STATE OF CALIFORNIA EDMUND G. BROWN JR., Governor

PUBLIC UTILITIES COMMISSION

505 VAN NESS AVENUE

SAN FRANCISCO, CA 94102-3298

D.17-06-015 Compliance Plan Guidance Document

This guidance document provides clarifications and expectations, to be used with the RASA Compliance Plan Template, for Operators to complete their biennial best practices Compliance Plans. Requests for additional clarification should be submitted to the Safety and Enforcement Division, Risk Assessment and Safety Advisory Section (RASA).

The Compliance Plans will consist of three Sections: an Executive Summary, the Best Practice chapters, and a Supplemental section to include reference materials and detailed procedures. Guidance for the contents of each Section follows.

Executive Summary Section: Operators must submit an overall program summary highlighting their major efforts to reduce methane emissions, estimated incremental costs where known, and any significant changes from their previous Compliance Plan. This Section should summarize the total anticipated emission reductions from the proposed practice projected for the two-year compliance period and, if possible though the year 2030. The executive summary must be signed by the corporate officer responsible for gas operations.

Best Practices Section: Each of the Best Practices (BPs) as described in D.17-06-015 should be addressed in its own Chapter, numbered 1 to 26. The Compliance Plan Template should be used for each Chapter. If the Operator claims exemption for a particular BP, they should make the claim with justification in the corresponding Chapter.

If the contributions to emission reduction and costs cannot be directly attributed for some of the BP’s, the Operator may instead give a cumulative forecast in the Executive Summary section.

For each of the Best Practice chapters, refer to these guidelines when using the Template:

1) BP Overview: Provide an overview of the Operator’s plan to implement this BP and the current Status (R+D, Pilot, Phased-In Approach, on-going, etc). Include the date on which the new or incremental activity began or will begin.

2) BP Details: Section 2 will provide the details for implementing the best practice.

2a) Discuss the Operator’s previous work, and whether the measures outlined within this best practice are already incorporated in to its normal operations work.

2b) As appropriate, outline a pilot project or phased-in implementation, rather than full scale implementation of this best practice.

2c) Describe Operator’s proposed implementation of this Best Practice.

2d) Discuss the extent that this practice overlaps with other regulatory compliance activities, and what portion of the practice is incremental above and beyond those activities. Note: When requesting cost recovery, which is outside the scope of the Compliance Plan, an operator will make their case for the incremental portion of costs above and beyond compliance with other Federal or State regulations.

2e) Outline why a technology was chosen, and highlight any efficiency related to safety-related activities, or other work efficiencies. Technical specification and relevant units should be specified here or attached as supplemental information. In summary, the Operator can provide an outline on the characteristics of its selected technology. Supplemental data that is attached can be referenced below in section 3 of this document.

2h) Identify any new procedures or existing ones to be modified. Attach detailed procedures in Section 3.

2i) Present the Operator’s planned actions over the next two years. If an Operator identifies a phased approach, the milestones and anticipated timelines should be included here. The reductions for a phased-in implementation should be covered in section 2m).

2j) Discuss the range of factors that an Operator evaluated for determining the cost-effectiveness of a particular best practice, such as work efficiencies and benefits to combined safety or risk related work. Additionally, an Operator should explain how the pace of work was determined (if not previously defined in section (2i)), and any relationship with cost effectiveness. This should also capture any projected incremental costs. Highlight, and where possible quantify other benefits from implementing this best practice such as costs savings from unvented emissions and other metrics to be identified.

2k) Highlight, and where possible quantify, other benefits from implementing this best practice such as costs savings from unvented emissions.

2m) When attribution of emission reductions to this BP is possible, include anticipated emissions reductions expected for each year of the phased-in implementation, and the units used for measuring emissions. Where possible, discuss the component emissions of the 2015 Baseline Emissions Survey that you expect to be reduced by this BP.

2n) Describe how the anticipated emissions were calculated, what assumptions were made, and any emission factors that were used. Supplemental information relating to the calculations may be attached in section 3d.

2p) This section should address the following questions:

·  What incremental costs and/or benefits of the BP overlap with existing or planned safety/risk work?

·  If any overlap, provide a summary explanation of the BP and safety/risk overlap and a description of how the BP improves safety and/or reduces risk?

·  If any overlap, if possible quantify any cost reduction for existing or planned safety and risk work as a result of the BP?

Supplemental Section: This section should provide supplementary documents that provide the details of new or modified procedures/processes created to align with this best practice, which will provide transparency into how these changes are implemented. Additionally, documents for new technologies, including equipment application and technical specifications, should be included.

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