Case 3:14-cr-00175-TEH Document 905 Filed 01/09/17 Page 1 of 14

1 BRIAN J. STRETCH (CABN 163973)

United States Attorney
2
BARBARA J. VALLIERE (DCBN 439353)
3 Chief, Criminal Division
4 HALLIE MITCHELL HOFFMAN (CABN 210020)
HARTLEY M. K. WEST (CABN 191609)
5 JEFF SCHENK (CABN 234355)
Assistant United States Attorney
6
450 Golden Gate Avenue, Box 36055
San Francisco, California 94102-3495
7
Telephone: (415) 436-7200
Fax: (415) 436-7234
8
Hallie.Hoffman@usdoj.gov
Hartley.West@usdoj.gov
9
Jeffrey.B.Schenk@usdoj.gov
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Attorneys for United States of America
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UNITED STATES DISTRICT COURT
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NORTHERN DISTRICT OF CALIFORNIA
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SAN FRANCISCO DIVISION
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UNITED STATES OF AMERICA,

)
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Plaintiff,
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)
v.
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PACIFIC GAS AND ELECTRIC COMPANY, )
)
Defendant.
)
)

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U.S. SENTENCING MEMORANDUM
CR 14-00175 TEH

Case No. CR 14-00175 TEH

UNITED STATES SENTENCING
MEMORANDUM
Date:
Time:
Courtroom:
Judge:

January 23, 2017

2:30 p.m.
G, 15th Floor
Hon. Thelton E. Henderson

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TABLE OF CONTENTS

1
2 I.

INTRODUCTION ...........................................................................................................................1

3 II.

DISCUSSION ..................................................................................................................................2

A.

Offense Conduct ..................................................................................................................2

1.

Count One ................................................................................................................2

2.

Counts Two and Five Through Eight.......................................................................3

B.

Relevant Conduct .................................................................................................................4

1.

Obstruction...............................................................................................................4

2.

Other Pipeline Safety Violations .............................................................................5

10 III.

SENTENCING GUIDELINES CALCULATION ..........................................................................6

11 IV.

ARGUMENT ...................................................................................................................................7

12

A.

Fine ......................................................................................................................................7

13

B.

Probation ..............................................................................................................................8

14

1.

Safety Program.........................................................................................................8

15

2.

Advertising Program ................................................................................................9

16

3.

Monitor/Compliance and Ethics Program ...............................................................9

17

4.

Community Service ...............................................................................................10

18 V.

CONCLUSION ..............................................................................................................................10

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20
21
22
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U.S. SENTENCING MEMORANDUM
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TABLE OF AUTHORITIES

CASES

3 United States v. Danilow Pastry Co., 563 F. Supp. 1159 (S.D.N.Y. 1983) ............................................... 7
4 United States v. Lowe, 654 F.2d 562 (9th Cir. 1981).................................................................................. 8
5 United States v. Mitsubishi Int'l Corp., 677 F.2d 785 (9th Cir. 1982) ........................................................ 7
6

STATUTES

7 18 U.S.C. 3553 ..................................................................................................................................... 7, 8

8 18 U.S.C. 3563 ............................................................................................................................... 8, 9, 10
9 18 U.S.C. 3572 ..................................................................................................................................... 7, 8
10 49 U.S.C. 60123(a) .............................................................................................................................. 3, 6
11
12
13
14
15
16
17
18

RULES
U.S.S.G. 2Q1.2 ........................................................................................................................................ 6
U.S.S.G. 4A1.3 ........................................................................................................................................ 6
U.S.S.G. 5K2.3 ........................................................................................................................................ 6
U.S.S.G. 8B1.3 ....................................................................................................................................... 10
U.S.S.G. 8B2.1 ......................................................................................................................................... 9
U.S.S.G. 8C2.1..................................................................................................................................... 6, 7
U.S.S.G. 8D1.4(a) .................................................................................................................................... 9

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20
21

REGULATIONS
49 C.F.R. 192.517(a)................................................................................................................................ 5
49 C.F.R. 192.709(a)................................................................................................................................ 5

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U.S. SENTENCING MEMORANDUM
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1
2

I.

INTRODUCTION

On September 9, 2010, a natural gas pipeline owned and operated by defendant Pacific Gas and

3 Electric Company (PG&E) ruptured in a residential neighborhood in San Bruno, California. The rupture
4 of Line 132 released approximately 47.6 million standard cubic feet of natural gas, created a crater
5 approximately 72 feet by 26 feet wide, and launched a 180-foot long pipe weighing 3,000 pounds from
6 several feet underground to rest about 100 feet away. The gas ignited, causing an explosion and fire that
7 took 50 hours to extinguish. The fire killed 8 people and injured 58 others, several with severe burns
8 over much of their bodies. It damaged 108 homes; 38 were completely destroyed.
9

The National Transportation and Safety Board (NTSB) immediately began an investigation into

10 the cause of the explosion, as well as PG&Es pipeline integrity management program, which was
11 supposed to ensure the safety of its system. The NTSB determined that PG&Es gas transmission
12 integrity management program was deficient and ineffective, and specifically that PG&E had
13 inaccurate and incomplete records, failed to consider known longitudinal seam cracks in Line 132, chose
14 a method to assess Line 132s integrity that it knew was inadequate to detect seam defects such as the
15 one that led to the rupture, and improperly considered known manufacturing defects on Line 132 to be
16 stable. Dkt. 672 at 4-6. The California Public Utilities Commission (CPUC) also conducted an
17 investigation, concluding that PG&Es failure to comply with integrity management requirements,
18 inadequate record keeping practices, and systemic failure of PG&Es corporate culture to emphasize
19 safety over profits, were causes of the San Bruno explosion. Dkt. 672 at 4-5.
20

PG&E was charged with violating the very same pipeline safety regulations that underlay the

21 NTSBs and CPUCs findings. On August 9, 2016, after an eight-week jury trial, PG&E was convicted
22 on five felony counts of knowingly and willfully violating minimum safety standards under the Natural
23 Gas Pipeline Safety Act. The jury also convicted PG&E of obstructing the NTSB proceedings, finding
24 that it intentionally and corruptly provided investigators with misleading information concerning its
25 integrity management practices.
26

PG&Es pattern of deliberate and methodical violations of safety regulations, motivated by profit

27 and resulting in mass death and destruction, warrants the most serious sentence this Court can impose.
28 The United States fully supports the comprehensive sentencing recommendation of the United States
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1 Probation Office, including a five-year probation term, extensive monitoring program, 10,000 hours of
2 community service by executive management and other employees, revamping of the companys
3 compensation structure to reward safety over profits, and media acknowledgement of its violations and
4 convictions, as well as the maximum statutory fine. The Court should order that these costs not borne
5 by the ratepayers. Such a sentence is not only appropriate, it is the minimum necessary to reflect the
6 seriousness of PG&Es conduct, promote respect for the law, provide just punishment, protect the public
7 from further crimes by this recidivist defendant, and adequately deter other natural gas operators across
8 the country.
II.

