENT OF THE OFFICE OF RATEPAYER ADVOCATES

ON PACIFIC GAS AND ELECTRICS PROPOSED COMPLIANCE PLAN
MATTHEW YUNGE
Utilities Engineer
The Office of Ratepayer Advocates
California Public Utilities Commission
505 Van Ness Avenue
Telephone: (415) 703-1667
E-Mail: myu@cpuc.ca.gov
TRACI BONE
Attorney for
The Office of Ratepayer Advocates
California Public Utilities Commission
505 Van Ness Avenue
Telephone: (415) 703-2048
E-Mail: traci.bone@cpuc.ca.gov
December 14, 2016
D-1
I.
Introduction
On October 24, 2016, The Office of Ratepayer Advocates (ORA) participated in
an initial meet and confer ordered in Commission Decision (D.)16-08-020 with Pacific
Gas and Electric Company (PG&E), The Utility Reform Network (TURN), the Safety
Enforcement Division (SED) and City-of Carmel-by-the-Sea (Carmel) regarding PG&Es
Gas Distribution Records Compliance Plan (Compliance Plan).1 ORA participated in a
second meet and confer in which parties addressed a revised draft of the Compliance Plan
that incorporated some of the parties comments from the October 24 meeting. ORA
submits this statement in response to the Draft Compliance Plan PG&E provided the
parties on December 5, 2016.
Beyond the changes already incorporated into the Compliance Plan, ORA
recommends that the Commission make the following changes to PG&Es proposed
Compliance Plan:
1. Require PG&E to maintain traceable, verifiable, and complete distribution
records, including provision of quarterly compliance reports regarding the
costs of this effort;
2. Require PG&E to comply with federal minimum safety requirements by using
proper assumptions where PG&E has not maintained adequate records;
3. Hold additional workshops regarding unmapped plastic inserts in distribution
pipe;
4. Revise the proposed Compliance Plan to include a more expansive description
of the intent behind each remedy; and
5. Include the actual record retention schedule as an attachment to the final
Compliance Plan.
In addition to these requested changes, ORA supports the recommendations that TURN
and SED have made throughout the meet and confer process.
II.
Discussion
During the meet and confer process ORA submitted several rounds of comments
requesting clarification regarding PG&Es process in developing the proposed remedies.
D16-08-020, p. 66.
1
D-2
Several of the concerns mentioned by ORA were sufficiently addressed over the course
of the meet and confer process, but several remain to be addressed.
A. Traceable, Verifiable, and Complete Records Are Needed To Calculate The

Maximum Allowable Operating Pressure (MAOP) Of Distribution Pipes
PG&Es omission of the term traceable, verifiable, and complete (TVC) from its
gas distribution records compliance is not compatible with federal regulations and
requirements, including 49 Code of Federal Regulations (CFR) Part 192 (which
establishes the minimum federal safety standards for all pipelines). TVC records are as
necessary for distribution records as they are for transmission records in order to comply
with the procedures to establish MAOP. 2 This includes design records, pressure testing
records, historical operating pressure records, and the engineering judgment of the
operator. TVC was included in a remedy proposed by SED in the Record Keeping
Investigation (I.) 11-02-016 applicable to transmission pipes.3 The three words included
in this term are defined by the Pipeline and Hazardous Materials Safety Administration
(PHMSA) in Advisory Bulletin (ADB) 2012-06.4 While the Advisory Bulletin was
directed towards Gas Transmission Operators, the definitions of each of the words do not
preclude application to gas distribution record keeping. The term traceable, verifiable,
and complete as defined by PHMSA is an appropriate description of thorough and
responsible recordkeeping practices, regardless of the type of system those practices
49 CFR 192.619 is applicable to all steel and plastic gas pipelines. Additional requirements exist for
distribution pipelines under 49 CFR 192.621 and 192.623. See also Letter from PHMSA to ORA, PI14-0005, dated January 23, 2015.
Question 3: Does 192.619 apply to both transmission lines and distribution lines?
Response: Yes. The requirements in 192.619 apply to both distribution and transmission natural gas
pipelines. Section 192.621 contains different standards that apply only to high pressure distribution
systems. States that regulate intrastate natural gas transmission pipelines and natural gas distribution
pipelines have the right to implement state pipeline regulations that exceed the requirements in Part 192.
3
D.15-04-024, Appendix E, p. 9.
Federal Register Vol. 7, No. 88, Monday, May 7 2012, ADB-2012-06.
2
D-3
might be applied to. ORA recommends that the term traceable, verifiable, and
complete be included in remedies 4, 11, 13, and 15.
ORA also recommends that the Commission require PG&E to provide quarterly
compliance plans for the work it is conducting on the gas distribution system to bring it
into compliance with the minimum federal safety standards. These reports should be
similar to those provided in response to the Pipeline Safety Enhancement Plan (PSEP),
where the Commission required PG&E to report on the status and costs of its safety work
to the Commission, parties, and the public at large. To improve upon the PSEP quarterly
reports, the Commission should put PG&E on notice that all actual costs incurred to
bring its distribution system into compliance with minimum federal safety standards, and
any more stringent standards required by the Commission, should be included in the
quarterly reports and that failure to include costs in the quarterly reports will result in
disallowance of those costs.5
B. Where TVC Records Have Not Been Retained, PG&E Must Calculate The
MAOP Of Distribution Pipes Consistent With Federal Regulations
Where PG&E has not retained TVC records of the material properties of its
distribution pipes it should be required to follow federal minimum safety standards.
Furthermore, unless PG&E has retained the proper records for historical operating
pressures between 1965 and 1970, it must pressure test its distribution pipelines in order
to be compliant with 49 CFR 192.619. Regarding the proper material properties of
pipelines, federal code provides the appropriate guidance. 6
The poor quality of PG&Es cost reporting in the quarterly PSEP reports was revealed in PG&Es 2015
Gas Transmission and Storage Application 13-12-012. For a fuller discussion of the issue, see ORAs
opening and reply briefs in that proceeding:
http://docs.cpuc.ca.gov/PublishedDocs/Efile/G000/M151/K340/151340347.PDF
http://docs.cpuc.ca.gov/PublishedDocs/Efile/G000/M152/K805/152805087.PDF
6
A summary of the provisions of the federal minimum safety standards addressing assumptions is
provided in Attachment A.
3
D-4
It is troubling that PG&E's proposal mimics, to some extent, authorization to make

assumptions where records are missing as set forth in D.11-07-016. While this
authorization to use assumptions has been codified in state law in Public Utilities Code
958, ORA has pointed out to the Commission in multiple proceedings, provisions
permitting such assumptions are preempted by federal law because they are less stringent
than the federal regulations in 49 CFR Part 192. These federal regulations govern the
types of assumptions that may be made when records are missing. To be consistent with
federal regulations, and to ensure that pipes with the least available information be
addressed first, ORA recommends that the Commission order PG&E to identify each one
of its distribution pipes for which it cannot calculate MAOP in compliance with the
federal regulations due to missing records, and that PG&E be required to file a waiver
request with the CPUC, and any other appropriate agency, with a timeline for correcting
such violations. In the interim, for all pipes where such violations exist, PG&E must use
the assumption allowing the greatest safety margin, provided that such an assumption is
not inconsistent with the federal regulations.
C. Remedy 24 Workshops Should Be Held To Address Unmapped Plastic Pipe

Inserts
ORA recommends that additional workshops be held to aid in the implementation of
Remedy 24. The Compliance Plans Remedy 24 states that PG&E will evaluate whether
any additional work can be done to identify unmapped plastic pipe inserts7 in its gas
distribution system.8 ORA views the development of this remedy as a starting point for
further discussion of safety and information gathering practices that can be evaluated.
ORA proposes that Commission staff-led workshops are appropriate to continue
discussion of additional practices that can be evaluated.
7
Plastic pipe inserts are where a gas pipeline operator will use another existing pipeline, for example, a
steel pipeline, and rather than installing an entirely new pipeline, will use the steel pipeline as a conduit
for the plastic pipe.
8
Updated Compliance Plan Dated December 5, 2016, p. 28.
4
D-5
D. The Compliance Plan Should Include More Expansive Explanations Of The

Intent Behind Each Remedy
ORA requests that the PG&Es Compliance Plan be required to include
explanations of the intent behind each remedy. ORA notes that Section I for each remedy
includes an extremely brief description of the intent of the remedy, and that this
description is limited to how the remedy relates to one of the six issues in D.16-08-020.
ORA requests that Section I for each remedy be expanded so that utility and regulatory
staff can quickly gain an understanding of the systemic issue that prompted the
development of a given remedy. Without such information, future Commission staff,
PG&E employees, and intervenors may not be able to understand the scope of the
problem or what the purpose of the remedy is. This is particularly important as
regulations, such as 49 CFR Part 192, or the California Public Utilities Commissions
(CPUC) General Order 112, change in the future.
E. PG&Es Records Retention Schedule Should Be Included As An Appendix To

