The Joint Parties recommend that the provision in the gas safety citation program requiring notification of local officials is unnecessary, given the above publication requirement, and that this notification provision should be eliminated. Alternatively, the Joint Parties recommend that if the Commission maintains this notification provision for gas, the provision should not apply to the electric safety citation program. Similarly, the Joint Parties recommend that the provision requiring the gas utilities to report the citations to other state or federal authorities is unnecessary because the gas and electric utilities are subject to existing regulations, including federal reporting requirements. The Joint Parties recommend that this provision be eliminated from the gas safety citation program and not be extended to the electric safety citation program. The Joint Parties recommend that the gas safety citation program be modified so that the response time to a citation is 30 days (instead of the current 10 days), similar to the electric safety citation program. The Joint Parties further recommend that the burden of proof under the gas safety citation program be modified to reflect the burden of proof articulated in the electric safety citation program. Generally, if not specifically mentioned, the Joint Parties recommend that if the Commission chooses to harmonize both programs, the Commission should use the electric safety citation program as a model since that program was established through the rulemaking process, rather than by resolution. The Joint Parties believe that audits of the utilities every three years to monitor whether penalties are in fact paid by shareholders (as recommended by ORA) are unnecessary as these audits occur in the general rate cases. The Joint Parties recommends that the Commission conduct an independent review of the success of the citation programs during the initial years of implementation and improve the programs on the basis of such review and stakeholder input. The Joint Parties reiterate their request for workshops on many of the above issues and attach proposed workshop guidelines to their comments. In their reply comments the Joint Parties state they agree with the comments of the other utilities, specifically PG&E, SoCalGas/SDG&E, and CUE. The Joint Parties state that EPUC’s comments to include reliability issues are beyond the
The Joint Parties recommend that the provision in the gas safety citation program requiring notification of local officials is unnecessary, given the above publication requirement, and that this notification provision should be eliminated. Alternatively, the Joint Parties recommend that if the Commission maintains this notification provision for gas, the provision should not apply to the electric safety citation program. Similarly, the Joint Parties recommend that the provision requiring the gas utilities to report the citations to other state or federal authorities is unnecessary because the gas and electric utilities are subject to existing regulations, including federal reporting requirements. The Joint Parties recommend that this provision be eliminated from the gas safety citation program and not be extended to the electric safety citation program. The Joint Parties recommend that the gas safety citation program be modified so that the response time to a citation is 30 days (instead of the current 10 days), similar to the electric safety citation program. The Joint Parties further recommend that the burden of proof under the gas safety citation program be modified to reflect the burden of proof articulated in the electric safety citation program. Generally, if not specifically mentioned, the Joint Parties recommend that if the Commission chooses to harmonize both programs, the Commission should use the electric safety citation program as a model since that program was established through the rulemaking process, rather than by resolution. The Joint Parties believe that audits of the utilities every three years to monitor whether penalties are in fact paid by shareholders (as recommended by ORA) are unnecessary as these audits occur in the general rate cases. The Joint Parties recommends that the Commission conduct an independent review of the success of the citation programs during the initial years of implementation and improve the programs on the basis of such review and stakeholder input. The Joint Parties reiterate their request for workshops on many of the above issues and attach proposed workshop guidelines to their comments. In their reply comments the Joint Parties state they agree with the comments of the other utilities, specifically PG&E, SoCalGas/SDG&E, and CUE. The Joint Parties state that EPUC’s comments to include reliability issues are beyond the
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