BILL ANALYSIS                                                                                                                                                                                                    �



                                                                  AB 1456
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          Date of Hearing:   April 9, 2012

                    ASSEMBLY COMMITTEE ON UTILITIES AND COMMERCE
                               Steven Bradford, Chair
                   AB 1456 (Hill) - As Introduced:  January 9, 2012
           
          SUBJECT  :   Gas Corporations: rate of return: safety.

           SUMMARY  :   This bill would require the commission to consider 
          the safety performance of a gas corporation in determining what 
          constitutes a just and reasonable rate of return.

           EXISTING LAW  : 

          1)States that the California Public Utilities Commission (PUC) 
            has regulatory authority over public utilities, including gas 
            corporations, authorizes the commission to fix the rates and 
            charges for every public utility, and requires that those 
            rates and charges be just and reasonable. 

          2)States the Natural Gas Pipeline Safety Act of 2011, among 
            other things, prohibits a gas corporation from recovering any 
            fine or penalty in any rate approved by the commission.  

           FISCAL EFFECT  : Unknown.

           COMMENTS  :   According to the author, "this bill would require 
          the PUC to consider the safety performance of a gas utility in 
          determining what constitutes a just and reasonable profit.  By 
          tying safety performance to utility profit, the bill would 
          ensure that safety is a top focus of management."

           1)Background  : The impetus of this bill stems from the September 
            9, 2010 explosion and fire that occurred in the City of San 
            Bruno.  A 30-inch natural gas transmission pipeline, owned and 
            operated by Pacific Gas and Electric Company (PG&E), ruptured 
            and caused an explosion and fire which claimed the lives of 
            eight people and injured dozens more; destroyed 37 homes and 
            damaged dozens more.  Natural gas pipeline accidents in 
            California, particularly the explosion in the City of San 
            Bruno, have called for a re-evaluation of pipeline safety in 
            the legislature and regulatory enforcement agencies.

            The National Transportation and Safety Board (NTSB) had 
            principal jurisdiction over the investigation into the San 








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            Bruno explosion and released its final report on the causation 
            last year.  The NTSB determined that the probable cause of the 
            accident was the Pacific Gas and Electric Company's (1) 
            inadequate quality assurance and quality control in 1956 
            during its Line 132 relocation project, which allowed the 
            installation of a substandard and poorly welded pipe section 
            with a visible seam weld flaw that, over time grew to a 
            critical size, causing the pipeline to rupture during a 
            pressure increase stemming from poorly planned electrical work 
            at the Milpitas Terminal; and (2) inadequate pipeline 
            integrity management program, which failed to detect and 
            repair or remove the defective pipe section.

            The report notes that contributing to the accident were the 
            California Public Utilities Commission's and the U.S. 
            Department of Transportation's exemptions of existing 
            pipelines from the regulatory requirement for pressure 
            testing, which likely would have detected the installation 
            defects. Also contributing to the accident was the PUC's 
            failure to detect the inadequacies of PG&E's pipeline 
            integrity management program.

            Furthermore, contributing to the severity of the accident were 
            the lack of either automatic shutoff valves or remote control 
            valves on the line and PG&E's flawed emergency response 
            procedures and delay in isolating the rupture to stop the flow 
            of gas.

          2)The PUC formed its own review panel based on authority it 
            cited in its resolution to"do all things, whether specifically 
            designated in ... �the Public Utilities Code] or in addition 
            thereto, which are necessary and convenient" to our regulation 
            of public utilities, including, though not limited to, 
            adopting necessary rules and requirements in furtherance of 
            our constitutional and statutory duties to regulate and 
            oversee public utilities operating in California." 

          3)In September 2010, the PUC's Independent Review Panel (IRP) 
            was formed to examine contributing factors to the San Bruno 
            disaster.  The PUC directed the panel to make a technical 
            assessment of the events, determine the root causes, and offer 
            recommendations for action by the PUC to best ensure such an 
            accident is not repeated elsewhere.