The Final Adopted Compliance Plan
ORA also recommends that PG&Es Records Retention Schedule be included as
an additional appendix to its final adopted compliance plan. In Remedy 8, Section C of
PG&Es proposed compliance plan, PG&E defines the mandated retention periods for
records relevant to gas distribution though its Gas Operations Records Retention
Schedule.9 The Remedy then refers to D.15 -04-024 for the Remedys Compliance
Action and Schedule (Section E). However, D.15-02-024 only states that The retention
schedule will support the policy by providing retention length for all identified official
records to meet legal and regulatory mandates. 10 Absent including the Records
Updated Compliance Plan Dated December 5, 2016, p. 10.
10
D.15-04-024, Appendix E, p. 8.
5
D-6
Retention Schedule as an Appendix to the final Compliance Plan, there is no ready

mechanism for the Commission to assess PG&Es future compliance with record
retention requirements.
III.
Conclusion
The Commission should require PG&E to implement the five recommendations above, as
well as the recommendations of TURN and SED.
6
D-7
ATTACHMENT A
Summary of The Minimum Federal Safety Standards (49 CFR Part 192) Regarding
Pipeline Assumptions
D-8
D-9
192.113
0.6
A-1
[2] 1.14 times the smallest measurement taken for pipe less than 20 inches in diameter. No more than
1.11 times the smallest measurement on pipe 20 inches or larger in diameter.
[1] For unknown pipe where tensile testing (In accordance with Section II-D of Appendix B) has been
conducted, use the lowest of: (A) 80% of the average yield strength determined by tensile testing; (B)
The lowest yield strength determined by tensile testing. If the pipe has not been tensile tested, then
use 24,000 psig.
0.4 to
0.72
192.125. Overall design pressure is limited to 100 psig in mains and services.
192.111
Copper
[1]
Plastic
192.109
192.121 & 192.123. Overall design pressure is limited to 100 psig, or 125 psig for
thermoplastic pipe produced after 7/14/2004, or 200 psig for polyamide-11 (PA-11) pipe
produced after 1/23/2009.
E
Value
24,000
psi
Joint Factor
[E] (Code)
192.107(b)
[1]
F
Value
Steel
t
Value
S
Value
Type of
Pipe
Wall
Thickness
[t] (Code)
Yield
Strength
[S] (Code)
Design
Factor
[F]
(Code)

APPENDIX E
COMMENTS OF THE UTILITY REFORM NETWORK (TURN) ON
PG&ES INITIAL COMPLIANCE PLAN
Comments of The Utility Reform Network (TURN) on PG&Es Initial Compliance Plan
I.14-11-008, Distribution Recordkeeping OII
1.
Introduction
Pursuant to D.16-08-020 (p. 54), TURN submits this statement to identify its areas of
disagreement with PG&Es proposed compliance plan and, with respect to those areas of
disagreement, to present its alternative recommendations and supporting rationale. To the extent
that TURNs recommendations would alter PG&Es proposed compliance plan, TURN has
attached a redlined version of the affected PG&Es provisions to this statement. Before
presenting its alternative recommendations, TURN will briefly summarize its perspective on
aspects of PG&Es proposed plan that benefited from the mandated meet and confer process.
2.
The Meet and Confer Process Yielded Some Beneficial Changes and Compromises
As noted in Appendix B, two meet and confer sessions were held, and TURN participated
in both. From TURNs perspective, PG&E and all parties involved took seriously the goal of
developing a comprehensive compliance plan that includes all feasible and cost-effective
measures necessary to improve PG&Es natural gas distribution recordkeeping. (D.16-08-020,
p. 54). PG&E accepted some proposals and recommendations from the parties and agreed to
modify some of its proposed remedies in response to concerns raised by the parties. Of
particular note, PG&Es changes to its plan in response to issues identified by TURN included
the following:
3.
PG&E agreed to add to its proposed compliance plan appropriately re-worded versions of
remedies 6 through 9 from the Recordkeeping OII (I.11-02-016). These appear as
remedies 5 through 8 in PG&Es proposed plan in Appendix A and obligate PG&E to
extend improved recordkeeping management practices to its distribution records.
In proposed Remedy 13, Section C, PG&E added an acceptable definition of kept with
the record, which will help to document PG&Es obligation to keep information about
corrections accessible to all users.
Proposed Remedy 24 reflects a compromise among the parties to clarify PG&Es
obligations with respect to preparation of a report to determine if anything more can be
done to identify unmapped plastic inserts in PG&Es distribution system.
TURNs Recommended Changes to PG&Es Proposed Plan
Despite earnest participation by all, the parties were not able to agree on a proposed
compliance plan that addressed all parties concerns. Following are the minimum changes to
PG&Es proposed plan that TURN sees as necessary. TURN has reviewed ORAs additional
recommendations and SEDs statement and supports those as well.
1
E-1
a.
Consistent with Recordkeeping OII Remedy 12, PG&E proposed Remedy 11

should obligate PG&Es distribution recordkeeping practices to meet the
traceable, verifiable, and complete standard.
PG&Es proposed Remedy 11 is derived from Recordkeeping OII (RK) Remedy 12,
but differs significantly. Here is PG&Es proposal:
PG&Es records management processes shall be managed and maintained to
support the safe operation and maintenance of the gas distribution system and to
retain physical and digital distribution pipeline records for the life of the asset.
(Italics added to highlight PG&Es departure from RK 12.)
The vague italicized language reflects a significant watering down of this remedy
compared to RK 12, which obligated PG&E to meet the traceable, verifiable and complete
standard. Here is TURNs recommendation, which modifies the proposed remedy to replicate
RK 12, adding only the word distribution:
PG&Es records management processes shall be managed and maintained in
accordance with the traceable, verifiable and complete standard, including
retention of physical and digital distribution pipeline records for the life of the
asset. (Underlining added to show changes to PG&Es proposal.)
To support this remedy, TURN further recommends that the following definitions be
added to the definitions for Remedy 11:
Traceable records are those which can be clearly linked to original information
about a pipeline segment or facility.
Verifiable records are those in which information is confirmed by other
complementary, but separate, documentation.
Complete records are those in which the record is finalized as evidenced by a
signature, date or other appropriate marking.
These definitions are drawn verbatim from PHMSAs May 7, 2012 Advisory Bulletin to
gas pipeline operators.1
TURNs justification for its recommendation is that PG&Es recordkeeping practices
should meet the same clear and well-defined traceable, verifiable and complete standard for
both its transmission and its distribution system. PG&E has been found to have committed
serious recordkeeping violations with respect to both systems; the records for both systems
should be managed to meet the same standards. Indeed, the results of PG&Es distribution

1
May 7, 2012 PHMSA Advisory Bulletin, Federal Register, Vol. 77, p. 26823.
2
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recordkeeping failures that prompted this OII show that such failures also can pose serious
threats to life and property. PG&Es proposed replacement language (in italics above) would
replace the clear traceable, verifiable and complete standard with vague language that sounds
good but ultimately does little more than restate PG&Es obligation under Public Utilities Code
Section 451. PG&E should not have two tiers of recordkeeping obligations robust and
enforceable standards for transmission records and vague and unenforceable standards for
distribution records.
In the meet and confer, PG&E contended that the PHMSA May 7, 2012 Bulletin is
directed at records to support calculation of MAOP and MOP. However, PG&E overlooks the
fact that, as a remedy for PG&Es transmission recordkeeping violations, the Commission has
required PG&E to apply the traceable, verifiable and complete standard to all transmission
records for all purposes, not just for calculation of MAOP and MOP. PG&E has failed to give a
good reason why transmission records and distribution records should be subject to different
standards.
TURN notes that, in the meet and confer sessions, we advocated similar changes be
made to proposed Remedies 13 and 15 to include the traceable, verifiable and complete language
from the RK analogs from which they were derived. While we continue to support such changes
to PG&Es proposed remedies, TURNs recommended change to proposed Remedy 11 would
apply the traceable, verifiable and complete requirement to all of PG&Es distribution
recordkeeping efforts, thus arguably rendering similar changes to proposed Remedies 13 and 15
less important.
b.
PG&E proposed Remedy 14 should be modified to require PG&E to follow the

