combining the contribution to utility’s evidence, plus that from the proceeding. external sources to provide the Commission with a more CFC’s alleged complete perspective on how contributions on proposed PG&E’s this issue did expenditures fit into the not assist the broader, long-term context of Commission’s replacing the aging utility’s decisionmaking distribution system assets. process. CFC anticipated using the supplementary information Because of the CFC- Leak Management Corrective assembled to demonstrate that lack of Maintenance Expenses, pp. 3-6 planned expenditures PG&E’s substantial were both inconsistent with contribution on the long-term expense this issue, the trajectory required to sustain Commission the system in good condition, disallows 75% yet also presenting a of hours CFC’s expenditure spike claimed inconsistent with the avoiding regarding “Gas unnecessary rate-shock. Distribution Further, CFC examined the Maintenance reported incident causes Expenditures CFC- Leak Management Corrective affecting PG&E gas (GDST).” Maintenance Expenses, pp. 5,6,11,14 distribution, and noted the non-trivial proportion of causes linked to company conduct. CFC argued for some of the steep increased expenditures being rightly recovered from shareholders, because company conduct contributed to the incidences. CFC proposed reducing the CFC- Leak Management Corrective Gas Distribution expenses Maintenance Expenses, pp. 2,12 budget by $18.7M, on the basis that, some repairs are CFC- Leak Management Corrective directly the result of incorrect Maintenance Expenses, pp. 5,6 operation. Section 191 reports required by, and filed with, the Pipeline and Hazardous Materials Safety Administration (PHMSA) CFC- Leak Management Corrective identify leaks caused by
combining the utility’s evidence, plus that from external sources to provide the Commission with a more complete perspective on how PG&E’s proposed expenditures fit into the broader, long-term context of replacing the utility’s aging distribution system assets. CFC anticipated using the supplementary information assembled to demonstrate that PG&E’s planned expenditures were both inconsistent with the long-term expense trajectory required to sustain the system in good condition, yet also presenting a expenditure spike inconsistent with the avoiding unnecessary rate-shock. Further, CFC examined the reported incident causes affecting PG&E gas distribution, and noted the non-trivial proportion of causes linked to company conduct. CFC argued for some of the steep increased expenditures being rightly recovered from shareholders, because company conduct contributed to the incidences. CFC proposed reducing the Gas Distribution expenses budget by $18.7M, on the basis that, some repairs are directly the result of incorrect operation. Section 191 reports required by, and filed with, the Pipeline and Hazardous Materials Safety Administration (PHMSA) identify leaks caused by CFC- Leak Management Corrective Maintenance Expenses, pp. 3-6 CFC- Leak Management Corrective Maintenance Expenses, pp. 5,6,11,14 CFC- Leak Management Corrective Maintenance Expenses, pp. 2,12 CFC- Leak Management Corrective Maintenance Expenses, pp. 5,6 CFC- Leak Management Corrective contribution to the proceeding. CFC’s alleged contributions on this issue did not assist the Commission’s decisionmaking process. Because of the lack of substantial contribution on this issue, the Commission disallows 75% of CFC’s hours claimed regarding “Gas Distribution Maintenance Expenditures (GDST).”
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