that a 30-day period would allow adequate time to conduct necessary investigations and avoid the need to piecemeal submittals to Staff. Joint Parties recommend that the time period to self-report a violation after discovery be 30 days for both electric and gas utilities. Southwest Gas recommends a reporting requirement for what it terms safety-related violations, with violations disclosed to SED only on a pre-audit exceptions list. ORA opposes increasing the current 10-day reporting period for gas utilities, although it does not contest the 30-day period for electric utilities. The utilities suggest harmonizing the reporting time requirement for both gas and electric utilities, and argue that the current 10-day reporting period for gas is an insufficient amount of time for the utility to gather all the underlying facts and information necessary to carefully analyze the underlying violation and potential remedies and consult with SED to develop a thoughtful and thorough solution to the problem. As the report of self-identified violations should include a corrective action plan, SED agrees with this argument. SED agrees with the utilities’ recommendation that both gas and electric utilities be given 30 days to report self-identified potential violations. However, although SED is agreeable to a 30-day reporting period, SED encourages the electric and gas utilities to consult with SED Staff regarding a potential violation as soon as possible, even if it is only an initial cursory report with a subsequent official submission. SED emphasizes that a 30-day reporting period in no way relieves the utilities of their duty to implement corrective actions, and make their facilities safe as quickly as possible. Notification to City and County Officials Resolution ALJ-274 requires that gas corporations notify local authorities, including Chief Administrative Officer or similar authority in the city and county “the where a citation is issued” within 10 days of self-identifying a violation. The electric
that a 30-day period would allow adequate time to conduct necessary investigations and avoid the need to piecemeal submittals to Staff. Joint Parties recommend that the time period to self-report a violation after discovery be 30 days for both electric and gas utilities. Southwest Gas recommends a reporting requirement for what it terms safety-related violations, with violations disclosed to SED only on a pre-audit exceptions list. ORA opposes increasing the current 10-day reporting period for gas utilities, although it does not contest the 30-day period for electric utilities. The utilities suggest harmonizing the reporting time requirement for both gas and electric utilities, and argue that the current 10-day reporting period for gas is an insufficient amount of time for the utility to gather all the underlying facts and information necessary to carefully analyze the underlying violation and potential remedies and consult with SED to develop a thoughtful and thorough solution to the problem. As the report of self-identified violations should include a corrective action plan, SED agrees with this argument. SED agrees with the utilities’ recommendation that both gas and electric utilities be given 30 days to report self-identified potential violations. However, although SED is agreeable to a 30-day reporting period, SED encourages the electric and gas utilities to consult with SED Staff regarding a potential violation as soon as possible, even if it is only an initial cursory report with a subsequent official submission. SED emphasizes that a 30-day reporting period in no way relieves the utilities of their duty to implement corrective actions, and make their facilities safe as quickly as possible. Notification to City and County Officials Resolution ALJ-274 requires that gas corporations notify local authorities, including “the Chief Administrative Officer or similar authority in the city and county where a citation is issued” within 10 days of self-identifying a violation. The electric