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General Order 165
III.    Reporting and Recording Requirements
A    Comments of the Parties
Edison, PG&E, and Sierra propose the first annual report be submitted in July 1998 rather than July 1997 in order to provide adequate time for the utilities to demonstrate compliance with the new standards. SDG&E supports the annual reporting requirements proposed in D.96-11-021.

ORA recommends that the utilities be required to document all corrective action scheduled and undertaken as a result of their inspections. It also recommends that a proposed General Order on inspection cycles require the utilities to rate the condition of facilities according to results of each inspection. Along the same lines, CUE proposes that the General Order require the utility to maintain a record of problems observed by the inspector, the date of corrective action, and the identity of the person performing the work.

ORA comments that the Commission, perhaps inadvertently, proposed to require 30-day notice by Commission staff for reviewing utility records. ORA observes that PU Code Section 314 ( a) provides that Commission staff may inspect utility records "at any time."

CUE proposes the General Order include specific definitions for "patrol," "detailed," and "intrusive," consistent with the discussion in D.96-11-021.
B    Discussion
As the utilities suggest, we will require the first annual reports to be submitted in July, 1998. However, to assure that reports as well as source records are clear and comprehensive, we direct utilities to submit compliance plans as soon as possible, but before July 1, 1997. These compliance plans will include the proposed forms for annual reports and source records, as well as the utility's plans for the types of inspections and equipment to be inspected during the coming year. For detailed and intrusive inspections, schedules should be detailed enough (in terms of the month of the inspection and the circuit, area, or equipment to be inspected) to allow staff to confirm that scheduled inspections are proceeding as planned. Since patrol inspections may be carried out in the course of other utility business, schedules are not required in advance. However, utilities should explain how all required facilities will be covered during the year.

The utilities are directed to update this schedule annually. We authorize Energy Division to review these compliance plans and to prescribe changes relating to data, definitions, formats, and forms when and as necessary.

D.96-11-021 required that utilities maintain various kinds of information on inspections. We will also include in the General Order the requirement that the utilities maintain a record of problems observed by the inspector, the schedule and actual date of corrective action, and the identity of the person performing the work. This type of information will promote follow-up to inspections and serve as a foundation for determining the reasonableness of utility actions if and when specific problems occur on the system. Finally, for detailed and intrusive inspections, we adopt ORA's recommendation that utilities rate and record the condition of inspected facilities.

We incorporate in to the General Order the descriptions of the terms "patrol," "detailed," and "intrusive" presented in D.96-11-021, as proposed by CUE.

We agree that Commission staff should not be required to provide 30-day notice to inspect utility records and will modify our original proposal accordingly.