          4)The IRP released its findings on June 9, 2011. Important 








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            findings related to this bill are:

             a)   A recommendation that "Upon thorough analysis of 
               benchmark data, adopt performance standards for pipeline 
               safety and reliability for PG&E, including the possibility 
               of rate incentives and penalties based on achievement of 
               specified levels of performance."

             b)   A finding that "the CPUC did not have the resources to 
               monitor PG&E's performance in pipeline integrity management 
               adequately or the organizational focus that would have 
               elevated concerns about PG&E's performance in a meaningful 
               way."

          1)The IRP did not recommend that safety performance be a 
            consideration in the PUC's rate of return assessment.

          2)It is unclear that, since June 2011, the PUC has had 
            sufficient time to reorganize itself in a manner that will 
            ensure that pipeline integrity management is adequately 
            monitored. The PUC is currently soliciting bids to analyze and 
            evaluate the Gas Safety and Reliability Branch of the PUC in 
            the context of their effectiveness in adhering to existing 
            federal safety regulations and provide CPUC with new ideas and 
            insight as to how the program could evolve into one that is 
            more proactive in addressing future gas safety issues. The PUC 
            is not expected to award this contract until May 2012.

           3)Safety performance does not fit neatly into a triennial rate 
            of return assessment.  While the intent of the bill may seem an 
            appropriate reaction to an event such as San Bruno, safety 
            performance, as has also been learned from San Bruno is 
            something that extends well before and well after the PUC's 
            triennial review of rates of return. If the safety performance 
            of regulated utility were taken into consideration prior to 
            San Bruno the PUC might have concluded that, for example, PG&E 
            should receive a bonus for its safety performance. Likewise, 
            after San Bruno, the PUC might conclude that PG&E should be 
            penalized for its safety performance. Correcting for this 
            deficiency in this bill would be arbitrary - one could propose 
            looking back over the last 10 years, last 20 years, last 50 
            years and in each increment, could conclude that over X period 
            of time, a regulated entity was safe and should receive a 
            normal rate of return. However, add just one tragic incident, 
            like San Bruno, and the decision could be significantly 








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            different.

           4)Lack of a safety standard.  Without an established safety 
            performance standard the PUC would be left to arbitrarily 
            determining whether or not any particular utility met, 
            exceeded, or fell short on its safety performance.

           5)Rate cases might be more appropriate for a safety incentive or 
            penalty.  Performance bonuses and penalties could be addressed 
            in the Rate Cases, where the PUC can better assess progress 
            and deficiencies. This could be done once the benchmarking 
            study is complete and performance standards are established.

          6)Until the benchmarking analysis is complete, this bill is 
            premature.  The author may wish to consider amending the bill 
            to require a benchmarking study and for the PUC to evaluate 
            rate incentive and penalties every three years after the 
            benchmarking study is complete.
                 
              Suggested amendments:
                 
           On page 2, beginning at line 9: (d) The panel suggested that 
           upon thorough analysis of benchmark dat  a rate incentives and 
          penalties be applied to gas corporations based on the 
          achievement of specified levels of performance.
          SEC. 2. Section 960 is added to the Public Utilities Code, to 
          read:
          960.  The commission shall consider the safety performance of a 
          gas corporation in determining what constitutes a just and 
          reasonable rate of return  .  
          (a) The commission shall perform an analysis of benchmark data 
          and adopt performance standards for pipeline safety and 
          reliability. 
           (b)The commission shall evaluate rate incentives and penalties 
          every three years after the benchmarking study is complete.

           
           REGISTERED SUPPORT / OPPOSITION  :   

           Support 
           
          None on file.

           Opposition 
           








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          Pacific Gas and Electric Company (PG&E)
          San Diego Gas & Electric Company (SDG&E)
          Sempra Energy utilities (SEu)
          Southern California Gas Company
           
          Analysis Prepared by  :    DaVina Flemings / U. & C. / (916) 
          319-2083