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As the business manager of the International Brotherhood of Electrical Workers Local 1245, which represents 12,000 workers at PG&E (including thousands of gas workers), I am writing to offer a different perspective on the company’s safety culture than was described by the PUC’s Safety Enforcement Division. Last summer, state Sen. Jerry Hill, D-San Mateo, told his fellow Bay Area legislators that in his opinion PG&E has the safest gas system in the country. I agree.

The recent accusations of falsification of gas records by the PUC Safety Enforcement Division involve the speed with which PG&E complies with a third-party request to “locate and mark” underground PG&E facilities prior to excavation in the area.

PG&E handles more than 1 million such requests a year. In the time period cited by the PUC Safety Enforcement Division, our members processed more than 5 million locate and mark requests.

Since the 2010 San Bruno explosion, PG&E has increased its gas workforce by 55 percent. In 2014, we negotiated two new gas classifications that handle nothing but compliance issues — the “locate and mark” work and gas leak surveys. There are now almost 300 dedicated gas compliance employees doing work that before 2017 was not assigned to a specialized workforce.

Over the last several years, our members and PG&E have made a concerted effort to reduce the number of third-party “dig-ins” with company gas lines. The vast majority of dig-ins were the result of poor excavating techniques by third parties working on sewer lines, water lines, fencing, and landscaping work or by the failure of the third party to request a “locate and mark”. Through our efforts with the company, we have cut the number of third-party dig-ins in half.

Requests for the “locate and mark” services are supposed to be completed within 48 hours. The recent accusations of falsification involve internal company reports of how long it took the employee to process the request. In a truly small number of instances when considering a denominator of 5 million tags, the completion time did not reflect a start-to-finish time, but was paused at some point in the process. This pause was either an act of intentional falsification (the CPUC’s position), or an honest misunderstanding of how the time was to be counted, especially when the requesting party told PG&E that it did not need the locate and mark service immediately.

The percentage of locate and mark tags was not a metric that affected the pay of the union workforce, their supervisors, or their management superiors. Employees were neither rewarded for completing the tags within 48 hours nor punished for not doing so. The PUC did not and does not require the company to report its completion percentage rate.

Simply put, there was no motive, either monetary or disciplinary, for anyone to engage in intentional falsification. If there exist two explanations for an occurrence, the more assumptions you have to make, the more unlikely an explanation. Using this principle here — and what I know about PG&E’s safety culture and especially the safety culture of our membership — I believe that the PUC’s rush to judgment on this issue is misplaced.

PG&E discovered the timing pause issue in late 2016, investigated it, and cooperated with the PUC investigation. I understand the lesson of Caesar’s wife — the appearance of impropriety is sometimes as important as the reality of impropriety. This is especially true in the current political reality where the failure to properly trim one branch on one of the 1.1 million trees that PG&E clears from power lines can be deemed criminal negligence.

PG&E is not perfect, and neither are our members. But we have first-hand knowledge of the dozens of safety initiatives that have been implemented in its gas system in the years since San Bruno. Measurable progress is being made. And when Sen. Jerry Hill says that PG&E has the safest gas system in the country, I have to agree.

Tom Dalzell is the business manager of International Brotherhood of Electrical Workers Local 1245, which represents 20,000 members in California and Nevada.