Reasonableness Review: Operation SDG&E’s and Management of its Facilities Prior to the Guejito Fire In evaluating SDG&E’s operation and management of its facilities in connection to the Guejito Fire, the Commission must determine whether SDG&E employed reasonable judgment in its operation and management of its facilities in the period leading up to the ignition of the Guejito Fire. The record shows that SDG&E utilized its Corrective Maintenance Program to perform patrol and detailed (overhead) inspections of P196387 and P196394 prior to the Guejito Fire ignition. SDG&E asserts its failure to identify the 3.3 foot clearance violation merely shows the utility was not perfect; we disagree. SDG&E’s use of patrol and overhead inspection protocols may be reasonable. The repeated failure of these patrols to identify the clearance violation is not reasonable. While SDG&E’s testimony highlights its Corrective Maintenance Program, the existence of the Corrective Maintenance Program is not sufficient to establish that SDG&E fulfilled its duty to be a reasonable and prudent manager. At the same time, the lack of inspection records indicates a failure to act prudently. The fact that the Cox line was installed in 2001, 6 years before the fire, and that no inspection records affirmatively reference compliance with GO 95 clearance requirements is problematic. Moreover, we find the 6-year gap in inspection records (from 2001 to 2007) to be indicative of imprudent management. SDG&E asserts that to find its failure imprudent would be to interpret the prudence standard as a perfection standard. We disagree. Documentation of compliance with objective clearance standards at some point during the many years the Cox line was installed is not equivalent to perfection.
Reasonableness Review: SDG&E’s Operation and Management of its Facilities Prior to the Guejito Fire In evaluating SDG&E’s operation and management of its facilities in connection to the Guejito Fire, the Commission must determine whether SDG&E employed reasonable judgment in its operation and management of its facilities in the period leading up to the ignition of the Guejito Fire. The record shows that SDG&E utilized its Corrective Maintenance Program to perform patrol and detailed (overhead) inspections of P196387 and P196394 prior to the Guejito Fire ignition. SDG&E asserts its failure to identify the 3.3 foot clearance violation merely shows the utility was not perfect; we disagree. SDG&E’s use of patrol and overhead inspection protocols may be reasonable. The repeated failure of these patrols to identify the clearance violation is not reasonable. While SDG&E’s testimony highlights its Corrective Maintenance Program, the existence of the Corrective Maintenance Program is not sufficient to establish that SDG&E fulfilled its duty to be a reasonable and prudent manager. At the same time, the lack of inspection records indicates a failure to act prudently. The fact that the Cox line was installed in 2001, 6 years before the fire, and that no inspection records affirmatively reference compliance with GO 95 clearance requirements is problematic. Moreover, we find the 6-year gap in inspection records (from 2001 to 2007) to be indicative of imprudent management. SDG&E asserts that to find its failure imprudent would be to interpret the prudence standard as a perfection standard. We disagree. Documentation of compliance with objective clearance standards at some point during the many years the Cox line was installed is not equivalent to perfection.
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