DISCUSSION

10 A.

Offense Conduct

11

The Presentence Report (PSR) accurately summarizes the proof at trial regarding PG&Es

12 offense conduct.
13

1.

Count One

14

The evidence proved that PG&E intentionally and corruptly endeavored to obstruct, influence, or

15 impede the NTSBs investigation. Among the issues that the NTSB specifically investigated was
16 PG&Es practice of intentionally raising the pressure every five years in many of its oldest gas
17 transmission pipelines in high consequence areas (HCAs), including Line 132. PG&E engaged in this
18 practice in an effort to maintain the pipelines five-year maximum operating pressure (5-year MOP) at
19 the maximum allowable operating pressure (MAOP). These planned pressure increases (PPIs) often
20 resulted in pipelines experiencing pressures that exceeded their 5-year MOP. According to the pipeline
21 safety regulations, once the pressure on these lines exceeded the 5-year MOP, manufacturing threats on
22 the pipelines became unstable, requiring the operator to replace or properly assess the integrity of the
23 pipeline either by a hydrotest or an acceptable form of in-line inspection (ILI).
24

After learning that PG&E was intentionally increasing pressure on its transmission lines as a

25 strategy to preserve its 5-year MOPs, the NTSB sent PG&E data requests seeking more information. In
26 February 2011, PG&E responded to the NTSBs requests with a copy of its Risk Management
27 Instruction (RMI-06), which set forth PG&Es PPI policy, including that PG&E considered a
28 manufacturing threat unstable only if the pressure exceeded the 5-year MOP by 10% (RMI-06 +10%
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1 version). On March 9, 2011, an inspector with the Pipeline and Hazardous Materials Safety
2 Administration (PHMSA), who was also a party member to the NTSB investigation, advised PG&E
3 management that its +10% allowance was not allowed. The NTSB followed up with a data request
4 asking how PG&E determined the stability of manufacturing threats on its high-risk pipelines.
5

After a flurry of emails amongst PG&E employees, PG&E emailed a letter to the NTSB on April

6 6, 2011, advising there was no indication that [the +10% allowance version of RMI-06] was ever
7 approved, and that the RMI-06 versions in effect did not include the 10% provision found in the
8 unapproved version. PG&E did not disclose that its integrity management group had actually followed
9 the +10% version of RMI-06 and, as a result, did not treat approximately 84 miles (443 segments) of its
10 gas transmission lines as having unstable manufacturing threats. The letter also failed to disclose to the
11 NTSB that senior members of PG&Es integrity management group who implemented this policy knew
12 the +10% version violated the pipeline safety regulations and PHMSA guidance regarding those
13 regulations. The lead NTSB investigator posted this letter on the NTSBs docket, which he testified
14 signified its importance to the investigation.
15

2.

Counts Two and Five Through Eight

16

PG&E was also convicted on Counts Two and Five through Eight, which charged knowing and

17 willful violations of Minimum Federal Safety Standard regulations for natural gas pipelines, in violation
18 of the Natural Gas Pipeline Safety Act, 49 U.S.C. 60123(a). As to Count Two, the evidence showed
19 that PG&E knowingly and willfully failed to gather and integrate data and information relevant to
20 identifying and evaluating potential threats to pipeline segments in HCAs. Specifically, PG&E integrity
21 management documents falsely stated that there were no failures or leaks on the long seams of particular
22 pipelines, and that potential threats had been reviewed and addressed. Meanwhile, PG&E admitted in its
23 data responses to the NTSB that its leak records were not fully integrated, and that it could not find
24 records pertaining to one particular leak. PG&E nonetheless consistently chose an integrity assessment
25 method (external corrosion direct assessment, or ECDA) that, while cheap, was not designed for nor
26 capable of testing for long seam leaks and failures.
27

As to Count Five, the evidence proved that PG&E knowingly and willfully failed to identify and

28 evaluate not only the leaks identified in Count Two, but also manufacturing threats to certain pipeline
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1 segments in HCAs. Numerous PG&E records, including its Integrity Management Plans, Baseline
2 Assessment Plans (BAPs), and risk assessment spreadsheets, documented the existence of potential
3 manufacturing threats, yet all identified ECDA as the only past and future assessment method despite
4 knowing it was unsuitable for assessing manufacturing threats.
Regarding Count Six, the evidence proved that PG&E knowingly and willfully failed to include

6 in its BAPs information supporting identification of potential manufacturing threats on HCA segments,
7 and methods selected to assess those threats. While the BAPs recognized the existence of potential
8 manufacturing threats on HCA segments that had experienced overpressures, they showed that PG&E
9 had again selected the cheaper and utterly ineffectual ECDA to assess the threats. The evidence
10 demonstrated such violations on eleven HCA segments on Line 132, and fourteen HCA segments on
11 other Bay Area pipelines.
In Count Seven, the jury found that PG&E knowingly and willfully failed to prioritize as high

12

13 risk HCA segments with manufacturing threats, after they had experienced overpressures. Evidence
14 from PG&Es own BAPs, Integrity Management Plans, and risk spreadsheets proved that PG&E
15 identified manufacturing defects, recognized overpressures, and nonetheless planned only to use ECDA
16 (knowing that it was incapable of assessing manufacturing threats) on well over 100 HCA segments,
17 including the exploded segment of Line 132.
Finally, in convicting on Count Eight, the jury found that PG&E knowingly and willfully failed

18

19 to prioritize as high risk certain HCA segments those containing low-frequency ERW pipe or pipe
20 with a joint efficiency factor less than 1.0 that had experienced overpressures. PG&Es own integrity
21 management records show its repeated choice of the entirely unsuitable ECDA on more than 70
22 overpressured HCA segments.
23 B.