Commissions stated guidance regarding how to apply conservative assumptions
when necessary records are missing or discarded
Proposed Remedy 14 is derived from RK 14 and addresses PG&Es obligations when

necessary records are missing or have been discarded. PG&E proposes:
When PG&E cannot locate records, it may apply conservative assumptions.
PG&E shall document any engineering-based assumptions it makes for data that
has been identified as missing or disposed of. Such assumptions must be clearly
identified and justified.
Here is TURNs recommendation, which restores important language that PG&E deleted
from RK 14:
When PG&E cannot locate records, it may apply conservative assumptions.
PG&E shall document any engineering-based assumptions it makes for data that
has been identified as missing or disposed of. Such assumptions must be clearly
identified and justified and, where ambiguities arise, the assumption allowing the
greatest safety margin must be adopted. (Underlining added to show changes to
PG&Es proposal.)
3
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Similar to TURNs recommendation above concerning proposed Remedy 11, TURNs

justification for this recommendation is that the underlined language provides a clear and
enforceable standard that should be equally applicable to PG&Es deficient transmission and
distribution records. As a basic matter of safety, TURN is puzzled why PG&E would object to a
requirement specifying that, when PG&Es own operating lapses have caused necessary records
to be unavailable, the company should choose an assumed value that provides the greatest safety
value.
In the meet and confer sessions, PG&E based its opposition to the underlined language
on its derivation from D.11-06-017, which was directed at records to support MAOP. However,
as with proposed Remedy 11, PG&E overlooks the fact that, as a remedy for PG&Es
transmission recordkeeping violations (RK 14), the Commission has required PG&E to apply the
greatest safety value standard to all transmission records for all purposes, not just for
calculation of MAOP. Again, PG&E has failed to give a good reason why transmission records
and distribution records should be subject to different standards, particularly when necessary
records are missing or have been discarded by PG&E.
c.
PG&Es compliance plan should include a commitment to accept shareholder

responsibility for the incremental costs of the remedies.
Even though the issue of shareholder responsibility for the costs of remedial safety
measures was expressly determined to be an issue to be addressed in this case,2 PG&Es
proposed compliance plan does not include any provision to address this issue. The Scoping
Ruling for this case specifies that, to the extent any remedial safety measures are ordered as a
result of this Investigation, the scope of the proceeding will include whether PG&E should be
authorized to seek ratemaking recovery of the cost of those measures in other proceedings.3
Now that the Commission is poised to adopt remedial safety measures, the adopted
compliance plan should make clear that, consistent with the remedies adopted in the
Recordkeeping OII, any incremental costs of the remedies adopted in this case should be
absorbed by shareholders and not eligible for rate recovery in future proceedings. Accordingly,
TURN recommends that the following provision be added to the compliance plan:
Consistent with the remedies ordered in the San Bruno Investigations, all
incremental costs to implement these remedies shall be paid by shareholders.
PG&E will retain the necessary records to demonstrate that all incremental costs
incurred to implement these remedies have been paid by shareholders. Upon
request, PG&E will promptly make such records available to the Commission and
parties. Incremental costs means costs that are incremental to the costs to
implement the remedies ordered in the San Bruno Investigations in D.15-04-024.
TURNs justification for this provision is based on the law and established Commission
precedent. On its face, the just and reasonable standard for utility rates in Public Utilities Code

2
3
Assigned Commissioners Scoping Memo and Ruling, April 10, 2015, p. 3.

Id.
4
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Section 451 does not allow utilities to charge ratepayers to remedy violations. Absent
extraordinary circumstances, it is simply not reasonable for a utility to impose on ratepayers the
costs to rectify the utilitys wrongdoing.
In D.15-04-024, the Fines and Remedies Decision for the three enforcement cases against
PG&E in the aftermath of the San Bruno explosion, the Commission applied this basic precept as
follows: Finally, we reiterate that, since these remedies are to cure violations found in the San
Bruno Violations Decision, Recordkeeping Violations Decision and Class Location Violations
Decision, all remedies are to be paid for by shareholders.4 The fundamental proposition that
shareholders, not ratepayers, should pay the costs of remedial work to correct violations was not
challenged by PG&E and otherwise not controversial in those cases. Here too, PG&E
shareholders should be required to take financial responsibility for any incremental costs to
remedy the companys distribution recordkeeping violations.
In the meet and confer sessions, PG&E contended that the issue of financial
responsibility for the costs of the remedies is outside the scope of this case. This assertion is
plainly incorrect, as shown by the language from the Scoping Ruling quoted above. PG&E also
relied on the following sentence from D.16-08-020, p. 53: The [compliance] plan could also be
useful for general rate cases to ensure that safety is prominently addressed. PG&Es reliance on
this sentence is completely misplaced as the sentence, on its face, does not address whether or
not shareholders should be responsible for costs of remedial safety measures in the compliance
plan. The sentence merely points out that the remedies in the compliance plan could provide one
useful yardstick for assessing the safety of PG&Es operations, a fact that has nothing to do with
cost responsibility.
To attempt to assess the financial import of this issue, TURN asked PG&E to provide an
estimate of the incremental costs of the remedies in its proposed compliance plan. PG&E stated
that it was unable to provide such an estimate. In response to TURNs follow-up inquiry, PG&E
did not provide even a ballpark estimate. It would seem then that PG&Es refusal to accept
financial responsibility for the costs to remedy its distribution recordkeeping violations is a
matter of principle. However, PG&E is clearly on the wrong side of this principle, as it would
be patently unreasonable for ratepayers to be required to pay the costs to remedy PG&Es
violations.
4.
Conclusion
For the reasons set forth above, TURN requests that the Commission order PG&E to
modify its proposed compliance plan based on TURNs foregoing recommendations.
TURN assumes that, by allowing parties to submit statements (such as this one) of
disagreements with PG&Es proposed plan, the Commission intends to pass judgment on these
statements and order PG&E to modify the plan to the extent the Commission agrees with the

D.15-04-024, pp. 103-104.
5
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dissenting statements. If parties seeking changes to PG&Es proposed plan are required to take
some other step to formally request modifications,5 TURN requests that it be so informed.
TURN appreciates the opportunity to present this statement.
Date: December 13, 2016
Respectfully submitted,
By:
__________/s/______________
Thomas J. Long
Thomas J. Long, Legal Director

THE UTILITY REFORM NETWORK
785 Market Street, Suite 1400
Phone: (415) 929-8876 x303
Email: TLong@turn.org
TURN is unsure of the meaning of the following sentence on p. 54 of D.16-08-020: Parties may
request that this proceeding be reopened if needed to ensure proper implementation. This sentence
appears to relate to the implementation of the adopted remedies, not the fashioning of the remedies.
However, if TURNs interpretation is incorrect and a request to reopen is necessary to seek changes to
PG&Es proposed remedies, then TURN hereby requests that the proceeding be reopened to consider the
changes to PG&Es proposed remedies recommended by TURN and by other parties.
6
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Attachment to
Comments of The Utility Reform Network (TURN) on PG&Es Initial Compliance Plan
I.14-11-008, Distribution Recordkeeping OII
Redline Showing TURNs Recommended Changes

to PG&E Proposed Remedies 11 and 14
7
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I.14-11-008
OCTOBER 2016
Remedy 11
A.
REFERENCE
I.12-01-007; I.11-02-016; I.11-11-009,COMPLIANCE PLAN (D.15-04-024), JUNE 8, 2015 Record Keeping OII #12
B.
REMEDY
PG&Es records management processes shall be managed and maintained in accordance

with the traceable, verifiable, and complete standard, including retention of to support
the safe operation and maintenance of the gas distribution system and to retain physical
and digital distribution pipeline records for the life of the asset.
C.
REMEDY TERMS
DEFINED
Records are defined as records contained in PG&Es job files. See Remedy #15 for the
definition of job files, which consists of both as-built and non-as-built records.
Life of the asset is defined to begin at the time the asset becomes operational and end at
the point at which the gas distribution asset is retired from operations.
Traceable records are those which can be clearly linked to original information about a
pipeline segment or facility.
Verifiable records are those in which information is confirmed by other complementary,
but separate, documentation.
Complete records are those in which the record is finalized as evidenced by a signature,
date or other appropriate marking.

8
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I.14-11-008
OCTOBER 2016
Remedy 14
A.
REFERENCE
I.12-01-007; I.11-02-016; I.11-11-009,COMPLIANCE PLAN (D.15-04-024), JUNE 8, 2015 Record Keeping OII #16 a,b,c
B.
REMEDY
The information that was contained in PG&E's historic records and documents, and that
has been identified as 'missing or disposed of,' and is necessary to be retained for the safe
operation of the pipelines shall be recovered.
When PG&E cannot locate records, it may apply conservative assumptions. PG&E shall
document any engineering-based assumptions it makes for data that has been identified
as missing or disposed of. Such assumptions must be clearly identified and justified
and, where ambiguities arise, the assumption allowing the greatest safety margin must be
adopted.
9
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APPENDIX F
COMMENTS OF PG&E ON THE INITIAL COMPLIANCE PLAN
AND DIFFERENT AND ADDITIONAL REMEDIES PROPOSED BY
SED, ORA, AND TURN
Gas Distribution Remedies OII

