PG&E Response to Indicated Shippers Data Request IS_013-Q16

Proceeding: A.13-12-012
ALJ:
Yip-Kikugawa
Date:
Exhibit No:
PACIFIC GAS & ELECTRIC COMPANY
GT&S Rate Case 2015
PG&E Response to Indicated Shippers Data Request
IS_013-Q16
PACIFIC GAS AND ELECTRIC COMPANY
Gas Transmission and Storage Rate Case 2015
Application 13-12-012
Data Response
PG&E Data Request No.:
PG&E File Name:
Request Date:
Date Sent:
PG&E Witness:
QUESTION
lndicatedShippers 013-16
GTS-RateCase2015 DR lndicatedShiooers 013-016
September 18, 2014
Requester DR No.:
013
October 8, 2014
Requesting Party:
Indicated Shiooers
Bennie Barnes
Requester:
Evelyn Kahl/
John Mcintyre/
Dr. Jonathan Lesser, PhD/
Dr. Charles Feinstein, PhD
16
In PG&E Rebuttal Testimony, Page 4A-64, Lines 17-19, PG&E states that "Dr. Lesser
misses the point that earthquake fault crossing studies could not really begin until PG&E
had acquired a database of earthquake faults in 2008."
(a) When did PG&E begin the compilation of its database?
(b) Why did PG&E choose that particular time to commence the compilation of its data
base?
(c) Could PG&E have completed its database of eartt:iquake fault crossings prior to
2008? If not, please explain why not and the basis for the explanation.
ANSWER
16
(a) As PG&E notes in the response to GTS-RateCase2015_DR_TURN_029-Q15, "By
2001, PG&E and the geosciences industry had gained enough usable data and
knowledge to implement a seismic mitigation program on the gas transmission
system similar to the program proposed in this 2015 GT&S Rate Case." However,
it was in 2008 that PG&E began to develop this data into a useable database.
Further, both PG&E and California United States Geological Survey (USGS)
continue to learn about active faults and the database continues to grow. For
example, as recently as the Napa earthquake (American Canyon), PG&E and the
USGS learned of a newly active fault that was previously identified as inactive by
USGS.
(b) PG&E began that effort in 2008 because that is when the USGS in response to the
Alquist Priolo Act had active earthquake fault data in an. electronic format that could
be used by the industry to develop a database. As stated in (a), both the USGS
and PG&E have continued to evolve knowledge about active faults and continue to
learn of newly identified active faults.
(c) PG&E did have and used partial data that was available from USGS earlier than
2008 as it continued to build towards a usable database in 2008. In fact, PG&E
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performed its first three fault crossing mitigation projects in 1994 and another eight
between the beginning of 2001 and the end of 2009.
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