Relevant Conduct

24

In addition to the offenses of conviction, the evidence at trial demonstrated a larger pattern of

25 obstructive conduct by PG&E, as well as other violations of the pipeline safety regulations.
26

1.

Obstruction

27

PG&Es submission of the misleading April 6 letter was not its only effort at obstruction. Trial

28 testimony established that, throughout the NTSBs investigation, PG&E failed to provide accurate or
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1 complete information, hindered investigators ability to gather information during interviews, misled
2 investigators about the amount of overpressures on the lines, and withheld information about the number
3 and types of leaks on lines, including on Line 132. Indeed, PG&Es party participation was so abysmal
4 that the NTSB took the rare step of removing its party representative.
5

PG&E also elicited false trial testimony from employee Calvin Lui, who denied PG&Es 10%

6 practice. The evidence, however, showed that he was specifically trained on the 10% practice and that
7 he carried out the 10% practice through his instructions to engineers. The jurys finding of guilt on the
8 obstruction charge implicitly reflects their finding that Lui lied in saying no 10% practice existed.
9

And PG&Es obstructive conduct went beyond that heard by the jury. PG&E management

10 instructed employees to copy an attorney on any emails concerning the San Bruno explosion in an effort
11 to shield them from discovery. PG&E also withheld material evidence called for by subpoena during
12 the governments investigation, including the April 6 letter concerning the 10% practice. (The
13 government charged PG&E with the obstruction count after discovering the April 6 letter on the NTSBs
14 website.)
15

2.

Other Pipeline Safety Violations

16

The evidence also showed, by at least a preponderance of the evidence and notwithstanding the

17 jurys acquittal on Counts 3-4 and 9-12, that PG&E failed to maintain leak repair records and to retain
18 strength test pressure records (STPRs), as required under 49 C.F.R. 192.709(a) and 192.517(a).
19

PG&Es data responses, integrity management documents, and other communications

20 demonstrated that PG&E created leak repair records but could not locate them for years. As a result,
21 PG&E failed to take the leaks into consideration when making integrity management decisions such as
22 proper assessment methods.
23

That PG&E failed to retain STPRs as required was proved by Defense Exhibit 218A. The

24 federal regulations required PG&E to strength test each piece of pipe after installation and before using
25 it to transport natural gas. Defense Exhibit 218A purported to account for each STPR that PG&E had
26 not produced to the government prior to the Superseding Indictment the basis for the STPR charges.
27 Instead, it shows pressure tests conducted after PG&E was charged with lacking such records; tests prior
28 to pipe installation; and reports that simply lack the documentation mandated under the regulation.
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1
2

III.

SENTENCING GUIDELINES CALCULATION

The government concurs with the sentencing guidelines calculation set forth in the revised PSR.

3 Because there is no guideline assigned for 49 U.S.C. 60123(a), the Court should apply the most
4 analogous guideline. USSG 2Q1.2 is the guideline for Mishandling of Hazardous or Toxic Substances
5 or Pesticides; Recordkeeping, Tampering, and Falsification; Unlawfully Transporting Hazardous
6 Materials in Commerce. It is most analogous for an offense involving transportation of explosive
7 materials such as natural gas. Under 2Q1.2, the government concurs that PGEs offense level is 27:
8

Base Offense Level, USSG 2Q1.2:

Specific Offense Characteristics:

10

Ongoing discharge of hazardous material, USSG 2Q1.2(a)

+6

11

Substantial risk likelihood of death or serious bodily injury,

USSG 2Q1.2(b)(2)

+9

Disruption of utilities and evacuation of community,

USSG 2Q1.2(b)(3)

+4

12
13
14
15

Adjusted Offense Level:

27

In addition to these guidelines calculations, there are two applicable guidelines-based grounds

16 for upward departure. First, an upward departure is appropriate where the defendants criminal history
17 is inadequately represented. USSG 2Q1.2, App. N. 6 and 9(A); USSG 4A1.3. Here, PG&E has an
18 extensive history of violating the Pipeline Safety Act, as recounted in the PSR. A list of PG&Es prior
19 violations, pertaining to both its natural gas and electric lines of business, is attached to this Sentencing
20 Memorandum as Exhibit 1.
21

Second, an upward departure may be appropriate where an offense has caused extreme

22 psychological injury. USSG 2Q1.2, App. N. 9(B); USSG 5K2.3. PG&Es actions killed 8 people
23 and injured 58 others. They destroyed 38 homes and damaged another 70. There is no question that the
24 survivors of the explosion those critically injured, the family and friends of those killed and injured,
25 those whose homes were destroyed, and those who witnessed the death and destruction suffered
26 extreme psychological injury such as would warrant an upward departure.
27

USSG 8C2.1 governs the applicability of fine guidelines for defendant PG&E. Because

28 PG&Es guideline offense level is determined under USSG 2Q1.2, which is not listed in USSG
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1 8C2.1(a) or (b), USSG 8C2.10 applies. USSG 8C2.10 requires the Court to determine an
2 appropriate fine under 18 U.S.C. 3553 and 3572, which allow a maximum fine of $3,000,000.
IV.