Compliance Plan Feedback (Received through December 14, 2016)
PURPOSE: The purpose of Appendix F is to provide a summary of all remedies considered by PG&E in putting
together its Initial Compliance Plan, the written comments received by participants in the meet and confer
process and an explanation of PG&Es position regarding those comments.
ORGANIZATION: Appendix F is organized into three tables. Table 1 summarizes remedies proposed by parties
during the Gas Distribution Records OII (I.14-11-008) proceeding, but not acted on in the Commissions Decision
(D). 16-08-020. Table 2 provides a summary of the Gas Transmission Record-Keeping OII remedies reviewed by
PG&E and discussed with parties during the meet and confer process. Table 3 is a list of parties general
comments received by PG&E during the meet and confer process that do not map to a specific remedy. To
facilitate use of the tables, note that column 1 is numbered consecutively across the three tables. As PG&Es
comments refer to remedies found in each table, use the Item Number (Column 1) to locate the referenced
remedy.
Table 1 is organized chronologically by Column 3 of the table, the originally proposed remedy. During the
proceeding, P. Woods and Associates (PWA), the SEDs consultant, and then SED and other parties proposed
remedies.
Table 2 is organized chronologically by Column 3 of the table, the list of Gas Transmission Record-Keeping
Remedies. If Remedies were proposed during the proceeding or in the Gas Transmission Record-Keeping OII
proceeding and adopted by PG&E in its Gas Distribution Compliance Plan, Column 2 provides the Gas Distribution
Record-Keeping Remedy number. In both tables, the exact text of parties comments received during the meet
and confer process is shown in Columns 5 through 8. PG&E received no written input from Carmel-by-the-Sea
during the meet and confer process. Column 9 identifies whether PG&E has adopted the remedy and provides
PG&Es position on parties comments.
Table 3 provides a summary of general comments provided by parties during the Meet and Confer Process or
received prior to PG&Es submittal of its Gas Distribution Compliance Plan.
LOCATION OF PG&E POSITION ON COMMENTS PROVIDED BY SED:
1. Comprehensiveness of Remedies: Rows 1-60 (Tables 1-3) for all remedies considered. Appendix A, page 1
for methodology utilized.
2. Issues Identified in Audits: Row 51 (Table 2)
3. Use of Should vs. Will: Row 40 (Table 1)
LOCATION OF PG&E POSITION ON COMMENTS PROVIDED BY ORA:
1. Traceable, Verifiable and Complete Records: Row 41, et seq. (Table 2) and Row 59 (Table 3)
2. Conservative Assumptions: Row 43 (Table 2)
3. Workshops on Unmapped Plastic Inserts: Row 60 (Table 3)
4. Record Retention Schedule: Appendix A-1 for copy of Record Retention Schedule.
LOCATION OF PG&E POSITION ON COMMENTS PROVIDED BY TURN:
1. Traceable, Verifiable and Complete Records: Row 41, et seq. (Table 2)
2. Remedy 14: Conservative Assumptions: Row 43 (Table 2)
3. Shareholder Funding of Remedies: Row 27 (Table 1)
F-1
F-2
N/A
N/A
22
N/A
21
(1)
20
(2)
Item
GD RecordKeeping
Remedy #
PWA #6
PWA #5
PWA #4
PWA#3
PWA#2
PWA #1
(3)
Originally
Proposed
Remedy #
Causal Analysis
Plastic inserts
Internal Audit
MAOP risk
assessment
Re-examine more
aggressive stub
removal
Examine costs
and benefits of
systematic
identification of
plastic inserts and
stubs
(4)
Remedy
Summary
(5)
SED Position
(6)
TURN Position
Table 1: Remedies Developed by Parties during the Proceeding but Not Adopted in the Decision
(7)
ORA Position
(8)
Carmelby-theSea
Adopted.
This is a not a
recommendation on which
PG&E can act.
This is a not a
recommendation on which
PG&E can act.
Not adopted in the

compliance plan as the
remedy does not address a
violation found in the
Decision. After receiving the
PWA report, PG&E assessed
its method for setting the
MAOP for some of its
distribution systems to
determine if it creates
additional risk and concluded
that it did not as PG&E
testified at hearing. PG&E
recognizes that if SEDs
Application for Rehearing is
granted, its Initial Compliance
Plan may need to be
supplemented to address any
additional matters identified
at Rehearing.
Adopted.
Adopted.
(9)
PG&E Remedy Adoption

and Position on Parties
Comments
F-3
12
24
10
23
(1)
12
(2)
Item
GD RecordKeeping
Remedy #
SED d
SED c
SED b
SED a
(3)
Originally
Proposed
Remedy #
Plastic insert
proactive
program
evaluation
GIS validation
review
Report on
systemic review
covered by
previous remedy
(Remedy 12)
Systemic review
of records
(4)
Remedy
Summary
SED also believes that PG&E

should avoid using permissive
language in its
Compliance Plan. For
example, each instance of the
word should that appears
SED (d): The intent is for

PG&E to conduct a risk study
on its need to establish a
separate proactive program
to address unknown plastic
inserts, in addition to its
current use of the Gas Carrier
Checklist and Continental
Bolt on Tee. This would
include a feasibility analysis
and/or benchmarking.
SEDs comments on this

remedy were provided as part
of their comments on Remedy
14 (row 45)

of their comments on Remedy
14 (row 45)
(5)
SED Position
The proposed remedy

language should change
evaluate the need for to
implement. PG&E needs to
explain why such a program
should not be implemented.
(6)
TURN Position
The phrase should evaluate

the need for should be
replaced with shall
implement. Similar to
TURNs concern, simply
evaluating the need for a
program provides the
potential for avoiding the
responsibility of
implementing measures that
could prevent incidents such
as the ones listed in
D.16-08-020. Additionally,
PG&E should provide a
timeframe for when it will file
a report on the program. It
does not have to be the
90 days after the Commission
There needs to be an
explanation of why the
language concerning
comparing meter data in
CC&B to GD GIS was struck.
(7)
ORA Position
(8)
Carmelby-theSea
Gas Distribution Remedies OII Compliance Plan Feedback (Received through December 14, 2016)
(Continued)
PG&E declined to adopt ORA

and TURNs request that
PG&E implement whatever is
found in the benchmarking.
At this time, the benefit of a
program to identify unknown
plastic inserts in the gas
distribution system is
unknown. PG&Es existing
back stop measure of the
pipeline carrier checklist was
identified by PWA as an
effective practice to address
unmapped plastic inserts.
PG&E will evaluate the need
for such a program and
Adopted.
Adopted.
The language regarding

comparing meter data in
CC&B to GD GIS was not
struck; it was moved. PG&E
includes the language
regarding comparing its
Customer Care and Billing
(CC&B) records and its GD
GIS records in Remedy 12.
Adopted with modification to

make feasible removed to
ensure that all of its facilities
are accounted for.
Adopted.
(9)

Comments
F-4
N/A
N/A
12
13
(1)
See Row 2,
Remedy 21
(2)
Item
11
GD RecordKeeping
Remedy #
SED g
SED f
SED e
(3)
Originally
Proposed
Remedy #
Distribution
MAOP
identification
Excavation
damage
prevention
Stub
identification
(4)
Remedy
Summary
PG&E should include the

remedial measures
recommended by SED
regarding the documentation
of the MAOP across PG&Es
in
Remedy 24 should be
changed to the word will.
This improves the
enforceability of
the Compliance Plan by
preventing future disputes
regarding whether a
particular aspect
of a given remedy was
mandatory.
(5)
SED Position
(6)
TURN Position
decision, as was struck from

this draft, but should identify
a time frame sufficient for
PG&E to prepare the file a
report.
(7)
ORA Position
(8)
Carmelby-theSea
(Continued)
Not adopted. SED g (MAOP):

Establishing distribution
system MAOP was not an
issue identified in the
decision as needing a
Not adopted. PG&E did not

include this remedy because
the Decision did not make a
finding that PG&Es damage
prevention program was
deficient.
Not adopted. This remedy is

duplicative of PWA #2. PG&E
agreed to adopt PWA #2, in
lieu of this remedy.
During the meet and confer

process parties requested
that PG&E change language
in Remedy 24 from should
to must. PG&E agreed.
Specifically with respect to
Remedy 24, PG&E adopted
SEDs language as proposed
during briefing. Further,
PG&E uses words like will
and must in Section E,
which is the Compliance
Action and Schedule section
of each remedy template.
PG&Es compliance plan for

this remedy provides a
timeframe for when it will file
its report.
document its findings in a

report that will be submitted
to the SED.
(9)

Comments
F-5
GD RecordKeeping
Remedy #
(2)
Item
(1)
(3)
Originally
Proposed
Remedy #
(4)
Remedy
Summary
gas distribution system. One

of the key issues of
I.14-11-008 is that PG&E did
not have proper MAOP
documentation for a number
of its gas distribution lines.
Therefore, it seems prudent
that the Compliance plan
recommended by SED, which
include:
1. Identifying all of the
facilities in its distribution
system in which PG&E
applied its alternative
method of using post1970 leak survey records
to establish the MAOP.
PG&E should provide a
final list of these systems.
2. PG&E should conduct a
risk analysis and
demonstrate its basis to
conclude that the
method it used for
setting the MAOP on the
approximately 243
distribution systems do
not create any additional
safety risk. PG&E should
provide a report to the
Commission describing
the risk analysis
performed and the
conclusions derived from
that analysis.
(5)
SED Position
(6)
TURN Position
(7)
ORA Position
(8)
Carmelby-theSea
(Continued)
As documented in the
proceeding, both in
testimony and in PG&Es
Reply Brief, PG&E conducted
a risk analysis and concluded
that PG&Es method for
setting MAOP did not create
additional safety risk. While
MAOP was not identified as a
safety issue in the Decision,
PG&Es criteria for

establishing remedies is
documented in the cover
page of Appendix A (initial
compliance plan). That
criteria PG&E applied
includes that the remedy
address an issue raised in the
decision as needing a
remedy. The Decisions
Finding of Fact 11 stated,
PG&Es conduct after
discovering in the 1970s that
it was missing needed
distribution system highest
operating pressure paper
records from 1965 to 1970
included promptly admitting
that the records were
missing, diligently albeit
unsuccessfully searching for
the missing records,
analyzing and obtaining best
available replacement
records, and openly
disclosing the replacement
records to regulators.
remedy.
(9)

