7. Comprehensive Catastrophic Risk Assessment

This rulemaking will consider ways that this Commission can undertake a comprehensive catastrophic risk assessment for all natural gas pipelines regulated by this Commission. Due to aging utility infrastructure, we are interested in assessing whether we may be missing other natural gas pipeline safety issues or other catastrophic risks that are currently unidentified. In short, we pose the questions: "what else is out there?" and "what can we do to prevent another tragedy from unexpected sources?" We are also open to considering whether such a comprehensive assessment should be completed for other industries that the Commission regulates.

We are also keenly interested in improving our regulation of the far more common threat to natural gas transmission and distribution system safety - accidental damage during unrelated but nearby excavation, often referred to as a "dig in."

As required by 49 CFR § 198.37, we have in place a one-call damage prevention program that enables excavators to request marking of all underground facilities near a proposed excavation site. The federal regulations also require each operator of underground pipeline facilities to have a written damage prevention program to prevent damage to the pipeline from excavation activities. Pursuant to such a program, the pipeline operator must, upon notice from a one-call center to which the operator is a member, mark all the operator's subsurface facilities in the area of proposed excavation activity and, in a timely manner, inspect any facilities that the operator has reason to believe could have been damaged by any excavation activities, 49 CFR § 192.614.

Excavators who damage subsurface facilities, e.g., pipelines, but do not report the incident or, worse yet, actively conceal the damage may be threats to public safety in violation of Government Code § 4216 and such actions may be disturbingly common. We will endeavor to maintain a broad perspective in this proceeding and take such actions as will enhance overall public safety with regard to all subsurface utility facilities.