ARGUMENT

When it comes to sentencing, [c]orporate criminal defendants present a special problem because

5 they cannot be incarcerated. United States v. Mitsubishi Int'l Corp., 677 F.2d 785, 788 (9th Cir. 1982)
6 (upholding sentence requiring corporations to loan executives for one year to a community organization
7 and to make a contribution of $10,000 for each violation to said organization). Monetary penalties offer
8 insufficient deterrence as large corporate defendants, like PG&E, can just write a check and walk
9 away. Id. For this reason, courts frequently are require[d] . . . to adopt unique and creative
10 sentences. United States v. Danilow Pastry Co., 563 F. Supp. 1159, 1166 (S.D.N.Y. 1983) (quoting
11 Mitsubishi, 677 F.2d at 788).
Such is this case. PG&Es pattern of deliberately violating federal regulations designed to

12

13 ensure the safety of its natural gas pipelines absent which the San Bruno explosion and devastation
14 could not have occurred together with its obstruction of the ensuing investigation, mandate a creative
15 and comprehensive sentencing strategy.
Title 18, United States Code, Section 3553(a) requires courts to impose a sentence sufficient,

16

17 but not greater than necessary . . . to reflect the seriousness of the offense, promote respect for the
18 law, provide just punishment, afford adequate deterrence, and protect the public from further
19 crimes of the defendant. In fashioning the sentence, courts must also consider the nature and
20 circumstances of the offense and the history and characteristics of the defendant. 18 U.S.C.
21 3553(a)(1). The sentencing proposal formulated by U.S. Probation creatively and comprehensively
22 meets these goals. The United States supports the proposal recommended by U.S. Probation, with a few
23 modifications as set forth below, and urges the Court to adopt it. The government asks the Court to
24 order that none of the fine nor costs of performing the conditions of probation be passed on, in any form,
25 to PG&Es customers.
26 A.

Fine

27

The United States shares Probations concerns that the statutory maximum fine of $3 million will

28 be a drop in the bucket for PG&E, and will do little to deter it from continuing to prioritize profits
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1 over complying with safety regulations. PSR Sentencing Recommendation at 2. This is all the more
2 true given that:
1.

PG&E boasted an income of $333 million in the second quarter of 2010, just

4 before the explosion. 1 See 18 U.S.C. 3572(a)(1) (defendants income a factor in setting fine).
2.

PG&E has acted as a bad corporate citizen for decades. Beyond the criminal

6 activity supporting the counts of conviction and relevant conduct its further obstructive acts and its
7 failure to maintain critical leak and strength test records PG&E has a long history of other, similar
8 regulatory violations. The Probation Office catalogued these in Part B of the PSR, and we incorporate
9 this list of prior misconduct here as Exhibit 1.
3.

10

PG&E held the trusted position of operating as a monopoly, with a guaranteed

11 rate of return and customer base.

Particularly given these circumstances, the expansive terms of the proposed probation program

12

13 are necessary to meet the purposes of 3553(a).

14 B.

Probation

15

Courts have broad discretion in setting probation conditions, United States v. Lowe, 654 F.2d

16 562, 567 (9th Cir. 1981), so long as they are reasonably related to the factors identified above, 18
17 U.S.C. 3563(b). All of the conditions identified in the PSR are reasonably related, and in fact
18 necessary, to address the 3553(a) factors. The United States wishes to comment on a few of these
19 suggested conditions.
20

1.

Safety Program

21

The United States strongly supports requiring PG&E to restructure its employee bonus formula

22 so that the safety record is paramount. As a regulated monopoly, PG&E has a guaranteed rate of return,
23 such that it should not be prioritizing profits. That PG&E pipes have continued to rupture even after the
24 San Bruno explosion (e.g., March 2014 explosion of residence in Carmel during PG&E work on gas
25 pipeline, due to inaccurate records) demonstrates that its management has not taken safety seriously
26 enough. When employees are rewarded based on meeting budgets or earnings per share goals, it is
27
28

See PG&Es Press Release dated August 4, 2010, PG&E Corporation Reports Second Quarter
Earnings: Reaffirms Guidance.
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1 inevitable that such factors will affect decisionmaking.

2

2.

Advertising Program

The government supports the condition requiring PG&E to notify the public of its criminal and

4 neglectful behavior, what it was convicted of, and the changes made within the organization to reduce
5 the likelihood of future criminal conduct and negligence. See U.S.S.G 8D1.4(a) (The court may
6 order the organization, at its expense and in the format and media specified by the court, to publicize the
7 nature of the offense committed, the fact of conviction, the nature of the punishment imposed, and the
8 steps that will be taken to prevent the recurrence of similar offenses.).
9

The government recommends that all of the terms specified in the PSR be adopted except that (a)

10 PG&E be required to use the same television networks and same or comparable airing times as it used
11 during its advertising campaign in January through August 2016 (the months before and during trial);
12 (b) PG&E be required to post advertisements in the San Francisco Chronicle and the Wall Street Journal
13 containing the delineated information; and (c) PG&E include a hotline number for the public to report
14 safety concerns and incidents involving PG&E. The first modification is designed to ensure that PG&E
15 reaches the same audience it intended to reach with its ramped-up advertising campaign preceding and
16 during trial. The second is designed to reach the non-television viewing audience, as well as potential
17 investors who may be located elsewhere in the nation. That investors be able to evaluate PG&Es
18 conduct and vote with their pocketbooks is particularly significant when consumers cannot due to
19 PG&Es monopoly status. The third modification will help protect the public.
20

3.

Monitor/Compliance and Ethics Program

21

The United States regards establishment of a corporate compliance and ethics monitorship as an

22 indispensable component of PG&Es probationary sentence. Both 18 U.S.C. 3563(b)(22) and

23 U.S.S.G. 8B2.1 authorize and encourage this Court to require felonious corporations to establish
24 standards and procedures to prevent and deter future criminal conduct. PG&Es history of
25 noncompliance with its regulatory obligations demonstrates that it cannot be trusted to prevent criminal
26 conduct on its own. Instead, this Court should impose a corporate monitor on PG&E to achieve some
27 measure of confidence that PG&E will comply with Pipeline Safety Act regulations to prevent future
28 tragedies, such as the deadly pipeline explosion in San Bruno.
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The government and the defense are attempting to reach an agreement regarding the terms of this

2 monitorship. Whether or not an agreement has been reached, the government will submit to the Court a
3 Proposed Order regarding this monitorship. The government anticipates asking this Court to order
4 PG&E to retain a monitor of the governments choosing. The Monitor will serve for a period of years
5 and oversee PG&Es efforts to safely supply natural gas throughout Northern California. Among his or
6 her duties, the monitor will review and report on PG&Es level of compliance with governing
7 regulations, including the federal Pipeline Safety Act.
8

4.