Comments
F-6
(1)
N/A
N/A
N/A
N/A
15
16
17
18
N/A
(2)
Item
14
GD RecordKeeping
Remedy #
Carmel #4
Carmel #3
Carmel #2
Carmel #1
SED h
(3)
Originally
Proposed
Remedy #
Independent
review of PG&Es
safety culture
Safety and leak

performance
incentives
Safety and leak

intervenor
Executive
bonuses
Distribution
MAOP risk
analysis
(4)
Remedy
Summary

of their comments on SED g
above ( row 13)
(5)
SED Position
(6)
TURN Position
(7)
ORA Position
(8)
Carmelby-theSea
(Continued)
This is both outside the scope

of the proceeding and is not
an issue identified in the

Decision as needing a
remedy.

remedy.

remedy.
PG&E performed the actions

outlined in this remedy prior
to hearings and found no
additional safety risk (see
PWA 3 above).
For purposes of this

Compliance Plan, PG&E will
modify the remedies if
necessary based on the
Commissions Decision on
SEDs pending Application for
Rehearing.
PG&E remains committed to

working with its regulator to
identify and resolve safety
issues.
(9)

Comments
F-7
N/A
N/A
N/A
See row 2,
Remedy 21
N/A
N/A
23
24
25
26
27
N/A
21
22
N/A
20
(1)
N/A
(2)
Item
19
GD RecordKeeping
Remedy #
TURN #5
TURN #4
TURN #3
TURN #2
TURN #1
Carmel #8
Carmel #7
Carmel #6
Carmel #5
(3)
Originally
Proposed
Remedy #
(8)

remedy.

remedy.

remedy.
Not a recommendation on
which PG&E can act.
remedy.
(9)
Duplicative of SED g and h.

Not adopted.
Remedies to be
Duplicative of PWA #2/SED e,

which PG&E adopted.
MAOP
Identify and map

unmapped stubs
Duplicative of SED d, which

PG&E adopted.
(7)
ORA Position
Identify and map

plastic inserts
Proposed New Remedy:
(6)
TURN Position

Comments
Consistent with the

Decisions order. PG&E
reviewed the Transmission
OII remedies, adopting 12.
Four remedies were added
during the meet and confer
process bringing the total
adopted Transmission OII
remedies to 16.
(5)
SED Position
Carmelby-theSea
Adopt the 21
Transmission OII
remedies
Fines and
penalties should
be paid with
shareholder
money
Compensation for
Carmel
Order additional
safety remedies
Finding that PG&E

caused the
release of
methane gas
(4)
Remedy
Summary
(Continued)
F-8
GD RecordKeeping
Remedy #
(2)
Item
(1)
(3)
Originally
Proposed
Remedy #
paid by
shareholders
(4)
Remedy
Summary
(5)
SED Position
To attempt to assess the

financial import of this issue,
TURN asked PG&E to provide
an estimate of the
incremental costs of the
remedies in its proposed
compliance plan. PG&E
stated that it was unable to
provide such an estimate. In
response to TURNs follow-up
inquiry, PG&E did not provide
even a ballpark estimate. It
would seem then that PG&Es
refusal to accept financial
responsibility for the costs to
TURN proposes the addition

of the following remedy,
consistent with TURNs
testimony in this case:
Consistent with the remedies
ordered in the San Bruno
Investigations, all costs to
implement these remedies
shall be paid by shareholders.
PG&E will retain the
necessary records to
demonstrate that all costs
incurred to implement these
remedies have been paid by
shareholders. Upon request,
PG&E will promptly make
such records available to the
Commission and parties.
Incremental costs means
costs that are incremental to
the costs to implement the
remedies ordered in the San
Bruno Investigations in D.1504-024.
(6)
TURN Position
(7)
ORA Position
(8)
Carmelby-theSea
(Continued)
This proceeding is an
investigation and not a costrecovery proceeding. In
developing this compliance
plan, PG&E focused on
remedy development, not
cost estimating the
implementation of the plan.
Unlike the San Bruno
Penalties Decision, this
Decision (D.16-08-020) did
not determine that the
compliance plan activities be
paid by shareholders. The
decision states on p. 53 that,
We find that a
comprehensive assessment
of the remedial proposals is
needed to develop a costeffective and feasible
compliance plan. Such a plan
must involve all interested
parties and have a shared
view of the need for safe
operation of the natural gas
distribution system. The plan
could also be useful for
general rate cases to ensure
that safety is prominently
addressed.
(9)

Comments
F-9
(1)
18
(2)
Item
28
GD RecordKeeping
Remedy #
GD
Records
OII #1
(3)
Originally
Proposed
Remedy #
Validate that
records
reasonably
represent asset
location
(4)
Remedy
Summary
(5)
SED Position
remedy its distribution

recordkeeping violations is a
matter of principle.
However, PG&E is clearly on
the wrong side of this
principle, as it would be
patently unreasonable for
ratepayers to be required to
pay the costs to remedy
PG&Es violations.
(6)
TURN Position
The compliance action should

be expanded and the
schedule should include
language requiring personnel
to perform validation
measures in the field during
routine maintenance. The
goal is that if field technicians
are already at a site to check
the meter, they should also
check an as built and locater
wire to confirm the site and
adjacent sites match the asbuilts. This is consistent with
PG&Es overall message of
find it, and fix it.
(7)
ORA Position
(8)
Carmelby-theSea
(Continued)
PG&E commits to continue to

use its Gas Map Correction
procedure and when
conditions are found in the
PG&E did not adopt ORAs

request as written because of
cost effectiveness and
feasibility issues. Personnel
performing routine
maintenance are not
qualified to perform
suggested tasks and do not
use as-built records when
performing tasks. The ORA
recommendation further
requires renegotiation of
labor agreements.
PG&E created the following

remedy , consistent with the
order to develop more or
different remedies where
cost effective and feasible:
Validate that as-built main
and gas service records
reasonably represent asset
location and that locating
wire is functional.
(9)

Comments
F-10
(1)
19
(2)
Item
29
GD RecordKeeping
Remedy #
GD
Records
OII #2
(3)
Originally
Proposed
Remedy #
Formalize gas
carrier pipe
checklist and
Continental BoltOn fitting
(4)
Remedy
Summary
(5)
SED Position
(6)
TURN Position
(7)
ORA Position
(8)
Carmelby-theSea
(Continued)
PG&E created the following

remedy, consistent with the
order to develop more or
different remedies where
cost effective and feasible:
Formalize the role of Gas
Carrier Pipe checklist and the
use of the Continental BoltOn fitting in a work
procedure that is part of the
O&M Manual.
field that do not match

records, submit mapping
correction requests through
CAP.
(9)

Comments
F-11
N/A
31
32
33
34
(1)
(2)
Item
30
GD RecordKeeping
Remedy #
RK#5
RK#4
RK#3
RK#2
RK#1
(3)
Originally
Proposed
Remedy #
Records
management
system
Records and
Information
Management
(RIM) training
program
Corporate policy
and standard on
recordkeeping
Rejected by the
Commission
Level 3
Information
Maturity score
(4)
Remedy
Summary
a. PG&E historically used

paper forms to document its
operations and maintenance.
b. There are still paper
records currently used in Gas
RK OII #5: PG&E defines

systems in C (Remedy
Terms Defined) as electronic
systems that store records,
which is more limiting than
what is required in D.1504
024. The Decision required
development and
deployment of systems
necessary to manage,
maintain, access and
preserve records (physical
and electronic, in all formats
and media types).
N/A
(5)
SED Position
N/A
(6)
TURN Position
(7)
ORA Position
PG&Es gas distribution

record keeping practices
should match the rigor of
practices used for
documenting the gas
transmission system. If a
particular practice has been
deemed necessary for the gas
transmission system, then a
similar practice should be
implemented for the gas
distribution system. The
consistency across systems
would help if workers from
the gas distribution system
have to transfer to the gas
transmission system or vice
versa. Similarly, PG&E should
keep the term traceable,
verifiable and complete in
N/A
Table 2: Gas Transmission Record-Keeping OII Remedies Reviewed to Develop the Compliance Plan
N/A
(8)
Carmelby-theSea
(Continued)
The Commissions decision in

this proceeding, D.
16-08-020, did not require
that PG&E wholesale adopt
the remedies from
D.15-04-024. D.16-08-020
requires in OP2 that
participates begin their
review with Exhibit E of
D.15-04-024 to evaluate
those measures and to
determine, whether more or
different requirements are
needed for the gas
distribution system. Based
on the facts of the case,
summarized below, the
issues in the decision and the
Adopted.
Adopted
Adopted.
N/A
Adopted.
(9)
PG&E
F-12
(1)
(3)
Originally
Proposed
Remedy #
(4)
Remedy
Summary
(5)
SED Position
Note 1: 8/3/2015 PWA

interview of Division Gas
Crew Foreman David
Pacheco.
Distribution Operations
1
(i.e. Gas Carrier Checklist)
that are uploaded to SAP.
c. As such, PG&E needs to
determine final disposition of
paper records filled out by
field crews, and ensure
accurate transcription of
information/data into the
electronic system or
database.
Id. at 2-11:25-29 (PG&E Reply Testimony, Singh).

