wishes consistency between self-identified potential violations and other violations. We are not persuaded to impose a statute of limitations on issuing a citation based on a self-identified potential violation when we do not impose a statute of limitations on issuing a citation under the gas and electric safety citation program in general. As stated above, the Phase I Decision at 19-20 declined to impose a statute of limitations on the gas and electric safety citation program. D.15-05-054, the order modifying the Phase I Decision for purpose of clarification and denying rehearing, also addressed this general issue. In D.15-05-054 at 4-6, the Commission stated that PG&E appeared to be arguing that the Commission should have spelled out a specific time period for Staff to provide the utility with notice of a violation after discovering it. The Commission rejected this argument. The Commission recognized that § 1702.5(a)(2) requires that the Commission’s electric safety citation program include procedures ensuring that the Commission provides notice of a violation or violations within a reasonable period of time after discovery. However, the Commission also stated that there is express or implied language in § 1702.5 “no establishing the Legislature’s intent to create any type of time bar to the authorized citation,” and the fact that the Legislature did not define a amount of time” in § 1702.5(a)(2) shows the Legislature intended for “reasonable the Commission to make that determination. (Id. at 4-5.) For clarity, the Commission amended the procedural rules for the electric safety citation program to state that service of the citation shall be made within a reasonable period of time after the discovery of the violation. (Id. at 14.) We find this
wishes consistency between self-identified potential violations and other violations. We are not persuaded to impose a statute of limitations on issuing a citation based on a self-identified potential violation when we do not impose a statute of limitations on issuing a citation under the gas and electric safety citation program in general. As stated above, the Phase I Decision at 19-20 declined to impose a statute of limitations on the gas and electric safety citation program. D.15-05-054, the order modifying the Phase I Decision for purpose of clarification and denying rehearing, also addressed this general issue. In D.15-05-054 at 4-6, the Commission stated that PG&E appeared to be arguing that the Commission should have spelled out a specific time period for Staff to provide the utility with notice of a violation after discovering it. The Commission rejected this argument. The Commission recognized that § 1702.5(a)(2) requires that the Commission’s electric safety citation program include procedures ensuring that the Commission provides notice of a violation or violations within a reasonable period of time after discovery. However, the Commission also stated that there is “no express or implied language in § 1702.5 establishing the Legislature’s intent to create any type of time bar to the authorized citation,” and the fact that the Legislature did not define a “reasonable amount of time” in § 1702.5(a)(2) shows the Legislature intended for the Commission to make that determination. (Id. at 4-5.) For clarity, the Commission amended the procedural rules for the electric safety citation program to state that service of the citation shall be made within a reasonable period of time after the discovery of the violation. (Id. at 14.) We find this
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