Community Service

The government adopts Probations recommendation of 10,000 hours of community service,

10 2,000 of which needs be performed by high level personnel, and that this community service be
11 performed to repair communities impacted by PG&Es offense conduct. See U.S.S.G 8B1.3
12 (Community service may be ordered as a condition of probation where such community service is
13 reasonably designed to repair the harm of the offense.); U.S.S.G. 3563(b)(12). This condition of
14 probation uniquely conveys the seriousness of PG&Es offense conduct and has the capacity to help
15 rebuild the communitys trust in a corporation whose deliberate choices put their safety at risk.
16 Moreover, it deters PG&E from making choices simply based on the cost PG&E cannot simply pay its
17 way out but actually has to spend its time and energy repairing the communities it harmed and put at risk
18 by its criminal conduct.
V.

19
20

CONCLUSION

PG&E violated the sacred trust placed in it by every person living in or merely passing through

21 Northern California to follow minimum standards of safety in operating its natural gas pipelines pipes
22 that transport highly explosive material under the publics homes, freeways, and businesses. Its
23 deliberate and repeated choices not to do so were motivated by the desire to maximize profits instead of
24 safety in other words, greed. The San Bruno explosion was not an accident; it was a matter of time.
25 And PG&Es efforts to corruptly mislead the federal investigation of the explosion highlight its status as
26 a bad corporate citizen.
27

PG&Es crimes compel a serious sentence that will alter its culture for good. Only through the

28 comprehensive probationary scheme laid out in the PSR, as modified in the governments proposal and
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1 together with the maximum fine allowed by statute, will the sentence reflect the seriousness of PG&Es
2 crimes, promote respect for the law, justly punish PG&E, and protect the public from further crimes by
3 PG&E, and adequately deter future such crimes.
4

Finally, the United States anticipates that several victims of PG&Es crimes, including

5 representatives from San Bruno and the NTSB, may seek to be heard at sentencing regarding the
6 impacts of PG&Es crimes. The government will make every effort to advise the Court of the number
7 of individuals who wish to speak prior to commencement of the sentencing proceedings.
8
9 Dated: January 9, 2017

Respectfully submitted,
BRIAN J. STRETCH
United States Attorney

10
11

/s/
12
HALLIE MITCHELL HOFFMAN
JEFFREY B. SCHENK
HARTLEY M. K. WEST
Assistant United States Attorneys

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01-1981

12-1991

08-1994

01-1996

01-2000

12-2003

SF FINANCIAL DISTRICT GAS LEAK - The NTSB determined that the probable cause for the 1981 puncture of a 16inch transmission line in San Francisco was a third partys failure to fully comply with the terms of an excavation permit.
The NTSB also concluded that a contributing factor during the gas leak was PG&Es inability to locate an emergency
shutoff value due to inaccurate record keeping. This valve had been paved over and another valve, which was close by, was
inoperable because of inadequate maintenance. The NTSB found that responding PG&E employees were not trained or
equipped to shut the valves. During the leak, natural gas had escaped into the atmosphere, contaminating 8 square blocks of
San Franciscos financial district. REPORT # PAR-82-01. NTSB Safety Recommendation P-82-1 through 3.
SANTA ROSA GAS EXPLOSION - In the early morning hours of December 28, 1991, two explosions occurred in a Santa
Rosa apartment building. Two people were killed and eight injured. A subsequent investigation showed the line was likely
ruptured by a third party and gas migrated underground into a nearby apartment building. The NTSB believed installation of
an automatic shut off valve would likely have prevented the explosion, as well as the continued release of gas during
emergency response activities, which endangered firefighters and other emergency personnel.
http://www.ntsb.gov/safety/safety-recs/recletters/P92_19_20.pdf
ROUGH AND READY FIRE After a wildfire tore through the Sierra foothills, the County filed criminal charges against
PG&E and property owners filed private lawsuits. PG&E was found responsible for failing to trim trees around its power
lines, despite having received $80 million dollars to perform the work. PG&E shareholders paid $22.7M in vegetation
programs and made a $6M contribution to the CPUC. CPUC Decision/CASE# D.99-07-029.
http://www.sfgate.com/news/article/PG-E-Faces-Charges-Over-Fire-Safety-Nevada-3026642.php
HINKLEY GROUNDWATER CONTAMINATION - The town of Hinkley, California had its groundwater contaminated
with hexavalent chromium starting in 1952, resulting in a legal case against Pacific Gas & Electric (PG&E) and a multimillion-dollar settlement in 1996. PG&E operates a compressor station in Hinkley for natural gas transmission pipelines.
Natural gas has to be re-compressed approximately every 350 miles, and the station uses large cooling towers to cool the gas
after it has been compressed. Between 1952 and 1966, the water used in these cooling towers contained hexavalent
chromium now recognized as a carcinogen to prevent rust in the machinery. The contaminated water was stored between
uses in unlined ponds, which allowed it to percolate into the groundwater. This led to groundwater pollution, affecting soil
and contaminating water wells near the compressor station, with a plume approximately 2 miles long and nearly 1 mile
wide.
GAS PIPELINE REPLACMENT PROGRAM to RMP In approximately the year 2000, PG&E transferred its Gas Pipeline
Replacement Program (GPRP) into the Risk Management Program (RMP). While PG&E claimed its intent was to better
prioritize and manage risk, it failed to do either and instead just cut costs. GPRP had called for replacement or hydrotesting
of miles of transmission pipeline, including Line 132.
PLANNED PRESSURE INCREASE PROGRAM - Rather than perform costly integrity assessments on its oldest pipelines,
PG&E opted to artificially increase the pressure in an effort to establish known manufacturing threats as stable. PG&E often
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PG&E Incidents: Other Acts