Ex. 1 at 59 (PWA Report).
(2)
Item
GD RecordKeeping
Remedy #
(6)
TURN Position
remedies 4, 11, 13, and 15.

This term is defined by
PHMSA and 4reflect best
practices in record keeping
regardless of the system type
or application that these
terms are applied to.
Additionally, the
documentation must
demonstrate how it is
consistent with federal
regulations (including the use
of engineering assumptions
for unknown pipeline
features consistent with 49
Code of Federal Regulations
Section 192.105, 107, 109,
111, 113, and 115), state
regulations where they are
more stringent than the
federal regulations, and any
other CPUC guidance or
Order.
(7)
ORA Position
(8)
Carmelby-theSea
(Continued)
SAP includes an asset

management database that
contains equipment records,
These platforms include GD

GIS, which provides spatial
information about
distribution assets and
attributes of assets (e.g., size,
type, and location), along
with references to work
orders and gas service record
1
numbers. PWA called
PG&Es GD GIS system an
2
innovative practice.
PG&E reported in Reply

Testimony Chapter 2 on its
systems improvements. P. C24 of PG&Es brief
summarizes, PG&E has
already implemented a
number of technologies that
meet the intent of this
proposed remedy. These
platforms enable PG&E to
implement best practices for
standardizing recordkeeping
practices and improving its
asset data.
cost effectiveness and

feasibility elements of this
remedy, PG&E modified the
remedy.
(9)
PG&E
F-13
(1)
(3)
Originally
Proposed
Remedy #
(4)
Remedy
Summary
(5)
SED Position
(6)
TURN Position
(7)
ORA Position
Ex. 4 at 2-14:9-24 (PG&E Reply Testimony, Singh); id. at 4-11:28 to 4-14:16 (PG&E Reply Testimony, Trevino).
Ex. 1 at 56:3-5 (PWA Report).
(2)
Item
GD RecordKeeping
Remedy #
(8)
Carmelby-theSea
(Continued)
See Row 41, PG&Es entry for

GD Record-Keeping Remedy
PG&E reported throughout

the proceeding on its mobile
A form, eliminating paper
leak repair records and on its
controls, including its quality
management programs. See
PG&E Brief at p. 43 and 44.
maintenance history and

plans, gas leak data,
preventive and corrective
notifications, scheduling and
cost collecting orders,
material requisitions,
warehouse management,
financials, and cost
accounting, as well as an
inventory of data and
maintenance plans related to
regulation, valves, corrosion,
leak survey, and instrument
calibration for the gas
distribution system. SAP also
provides enhanced process
control measures for
monitoring the time to
complete mapping after
construction has been
3
completed. PWA found the
expanded use of SAP a
positive technology
4
addition.
(9)
PG&E
F-14
37
38
36
(1)
(2)
Item
35
GD RecordKeeping
Remedy #
RK#9
RK#8
RK#7
RK#6
(3)
Originally
Proposed
Remedy #
(8)
Adopted as part of meet and

confer process.
Adopted.
#11 for a discussion on

applying the gas transmission
traceable, verifiable and
complete standard to gas
distribution records.
(9)
PG&E
PG&E agrees with ORAs

input. PG&Es TD-4016S,
7/17/2013, Gas Operations
Records and Information
Management Standard,
provision 5.1 states that,
Records must meet legal,
regulatory and business
retention requirements.

confer process.
PG&E should specify the

duration of the document
retention period. At a
minimum the retention
period should match the rigor
of 49 CFR 192.709, which
requires that the information
pertinent to each repair
made to a transmission line
pipe must be retained for as
long as the pipe remains in
service. Furthermore, 49 CFR
192.709 requires that records
of each patrol, survey and
inspection should be retained
for at least 5 years or until
the next patrol, survey, or
inspection is completed,
whichever is longer.
Additionally, records
(7)
ORA Position
Retention periods
(6)
TURN Position

confer process.
(5)
SED Position
Carmelby-theSea
Consistent
standard
practices
Document
employees
responsible for
RIM
Senior
management
accountability
(4)
Remedy
Summary
(Continued)
F-15
10
11
40
41
(1)
(2)
Item
39
GD RecordKeeping
Remedy #
RK#12
RK#11
RK#10
(3)
Originally
Proposed
Remedy #
Traceable,
verifiable and
complete (TVC)
standard
Treatment of
active and
inactive records
Standards to
conform with RIM
policies
(4)
Remedy
Summary
(5)
SED Position
PG&E needs to explain why

its distribution records should
not meet the traceable,
verifiable, or complete
standard in light of D.12-12030, pp. 95-97, which views
this standard as a
fundamental indicator of
accurate and reliable records
and a basic requirement of
operating a gas system.
(6)
TURN Position

practices used for
documenting the gas
pertaining to pressure tests

must meet the criteria
established in 49 CFR
192.517, which states that
operators shall make, and
retain for the useful life of
the pipeline, a record of each
test performed under
192.505 and 192.507.
Records of tests performed
under 192.509, 192.511, and
192.513 must be maintained
for at least 5 years.
(7)
ORA Position
(8)
Carmelby-theSea
(Continued)
The TVC standard does not

apply to gas distribution. See
PHMSA Advisory Bulletin
(ADB201206), with the
subject Verification of
Records Establishing MAOP
and MOP. Gas distribution
systems operate at
considerably less than 20
percent of the maximum

remove transmission-specific
language, including the
transmission-specific
requirement that records be
complete (TVC).
Adopted.

confer process.
(9)
PG&E
F-16
(1)
(3)
Originally
Proposed
Remedy #
(4)
Remedy
Summary
(5)
SED Position
(6)
TURN Position

Additionally, the
documentation must
Section 192.105, 107, 109,
111, 113, and 115), state
Order.
(7)
ORA Position
PG&Es Reply Testimony, Chapter 5, Operational Improvements, Controls, and MAOP, p. 5-21 (Lines 4-15).
(2)
Item
GD RecordKeeping
Remedy #
(8)
Carmelby-theSea
(Continued)
PG&Es aspiration is to have

complete and accurate
records which is consistent
with TURN and ORAs input
Establishing a TVC standard

for gas distribution is a rulemaking activity, not a
compliance plan activity, and
should involve all
stakeholders state-wide.
record-keeping compliance
plan contains the appropriate
elements to effectively
address the elements of
TVCrecord retention,
standard elements for a job
file, and what action to take
when records are missing and
cannot be replaced including
the application of
conservative assumptions.
potential stress levels and

accordingly operate with a
5
significant margin of safety.
PHMSAs advisory applies to
gas transmission systems and
provides specific guidance on
the types of records
necessary to meet the
traceable, verifiable, and
complete standard applicable
to establishing MAOP and
MOP on gas transmission
systems.
(9)
PG&E
F-17
(1)
13
(2)
Item
42
GD RecordKeeping
Remedy #
RK#13
(3)
Originally
Proposed
Remedy #
Accuracy of
records
(4)
Remedy
Summary
a. RK OII # 13 requires
specific action to be taken by
PG&E when errors are
discovered.
b. SED (b) focuses on
RK OII #13 and SED (b)

address two different
requirements and should be
kept separate.
(5)
SED Position

this standard as a
(6)
TURN Position

practices used for
documenting the gas
(7)
ORA Position
(8)
Carmelby-theSea
(Continued)
PG&E has adopted RK#13 in

Remedy 13 and separately

complete (TVC). See row 41.
Finally, PG&E writes its

standards and procedures
consistent with the
philosophy ORA suggests - of
one standard for both
transmission and distribution
asset types, where possible.
PG&E agrees that similar
practices should be adopted
for both the gas transmission
and distribution assets to the
extent that the standards and
procedures in use apply to
both transmission and
distribution assets, such as
those standards regarding
record-keeping expectations.
Where the regulatory
requirements are different,
PG&E prepares different
standards and procedures.
regarding accurate and

reliable records. When we
dont have complete and
accurate records, we will
apply conservative
assumptions, as outlined in
Remedy 12.
(9)
PG&E
F-18
(1)
15
(2)
Item
43
GD RecordKeeping
Remedy #
RK#14
(3)
Originally
Proposed
Remedy #
Standard format
for job files
(4)
Remedy
Summary
Including RK OII #15

regarding job files being
readily accessible. SED
notes that PG&E does
mention standardization of
job files in RK OII #14
addressing the issue of

incomplete maps and
records, and making effective
use of various historical and
existing records, paper and
electronic, to proactively
identify distribution facilities
that may have not been
accounted for. This includes
the use of CAP to determine
the types of recordkeeping
issues reported by personnel
and to identify potential gaps
in the process.
(5)
SED Position

In addition to the above

comment regarding
complete records, PG&E
needs to explain why it does
not define kept with the
record, when PG&Es
proposed language would
include this term.
(6)
TURN Position

practices used for
documenting the gas

Additionally, the
documentation must
Section 192.105, 107, 109,
111, 113, and 115), state
Order.
(7)
ORA Position
(8)
Carmelby-theSea
(Continued)

