Attachment 1). However, the Applicants subsequently learned that Line 1600 could be taken out of service with manageable customer impacts. Both ORA and POC argue that the Utilities must pressure test Line 1600 according to the Commission’s PSEP Decision, D.1406007. According to ORA: SoCalGas/SDG&E’s decision tree, as adopted by D.1406007, requires the Utilities to test Line 1600. The record shows that SoCalGas/SDG&E do not intend to test Line 1600. Since this constitutes a modification to a Commission decision, SoCalGas/SDG&E must request Commission approval to modify their decision tree, and parties to the proceeding should be provided notice of that request. (ORA Opening Brief at 70.) ORA questions the Applicants’ response to Footnote 5 that explains the Applicants’ original contemplation in their 2011 PSEP Plan to build a new line to allow for pressure testing rather than derating of Line 1600. ORA challenges this assertion and argues that, in making this statement, “SoCalGas/SDG&E have conflated their own decision making process with the Commission’s decision making process.” (ORA Reply Brief at 11.) Further, ORA believes that the Applicants have improperly elevated language in D.1406007 dicta to suggest that future applications would be an appropriate means to deviate from the specific direction established in the Decision Tree. Similarly, ORA believes that the Applicants have placed a heavier emphasis on “professional engineering judgment” beyond what D.140607 intended. POC states, “[t]he Commission should not vote as a part of this or any other process to modify the PSEP Decision Tree.” (POC Opening Brief at 37.) “This Application is an impermissible collateral attack on D.1406007.” (POC Opening Brief at 37.) It argues that the Applicants’ actions suggest that the Commission should ignore the Decision Tree or consider it modified. It further
Attachment 1). However, the Applicants subsequently learned that Line 1600 could be taken out of service with manageable customer impacts. Both ORA and POC argue that the Utilities must pressure test Line 1600 according to the Commission’s PSEP Decision, D.1406007. According to ORA: SoCalGas/SDG&E’s decision tree, as adopted by D.1406007, requires the Utilities to test Line 1600. The record shows that SoCalGas/SDG&E do not intend to test Line 1600. Since this constitutes a modification to a Commission decision, SoCalGas/SDG&E must request Commission approval to modify their decision tree, and parties to the proceeding should be provided notice of that request. (ORA Opening Brief at 70.) ORA questions the Applicants’ response to Footnote 5 that explains the Applicants’ original contemplation in their 2011 PSEP Plan to build a new line to allow for pressure testing rather than derating of Line 1600. ORA challenges this assertion and argues that, in making this statement, “SoCalGas/SDG&E have conflated their own decision making process with the Commission’s decision making process.” (ORA Reply Brief at 11.) Further, ORA believes that the Applicants have improperly elevated language in D.1406007 dicta to suggest that future applications would be an appropriate means to deviate from the specific direction established in the Decision Tree. Similarly, ORA believes that the Applicants have placed a heavier emphasis on “professional engineering judgment” beyond what D.140607 intended. POC states, “[t]he Commission should not vote as a part of this or any other process to modify the PSEP Decision Tree.” (POC Opening Brief at 37.) “This Application is an impermissible collateral attack on D.1406007.” (POC Opening Brief at 37.) It argues that the Applicants’ actions suggest that the Commission should ignore the Decision Tree or consider it modified. It further