12-2003

12-2003

01-2005

07-2005
08-2005

01-2007

01-2007

increased the pressure of these pipelines beyond what they were allowed by federal law, rendering otherwise stable threats
now unstable. This program, as described by the CPUC, was a wrong-headed approach to safety.
UNPLANNED PRESSURE INCREASES - PG&E became aware that on occasion certain transmission lines experienced
unplanned pressure increases, where the pressure of certain pipelines exceeded federal limits. Some of these pipelines had
known but stable manufacturing threats before the pressure excursion. When the overages occurred, these threats became
unstable because PG&E did not have strength test pressure records that would have vouched for the pipes integrity.
SUBSTATION FIRE This PG&E Substation fire at 8th and Market Streets in San Francisco followed a 1996 fire at the
same location, for which the CPUC had issued a root cause analysis and safety recommendations that PG&E did not fully
implement. The second fire burned for two hours before someone noticed it and resulted in more than 100,000 people
losing power. The CPUC recommended a $10 million fine, which PG&E ultimately negotiated to $6 million to pay for
improvement programs and $500,000 to the States General Fund. CPUC OII 05-03-2011 Decision / CASE # 06-02-003.
PG&E EMPLOYEES FALSIFY REPAIR RECORDS AND SUPERVISOR COERCES SUBORDINATES TO
DOWNGRADE LEAKS A PG&E employee reported to law enforcement that he knew of an investigation involving the
falsification of gas repair maintenance records and a PG&E supervisor who coerced employees into downgrading gas leaks
to make them less of a repair priority. The investigation revealed that PG&E zeroed out these leaks without any repairs.
LOS ALTOS GAS EXPLOSION - A gas explosion nearly leveled a home in Los Altos. The owner was extracted from
rubble and his young children narrowly escaped.
TRANSFORMER EXPLOSION - PG&E transformer exploded in the San Francisco downtown area. The fire severely
burned a woman who was also struck by a flying manhole cover. This explosion brought about a related investigation in
which PG&E workers lied about performing required inspections.
PG&E VIOLATION OF BACKBILLING CUSTOMERS The CPUC found that PG&E systematically violated its tariff
rules by failing to issue bills at regular intervals based on actual metering data and improperly issuing backbills. The CPUC
ordered PG&E to refund, at shareholder expense, approximately $35 million for these unauthorized charges. CPUC
Decision / Case # 07-09-041. http://docs.cpuc.ca.gov/PublishedDocs/WORD_PDF/FINAL_DECISION/73124.PDF
CYCLIC FATIGUE - PG&E failed to create or adopt a policy to assess cyclic fatigue within its gas transmission pipeline
system, as required by federal law. The NTSB report issued following its investigation of the San Bruno Explosion stated
that pipeline safety regulation 49 C.F.R. 192.917(e)(2) requires an operator to conduct an analysis for cyclic fatigue,
assuming the presence of threats that cyclic fatigue can worsen, and considering other loading conditions that can induce
additional stresses on the pipeline. PG&Es integrity management team had previously decided not to conduct an analysis
for cyclic fatigue, based on a report by John Keifner entitled Evaluating the Stability of Manufacturing and Construction
Defects on Gas Transmission Pipelines (2007). This study, however, was premised on a testing of pipelines that had been
subjected to hydrotesting.
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PG&E Incidents: Other Acts

11-2007

12-2008

01-2010

09-2010

FALSIFIED LEAK SURVEYS - PG&E employees in the north bay falsified numerous leak survey reports, claiming a line
had been surveyed when it had not. PG&E had to create a new program, Accelerated Leak Survey (or ALS), to re-survey
large geographic areas.
RANCHO CORDOVA GAS EXPLOSION - In September 2006, PG&E responded to a gas leak at a residence in Rancho
Cordova. The source of the leak was a two-inch gas main located on the residents property. PG&E repaired the leak by
inserting twenty feet of polyethylene pipe inside the older two-inch pipe. Two years later, on December 24th, 2008, the
residence exploded, killing the home owner and injuring several others. The NTSB concluded that the probable cause for the
explosion was the use of a section of unmarked and out-of-speculation polyethylene pipe with inadequate wall thickness,
which allowed gas to leak from the coupling installed in 2006. In November 2010, the CPUC concluded that the explosion
was a result of the use of the 2006 pipe insert, which did not meet federal or state requirements for gas transportation.
In May 2011, the CPUC received an unsolicited pressure test video from PG&E, dated January 14, 2010. The video depicts
the piece of substandard pipe from the explosion failing a pressure test within a few seconds. It is believed that PG&E
withheld this video from the NTSB and CPUC, despite requests for such documentation. PG&E terminated employment of
the employee responsible for the 2006 repair but did not advise the NTSB and CPUC until their investigations concluded.
PG&E was fined $38 million dollars for this incident. A CPUC Commissioner stated:
However, I do not think we can put Rancho Cordova to rest with this decision. We need to ensure that we have
addressed adequately all of the problems that led to this disaster - improper training and inadequate equipment for
workers in the field, slow and ineffective responses to the report of gas odor, failure to follow internal procedures for
pipe repair and installation, poor recordkeeping, the use of unsuitable pipe, and most critically, the failure to take a
pro-active approach to safety issues.
CPUC Decision/CASE # 11-12-021. NTSB PAB-10-01.
http://www.ntsb.gov/investigations/AccidentReports/Reports/PAB1001.pdf
SAN JOSE - PG&E FAILS TO INSPECT UNDERGROUND ELECTRICAL SWITCHES AND TRANFORMERS. PG&E
experienced a string of explosions and fires in underground vaults in San Francisco. PG&E stated that it inspected the
equipment, but PG&E subsequently acknowledged that an employee reported a colleague as falsely certifying underground
electrical switches and transformers without inspection. A probe of the accusation found that about two dozen inspections
had not been carried out and another fifty were suspect; 14 workers were dismissed or suspended. In June 2016, however,
PG&E informed the CPUC that inspection concerns were far more widespread than company officials originally feared,
identifying 401 inspections that it suspected were not carried out. In October 2016, the CPUC cited PG&E for not having
carried out those inspections.
CASTRO VALLEY MAPPING ERROR - On September 17, 2010 PG&E failed to follow federal regulations and its own
standards when a third party contractor struck a 1-inch plastic gas service line that caused the release of natural gas into the
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PG&E Incidents: Other Acts