PG&Es positions regarding

TURNs comment on D. 1212-030 and ORAs comment
on TVC records is addressed
in row 41. PG&E has further
developed Remedy 14 to
address actions to take when
gas distribution records are
missing.
PG&E agrees with TURNs

input regarding kept with
the record and added a
definition for kept with the
record to the remedy
template.
has adopted SED b in Remedy

23 (see row 8) with
modification to make
feasibleremoved to
ensure that all of its facilities
are accounted for.
(9)
PG&E
F-19
GD RecordKeeping
Remedy #
(2)
Item
(1)
(3)
Originally
Proposed
Remedy #
(4)
Remedy
Summary
(5)
SED Position

Additionally, the
documentation must
Section 192.105, 107, 109,
111, 113, and 115), state
Order.
this standard as a
PG&E proposed Remedy 14

should be modified to require
PG&E to follow the
Commissions stated
guidance regarding how to
apply conservative
assumptions
when necessary records are
missing or discarded
In addition to the above

comment regarding
complete records, the
proposed remedy provides
no standard for what types of
records should be included in
a job file.
(7)
ORA Position
(6)
TURN Position
(8)
Carmelby-theSea
(Continued)
PG&E further removed

transmission language
regarding assumptions
allowing the greatest margin
of safety because PG&Es
distribution systems operate
at considerably less than 20
percent of their maximum
potential stress levels and
accordingly operate with a
significant margin of safety.
The compliance action for

this remedy will result in
PG&E developing a specific
listing of the types of records
to be included in a job file.
PG&Es positions regarding

TURNs comment on D. 1212-030 and ORAs comment
on TVC records is addressed
in row 41. PG&E has further
developed Remedy 14 to
address actions to take when
gas distribution records are
missing.
complete (TVC). See row 41.
(9)
PG&E
F-20
(1)
45
14
N/A
(2)
Item
44
GD RecordKeeping
Remedy #
RK#16
RK#15
(3)
Originally
Proposed
Remedy #
Recover missing
information and
apply
conservative
assumptions
when records are
not recoverable
Job file data to be

immediately
accessible
(4)
Remedy
Summary
RK OII #16 directs PG&E to

recover historic records and
documents that had been
missing or disposed of and
are necessary for the safe
operation of pipelines. If such
records or documents cannot
be recovered, PG&E must
a. This should be included in

the Compliance Plan as it
relates to the immediate
accessibility of distribution
system job files to
appropriate operating
personnel.
b. The accessibility of the job
files is directly related to
PG&Es recordkeeping
practices.
RK OII #15: Job file data,

including drawings, for all
parts of the active PG&E gas
transmission system shall be
immediately accessible from
multiple locations. The
development of a complete
and accurate catalog of job
files that can be searched
immediately shall be included
with this objective.

regarding job files being
readily accessible. SED
notes that PG&E does
mention standardization of
job files in RK OII #14
(5)
SED Position
In its proposed language for

Remedy and Remedy
Terms Defined, PG&E needs
to explain why it has deleted
the language from RK OII
Remedy # 16, which seems
entirely applicable to and
necessary for addressing
(6)
TURN Position
Retain the term must

instead of should in the
Remedy section and explain
why recovery actions a, b,
and c in the previous edition
of the Remedy section were
removed from the latest
draft.
(7)
ORA Position
(8)
Carmelby-theSea
(Continued)
This remedy is the third in a

series that addresses
Adopted conservative
assumptions portion of
original remedy. Added
definition of record as a
result of meet and confer.
Not adopted Records

accessibility was not an issue
in this proceeding and not
raised in the decision.
(9)
PG&E
F-21
GD RecordKeeping
Remedy #
(2)
Item
(1)
(3)
Originally
Proposed
Remedy #
(4)
Remedy
Summary
a. In contrast, SED (a) is

meant to establish
knowledge of the types or
categories of distribution
system records that are
missing, using available
information such as CAP or
the previous mapping
correcting process, and then
determining if any categories
of missing records are of a
similar magnitude as the
missing De Anza records
discussed in this proceeding.
b. SED (c) specifically
addresses the issue of
inaccuracies in records. This
would require use of various
historical and existing
records, paper and
electronic, to proactively
identify inaccuracies and
then determine/identify the
types or categories of records
with inaccuracies.
c. PG&E should also leverage
information reported by its
field personnel and
CAP to determine these
categories of records and
identify potential gaps in
the process.
d. Essentially, SED (b) and (c)
may require similar activities
to determine completeness
(SED (b)) and accuracy (SED
apply conservative
assumptions.
(5)
SED Position
missing or disposed of
records relating to the
distribution system. As a
result, there are no
meaningful standards that
PG&E must meet for the
procedure referenced in
Compliance Action and
Schedule for when
conservative assumptions
should be applied. Any
procedure would satisfy the
language of this proposed
remedy.
(6)
TURN Position
(7)
ORA Position
(8)
Carmelby-theSea
(Continued)
PG&E does update its records

when it can recover them
(Remedy 12). In this Remedy
14, PG&E addresses records
that are missing and cant be
recovered by applying
conservative assumptions.
identifying missing records

(Remedy 12), correcting
errors when found (Remedy
13) and when records cannot
be recovered, applying
conservative assumptions,
this remedy.
(9)
PG&E
F-22
N/A
16 and 17
N/A
48
49
50
N/A
47
(1)
N/A
(2)
Item
46
GD RecordKeeping
Remedy #
RK#21
RK#20
RK#19
RK#18
RK#17
(3)
Originally
Proposed
Remedy #
10-year audit of
record-keeping
practices
Consolidating gas
mappers and
addressing known
challenges and
backlog of gas
maps
Centralized
database to track
re-used pipes
(TURN #1)
Identification of
salvaged and
reused pipes
Document
changes to
policies,
standards, and
procedures
(4)
Remedy
Summary
(c)) of the records.
(5)
SED Position
(6)
TURN Position
Please include RK OII#21 and

#22, with the appropriate
modifications, to have these
PG&E mentioned at the

10/24 meet and confer that
gas distribution pipe is not
salvaged and reused. If this is
the case, then the
Compliance Plan should
include an alternate remedy
that requires PG&E to
implement a procedure for
documenting instances and
reporting to the Commission
and parties to this
proceeding, in which a
distribution pipe segment is
found to have been salvaged
and reused.
(7)
ORA Position
(8)
Carmelby-theSea
(Continued)
Not adopted This is a

recommendation for another
party in the proceeding, not
RK#20 has many subremedies. After reviewing

the complete set, PG&E
adopted sub-remedies C.11
and D.19 into its compliance
plan.
Not adopted not an issue

raised in the proceeding or
decision.
Not adopted not an issue

raised in the proceeding or
decision. PG&E has not
historically used and does not
use today salvaged or reused
pipeline (as referenced in the
GT Records OII) in its gas
distribution system.
Not adopted PWA testified

that any violations in this OII
were not the result of
defective procedures (Ex. 1 at
1:22-23).
(9)
PG&E
F-23
(1)
N/A
(2)
Item
51
GD RecordKeeping
Remedy #
RK#22
(3)
Originally
Proposed
Remedy #
Correct
deficiencies
identified from
audits
(4)
Remedy
Summary
PG&E should adopt RK OII

#22 with modification: PG&E
will correct deficiencies in
recordkeeping it discovers as
a result of each SED audit (as
directed in D.1504024, RK
OII #21) that also apply to
distribution system
recordkeeping. PG&E will
include in its report to SED
when such deficiencies in its
distribution recordkeeping
have been corrected.

regarding correcting
deficiencies discovered
resulting from the SED audit
in RK OII #21 (from the
Transmission OII) applicable
to the distribution system.
PG&E should use the
experience and knowledge
gained from this future audit
to improve its distribution
recordkeeping processes.
(5)
SED Position
(6)
TURN Position
Please include RK OII#21 and

