required reporting to be submitted in 2020, Commission Staff will have sufficient additional information to evaluate the cost-effectiveness of each individual compliance plan and best practices.”); p. 72-73 (“Because not enough is known at this time about the full cost of many Best Practices or their ultimate effectiveness in reducing methane, the utilities are provided with significant flexibility to put their efforts and resources toward the most promising Best Practices, while allowing for continued research and/or pilot programs where appropriate.”) Best Practices General Verified – TURN supported the best TURN Comments, February 10, 2017, practices proposed by SED as a p. 1-2. result of the working group process. D.17-06-015, p. 66 (“SB 1371 does not The Commission amended that the Commission must require some of the proposed best each operator under its jurisdiction to practices, but agreed that SB implement the same detailed set of 1371 does not require mandatory Best Practices, as CUE and mandating the same set of Best EDF contend, with little or no ability to Practices to be implemented by tailor the Best Practices to fit an each gas corporation without operator’s unique system or to phase in any flexibility. or pilot Best Practices as warranted (ibid. at 2). 67-68 (“While we “); support increased stringency for the Best Practices, we also support some needed flexibility provisions in the Best Practices that allow utilities to submit requests and justification for exemption or modification of specific Best Practices as appropriate.”); Verified Best Practices Lead Surveys – (BP 15) TURN argued that BP 15 TURN Comments, May 6, 2016, p. 5-7. should not be mandated, but TURN Comments, Feb. 10, 2017, p. additional data should be gathered to analyze the relative
required reporting to be submitted in 2020, Commission Staff will have sufficient additional information to evaluate the cost-effectiveness of each individual compliance plan and best practices.”); p. 72-73 (“Because not enough is known at this time about the full cost of many Best Practices or their ultimate effectiveness in reducing methane, the utilities are provided with significant flexibility to put their efforts and resources toward the most promising Best Practices, while allowing for continued research and/or pilot programs where appropriate.”) Best Practices – General TURN supported the best practices proposed by SED as a result of the working group process. The Commission amended some of the proposed best practices, but agreed that SB 1371 does not require mandating the same set of Best Practices to be implemented by each gas corporation without any flexibility. TURN Comments, February 10, 2017, p. 1-2. D.17-06-015, p. 66 (“SB 1371 does not that the Commission must require each operator under its jurisdiction to implement the same detailed set of mandatory Best Practices, as CUE and EDF contend, with little or no ability to tailor the Best Practices to fit an operator’s unique system or to phase in or pilot Best Practices as warranted (ibid. at 2). “); 67-68 (“While we support increased stringency for the Best Practices, we also support some needed flexibility provisions in the Best Practices that allow utilities to submit requests and justification for exemption or modification of specific Best Practices as appropriate.”); Verified Best Practices – Lead Surveys (BP 15) TURN argued that BP 15 should not be mandated, but additional data should be gathered to analyze the relative TURN Comments, May 6, 2016, p. 5-7. TURN Comments, Feb. 10, 2017, p. Verified