09-2010

09-2010

09-2010

04-2011
09-2011

09-2011

09-2011

atmosphere and a service interruption for four customers. The plastic pipes location was not clear due to a mapping error
resulting from incorrect field documentation of the historical gas service records. PG&E admitted that plat map errors were
found throughout its service territory. The investigative arm of the CPUCs California Protection and Safety Division
determined that PG&E did not have accurate construction records, maps, and operating history available to operating
personnel. INCIDENT # G20100917-01.
PG&E FOUND TO BE DEFICIENT IN POST EXPLOSION EMERGENCY RESPONSE - It took over ninety minutes for
PG&E employees to shut down the flowing gas in the Line 132 rupture. The NTSB Pipeline Accident Report discusses
deficiencies in PG&Es practices and procedures regarding emergency response, isolation and shutdown after the rupture,
quality control and integrity management. The report states that PG&E lacked a response command structure with defined
leadership and support responsibilities, and PG&Es emergency plan execution resulted in avoidable delays.
PG&E FOUND TO BE DEFICIENT IN THE WORK CLEARANCE PROCESS AT MILPITAS - Just before the San
Bruno explosion, PG&E employees were working on an exercise at Milpitas Terminal. Failure of equipment in this exercise
allowed gas to surge up the line to San Bruno, where Line 132 ruptured. The NTSB investigation identified several
deficiencies in the work clearance process used for the Milpitas Terminal electrical work.
PG&E MOUNTAIN VIEW MAPPING ERROR - On 9/17/10, a third party contractor digging a new storm drain for the
City of Castro Valley (Redgwick Construction Company), struck a 1-inch plastic service at 19879 San Miguel Avenue
which released gas into the atmosphere because PG&E did not have accurate records of the pipes location due to incorrect
field documentation from the historical gas service records. PG&E claims that plat map errors are found throughout PG&E's
service territory and each division is working to correct them as they are identified. Based on the CPUC investigation,
PG&E was in violation of Pipeline Safety Act regulations. INCIDENT # G 20100917-01.
CENTRAL COAST DIVISION AUDIT (01/2003 - 04/2011) - Audit findings include mapping errors, missed inspections,
missed equip testing, missed scheduled work orders/tags, missing high voltage signs, and record errors.
PG&E EMPLOYEE REPORTS FAILRURE TO MAKE LEAK REPAIRS - A PG&E employee wrote to CA Attorney
General Kamala Harris, the US Department of Transportation, the CPUC, and PG&E claiming to have evidence that PG&E
downgraded the severity of gas line leaks and failed to make required repairs. The employee advised that he reported the
failures to his supervisors but feared PG&E had still not made the repairs.
CUPERTINO GAS EXPLOSION - A gas explosion resulted from the failing of a plastic pipe, causing a fire that partially
engulfed a townhome. The NTSB had issued warnings about this type of plastic pipe that was prone to premature
brittleness, cracking, and failure. A PG&E employee advised: "It's been failing left and right. It's common knowledge
throughout PG&E, and PG&E has refused to address it."
ROSEVILLE ROADWAY GAS LEAK FIRE - A PG&E gas leak fully engulfed a roadway in fire when a 4 gas line
ruptured. PG&E reported this was the second time the line under that intersection ruptured and the gas line had previously
been scheduled for replacement.
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PG&E Incidents: Other Acts

10-2011

11-2011

02-2012

06-2012

06/2012

02-2013

PG&E INVESTIGATED FOR FORGED OPERATOR QUALIFICATION DOCUMENTS - Each operator employee or
contractor who performs specific safety-sensitive operations or maintenance activities on the pipeline system must be tested
to ensure he/she had the necessary knowledge, skills, and abilities to perform each task, and recognize and react to
emergencies that may arise while performing those tasks. A former PG&E employee claimed that PG&E fired him after he
challenged supervisors about employees being tasked to work on pipelines for which they were not qualified, asserting that
some training documentation, including documentation in his own file, had been forged.
CLASS LOCATION VIOLATIONS - PG&E used pipe segment strength (SMYS) values that exceeded 24,000 psi for
segments that did not have traceable, verifiable, and complete pressure test records in violation of 49 C.F.R. 192.107(b).
PG&E admitted that there were 133 such violations for a total of 1,191,662 days. PG&E further admitted that 843 pipeline
segments were not accurately classified in violation of federal regulations and that it did not perform a class location study
under 609 for the 172.1 miles of transmission pipe that changed up in class. PG&E admitted that its written pipeline patrol
procedures do not reference continuing surveillance regulations and do not discuss procedures for continuing surveillance.
http://www.cpuc.ca.gov/NR/rdonlyres/1865E039-2482-43A4-91A5-E9E28C40A00A/0/I1201007
etalCPSDOpeningBriefonFinesandRemedies.pdf
PG&E FAILURE TO PERFORM LEAK SURVEYS AS REQUIRED BY LAW - PG&E did not perform several leak
surveys for certain pipeline facilities. The CPUC fined PG&E $16.7 million. CPUC Decision/CASE # 2012-01-001.
http://www.cpuc.ca.gov/NR/rdonlyres/3BDE82E8-8484-48CE-8DFB-1FEAA8449C9E/0/Citation13003PGE.pdf
PG&E MORGAN HILL GAS MAPPING ERROR - On 06/12/2012, a third party contractor struck and damaged an
unmarked inch steel gas service line causing a release of natural gas after PG&E had failed to locate and mark steel
service line (the plat map was not updated to reflect it). One customer lost gas service and two structures were evacuated as
a precaution. The investigative arm of the CPUC determined that PG&E failed to mark the service line that was hit, provide
its employees with accurate maps and available information regarding its gas infrastructure, review its information and maps
for accuracy, and follow its own procedures. INCIDENT# G 20120621-01.
06/19/2012 KERN POWER PLANT FATALITY - CPUC investigation following fatality found that PG&E failed to
actively manage contractor work, accept responsibility for work at PG&E facilities, review work plans, ensure worker
safety, evaluate and rank contractor qualifications and safety data programs, and conduct and submit root cause analysis. It
further found that PG&E emphasized reduced liability over risk assessment and lacked an effective safety culture.
NORTH BAY DIVISION AUDIT - The audit findings include: PG&E had several overhead and underground facilities that
were not inspected, approximately 13,000 work orders were completed past or still open past their date of corrective action,
mapping errors were not caught or noted by PG&E inspectors, and PG&E failed to document and address violations in field
inspections. The CPUC expressed concern that PG&E provided inaccurate data responses, which raised questions about the
integrity of PG&E's reports, and that PG&Es was missing patrol and inspection maps/logs.
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06-2013