#22, with the appropriate
modifications, to have these
remedies applicable to the
gas distribution system and
to have the associated
reports sent to SED.
remedies applicable to the

gas distribution system and
to have the associated
reports sent to SED.
(7)
ORA Position
(8)
Carmelby-theSea
(Continued)
Not adopted. PG&E

completion of findings from
SED audits was not an issue
in the proceeding or the
decision. PG&E accepts SEDs
input and will use the
experience and knowledge
gained from the future audits
to improve distribution
record-keeping practices
where applicable, but does
not agree that a remedy is
appropriate.
PG&E.
(9)
PG&E
F-24
53
(2)
(1)
52
Comment
Number
Item
SED
SED
(3)
Party
Adopted inserted into
compliance plan text
Adopted See Appendix B
PG&E shall include in its final

submission to the Commission
a summary of the
recommendations received by
the parties, including PG&Es
position on why some
recommendation(s) were not
included in its final compliance
plan. PG&E has not provided
SED with adequate
justification for SED to
withdraw any of its previous
recommendations (including
those made in its Opening
Brief). Further, SED does not
agree with PG&Es premise
that an adverse Commission
finding regarding a specific
violation is a prerequisite for
enacting remedial measures
on that issue
(5)
Comment Adopted/Partially
Adopted/Not Adopted
Acknowledgment regarding RK
OII remedies (from the
Transmission OII) that are
implemented system wide and
are applicable to both
transmission and distribution
(4)
Comment
Table 3: General Comments that Do Not Apply to an Individual Remedy
SED proposed eight remedies. PG&E

adopted four of the remedies in the
compliance plan, acted on one of the
remedies prior to hearing, and rolled the
intent of one remedy into its adoption of
PWA 2.
PWA had six remedies. PG&E adopted all

but three, two of which were not directed at
PG&E.
PG&E did not include the following remedies

in its compliance plan:
This document summarizes

recommendations received by parties and
PG&E position on why some are not
included in the final compliance plan.
PG&Es compliance plan adopts relevant Gas
Transmission remedies, relevant parties
remedies, and introduces two new remedies
to comprehensively address the issues
raised in the decision.
PG&Es compliance plan text acknowledges

that some record-keeping remedies from
D.15-04-024 are applicable to both gas
transmission and distribution.
(6)
PG&E Response
(Continued)
F-25
(2)
(1)
54
Comment
Number
Item
ORA
(3)
Party
Finally, a section describing

the remedy intent should be
provided for each remedy,
even if one was not previously
included. These sections were
struck for remedies 12, 18, 19,
20, 21, 22, and 24. Retaining
such language provides clarity
in the event of questions
about the intent of a given
remedy, and whether it was
(4)
Comment
Partially Adopted
contemplated these sections
to add clarity, but ultimately
developed Section I GD RK
Issues Addressed
(5)
Adopted/Not Adopted
PG&E reintroduced the remedy intent

section Row I of Remedies 18 and 19, the
remedies PG&E developed. PG&E did not
contemplate developing the remedy
intent section for the Gas Transmission
Record-Keeping OII remedies as PG&E did
not develop the remedies and does not
know the authors intent. PG&E did
contemplate a remedy intent section as
described in ORAs comment, but chose to
develop Section I GD RK Issues Addressed
Carmels proposed remedies did not address

issues raised in the decision. In some
instances Carmels remedies required
parties other than PG&E to initiate the
action to implement. Finally, Carmel did not
identify any omissions on PG&Es proposed
remedies during this Meet and Confer
process.
As PG&E identified during briefing, TURNs

proposed remedies were largely duplicative
of SED proposed remedies. PG&E included
instead a combination of PWA and SED
remedies. TURN proposed that PG&E adopt
all of the Gas Transmission Record-Keeping
remedies. Instead, as directed by the
Commission in this decision, PG&E evaluated
each remedy, as described in the compliance
plan text for its applicability to distribution
and then its applicability to issues raised in
the decision.
(6)
PG&E Response
(Continued)
F-26
56
57
(2)
(1)
55
Comment
Number
Item
SED
SED
TURN
(3)
Party
PG&Es description of the

statements made at the meet
and confer does not constitute
an official record of such
statements. To the extent that
SED does not comment on a
given item, this does not
signify acceptance of PG&Es
description or position.
SEDs proposed remedial

measures are detailed in its
Opening Brief at pages 9496.
SEDs review of PG&Es
proposals does not constitute
SEDs acceptance of the
omission of any of SEDs
proposed remedial measures.
N/A
N/A
The language provided in the SED,

TURN, ORA, and Carmel columns is
written comments from parties received
between 10/30/2016 and 12/13/2016.
PG&E adopted SED a e. PG&E did not

adopt SED e g as those remedies address
items outside the decision. Pending the
outcome of SEDs Application for Rehearing
of D.16-08-2-2 PG&E will supplement this
compliance plan, as necessary
PG&E agrees.
Adopted remedy template

updated
General: Where applicable,

the phrase in Section I for
the proposed remedies should
be changed to read Maps is
GD GIS that do not match field
conditions. By omitting the
words do not, the phrasing
in the current draft does not
identify the problem that
needs to be addressed.
(6)
PG&E Response
to ground the remedies in the issues raised
in the decision.
(5)
Adopted/Not Adopted
proposed to comply with

federal or state regulations, to
implement best practices, or
for some other reason.
(4)
Comment
(Continued)
F-27
10
59
60
(2)
(1)
58
Comment
Number
Item
ORA
ORA
SED
(3)
Party
Partially adopted
Not adopted
Not adopted
Require PG&E to maintain

complete distribution records,
including provision of
quarterly compliance reports
regarding the costs of this
effort;
Hold additional workshops
regarding unmapped plastic
inserts in distribution
pipe
(5)
Adopted/Not Adopted
GD Records OII #3 suggests

alternate language:
a. PG&E shall validate that
records represent field
conditions.
b. In its procedures, PG&E
should describe how it
conducts these checks and the
criteria used (different records
may require different
tolerances).
(4)
Comment
During the two-year course of the I.14-11008 proceeding, a significant record was
developed, including a detailed report from
SEDs consultant PWA. That consultant
concluded that PG&E has identified effective
backstop measures regarding unmapped
plastic inserts. See PG&E Brief, Appendix C,
p. C-1. PG&E has agreed to conduct
benchmarking and to evaluate whether
there is anything more that can be done to
address unmapped plastic inserts, see
remedies 20 and 24 in Appendix A.
See row 41 of this Appendix for PG&Es

position on the gas transmission TVC record
standard.
PG&E ultimately developed Remedy 18 as

the feasible and cost effective method to
validate that records represent field
conditions.
(6)
PG&E Response
(Continued)

Pg&amp;e&#39;s Initial Compliance Plan 12-16-16

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Pg&amp;e&#39;s Initial Compliance Plan 12-16-16

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BEFORE THE PUBLIC UTILITIES COMMISSION

OF THE STATE OF CALIFORNIA

PACIFIC GAS AND ELECTRIC COMPANYS

Dated: December 16, 2016

BEFORE THE PUBLIC UTILITIES COMMISSION

PACIFIC GAS AND ELECTRIC COMPANYS

/s/ Elizabeth Collier

PACIFIC GAS AND ELECTRIC COMPANY

The Generally Accepted Records Keeping Principles (GARP) developed by ARMA

See PG&Es compliance plan activities for D.15-04-024

See PG&Es compliance plan activities for D.15-04-024

See PG&Es compliance plan activities for D.15-04-024

See PG&Es compliance plan activities for D.15-04-024

Missing records; Maps in GD GIS that do not match field conditions

As included in the Gas Transmission Remedy, 3 years concludes in April 2018.

PG&E shall issue a corporate policy and standard that will:

Information Management (IM) Compliance Department was reorganized as the Enterprise

See PG&Es compliance plan activities for D.15-04-024

See PG&Es compliance plan activities for D.15-04-024

See PG&Es compliance plan activities for D.15-04-024

See PG&Es compliance plan activities for D.15-04-024

See PG&Es compliance plan activities for D.15-04-024

See PG&Es compliance plan activities for D.15-04-024

Closed: August 24, 2015.

Gas Distribution Geographic Information System is the foundational system that

PG&E reported in I.14-11-008 Chapter 2 testimony on its GD GIS system conversion

PG&E shall establish accountability for development and implementation of a PG&E

PG&E defines senior management to be director and above.

See PG&Es compliance plan activities for D.15-04-024

See PG&Es compliance plan activities for D.15-04-024

See PG&Es compliance plan activities for D.15-04-024

See PG&Es compliance plan activities for D.15-04-024

PG&E defines implementation of the Gas Operations Records and Information

See PG&Es compliance plan activities for D.15-04-024

See PG&Es compliance plan activities for D.15-04-024

See PG&Es compliance plan activities for D.15-04-024

See PG&Es compliance plan activities for D.15-04-024

Standard practices is defined as policies, standards, and procedures

See PG&Es compliance plan activities for D.15-04-024

See PG&Es compliance plan activities for D.15-04-024

See PG&Es compliance plan activities for D.15-04-024

See PG&Es compliance plan activities for D.15-04-024

See PG&Es compliance plan activities for D.15-04-024

See PG&Es compliance plan activities for D.15-04-024

See PG&Es compliance plan activities for D.15-04-024

See PG&Es compliance plan activities for D.15-04-024

See PG&Es compliance plan activities for D.15-04-024

See PG&Es compliance plan activities for D.15-04-024

See PG&Es compliance plan activities for D.15-04-024

See PG&Es compliance plan activities for D.15-04-024

Records_12_AttachmentGas Operations Records Retention Schedule

Maps in GD GIS that do not match field conditions

GD Records OII SED #a, c

Maps in GD GIS that do not match field conditions

Document findings from the review with recommended actions.

Records_13_Attachment CAP Program Mobile Application Announcement

Expected Completion Date: 12/2/2019

Records_13_Attachment 4460P-11, Gas Map Corrections

Maps in GD GIS that do not match field conditions

Maps in GD GIS that do not match field conditions

Maps in GD GIS that do not match field conditions

Consider consolidating Gas Distribution Mappers to centralized location to facilitate

PG&E implemented this remedy as stated in testimony.

Address known challenges and backlog of Gas Maps.

Pg&e's Initial Compliance Plan 12-16-16

Pg&e's Initial Compliance Plan 12-16-16