ORA questions the reasonableness of the Decision Tree. It argues that certain projects in the proceeding were handled and tracked differently from others, using Playa Del Rey and Lines 42-66-1 and 42-66-2 as examples of projects with change orders and cost estimate revisions. In place of the “numerous” current Decision Tree, ORA advocates for a universal Decision Tree that applies to all of Applicants’ pipeline safety enhancement projects. ORA also suggests that Applicants be required to provide an explanation at each point in the Decision Tree that leads to the final outcome of each set of project costs. 6.3.2. PSEP Design and Construction Standards and Practices Applicants assert that PSEP is subject to guidelines and oversight designed to comply with their internal standards as well as applicable laws, regulations, and Commission orders. These include Code of Federal Regulations, Title 49, Part 192, as well as the standards articulated by the American Society for Mechanical Engineers, American National Standards Institute, American Petroleum Institute, and American Society for Testing and Materials. 6.3.3. PSEP Oversight and Controls Applicants claim that the PSEP Organization implemented a process whereby each project was initially managed in compliance with their existing policies overseen by PSEP Organization leadership, and the later projects were overseen by the PSEP PMO and the Commission’s Safety and Enforcement Division (SED). Additionally—and in conformity with D.14-06-007’s mandate that SED exercise oversight authority in order to observe and inspect the testing, maintenance, and construction of the pipeline system and related
ORA questions the reasonableness of the Decision Tree. It argues that certain projects in the proceeding were handled and tracked differently from others, using Playa Del Rey and Lines 42-66-1 and 42-66-2 as examples of projects with “numerous” change orders and cost estimate revisions. In place of the current Decision Tree, ORA advocates for a universal Decision Tree that applies to all of Applicants’ pipeline safety enhancement projects. ORA also suggests that Applicants be required to provide an explanation at each point in the Decision Tree that leads to the final outcome of each set of project costs. 6.3.2. PSEP Design and Construction Standards and Practices Applicants assert that PSEP is subject to guidelines and oversight designed to comply with their internal standards as well as applicable laws, regulations, and Commission orders. These include Code of Federal Regulations, Title 49, Part 192, as well as the standards articulated by the American Society for Mechanical Engineers, American National Standards Institute, American Petroleum Institute, and American Society for Testing and Materials. 6.3.3. PSEP Oversight and Controls Applicants claim that the PSEP Organization implemented a process whereby each project was initially managed in compliance with their existing policies overseen by PSEP Organization leadership, and the later projects were overseen by the PSEP PMO and the Commission’s Safety and Enforcement Division (SED). Additionally—and in conformity with D.14-06-007’s mandate that SED exercise oversight authority in order to observe and inspect the testing, maintenance, and construction of the pipeline system and related
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