07-2013

11-2013
12-2013

03-2014

08-2014

11-2014

LOS PADRE DIVISION AUDIT - The audit resulted in findings including: PG&E failed to inspect over 180 facilities,
failed to complete approximately 6,100 work orders on time, failed to document all corrective action, failed to document and
address violations found in field such as defective transformer, incorrect corrective action priority, corroded and pitted
transformer. The CPUC expressed concern that PG&E sent a data response to the CPUC that included inaccurate patrol and
inspection data. The data made it difficult to verify compliance of a general order being inspected.
PG&E FAILED TO KEEP RECORDS UP TO DATE IN MOUNTAIN VIEW A PG&E crew welded a fitting onto a 1
inch steel service line casing in Mountain View, without realizing that service line casing had 1-inch plastic line insert. The
insert melted, causing a release of gas which went unnoticed due to the gas traveling down the steel service line casing away
from the work area. The record provided to the PG&E crew did not accurately reflect the inserted plastic service line, in
violation of 49 C.F.R. 192.605(b)(3), which requires that construction records, maps and operation history be made
available to appropriate operating personnel. INCIDENT # G20130730-01.
PG&E INADEQUATE TESTING - A PG&E contractor performed inadequate X-Ray on Line 114 in Brentwood, CA.
PG&E was fined $8.1M for violations of General Order 112-E between 2011 and 2013. Citation # 13003.
SAN CARLOS - In October 2012, PG&E discovered a leak on Line 147 after a hydrotest. While PG&E records reflected
this pipe segment did not have a seam, crews discovered seams when they dug up the pipe segment; they also discovered
other pipe characteristic inaccuracies. These characteristics and records deficiencies were similar to what occurred in San
Bruno. PG&E waited until March 2013 to inform CPUC staff of this discovery and until July 2013 to make an official filing
of this situation. In December 2013, the CPUC fined PG&E $50,000 per day of delay, for a total of 229 days ($11.45
million). The CPUC also fined PG&E $2.9 million for filing an errata, downplaying the public safety concern, stating that
PG&Es explanation of the situation was profoundly disheartening and demonstrated a lack of candor.
PG&E GAS EXPLOSION IN CARMEL - PG&E crews were attempting to replace a gas distribution line but were unaware
of a plastic insert because of inaccurate records. When they cut into the pipe, they pierced the insert, allowing gas to leak
into the residence, which resulted in a gas explosion that destroyed the residence. In November 2014, the CPUC fined
PG&E $10.85 million. CPUC Case I.14-11-008; INCIDENT # G 20140303-01.
PG&E MEMO ON INADEQUACY OF SECURITY MEASURES - PG&Es Senior Director of Corporate Security advised
PG&E President Chris Johns in a memo that their efforts at security continue to be slow, piecemeal and uncertain. . . . in
reality PG&E is years away from a healthy and robust physical security posture.
https://www.documentcloud.org/documents/2081637-pg-amp-e-memo-august-30-2014.html
EXPLOSION, INJURY, and OUTAGE - Improper installation of conductor that was in use from 1990-2014 and failure to
properly mark underground facility resulted in explosion, injuries (burns to the face, head, and arms), a sustained (10-hour)
outage affecting 635 customers, and a momentary outage to 5,718 customers. PG&E failed to report the incident as required
to the CPUC.

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01-2015

04-2015

PG&E CITED BY CPUC FOR VIOLATIONS OF 192.925(b)(3), 192.935(a), and 192.937(a) and(b) from 2004 through
2012. PG&E failed to follow proper ECDA procedures when it reclassified immediate indications to avoid excavations,
and did not generate LTIMP reports in a timely manner. The CPUC found no documentation verifying that PG&E
performed continual evaluation for establishing reassessment methods and schedules by considering all information relevant
and required under the code. These violations were not self-reported but were discovered in an audit. PG&E was fined
$430K for these violations. CITATION # ALJ 274 15-01-002
On April 9, 2015, the CPUC imposed a $1.6 billion penalty against PG&E for unsafe operation of its gas transmission
system. PG&E has since accepted this penalty, which resulted from the following three Orders Instituting Investigation
(OIIs): (1) Investigation 12-01-007: Violations of Public Utility Code 451, General Order 112 and other applicable
standards, laws, rules and regulations in connection with the San Bruno explosion and fire on September 9, 2010; (2)
Investigation 11-11-009: Practices of PG&Es natural gas transmission pipeline system in locations with high population
density; and (3) Investigation 11-02-016: Practices of PG&E with respect to facilities records for its natural gas
transmission system pipelines. The CPUC stated:
The Commissions investigations into the San Bruno gas transmission pipeline explosion, PG&Es recordkeeping
practices and PG&Es pipeline classification related to higher density populations have brought to light the
characteristics and consequences of PG&Es longstanding failure to heed federal and state regulations governing the
safe operation of natural gas transmission pipelines throughout its system. This decision adopts penalties to be
imposed on Pacific Gas and Electric Company (PG&E) for violations arising from: (1) the September 9, 2010 San
Bruno explosion and fire; (2) PG&Es recordkeeping practices for its gas transmission pipeline system; and (3)
PG&Es failure to maintain the proper class designation for pipelines in areas of higher population density. The
Commission hereby imposes a fine and other penalties and remedies totaling $1.6 billion. This consists of: $850
million in future gas infrastructure improvements related to transmission pipeline safety to be paid for by PG&E
shareholders; $300 million fine payable to the General Fund; $400 million bill credit to PG&Es gas ratepayers in
the form of a one-time bill credit; and Approximately $50 million to implement over 75 remedies proposed by the
Commissions Safety and Enforcement Division previously called the Consumer Protection and Safety Division
(CPSD) and other intervenors to enhance pipeline safety.
PG&E committed 2,425 violations of various provisions of Part 192 of Title 49 of the Code of Federal Regulations,
Pub. Util. Code 451, the 1955 American Society of Mechanical Engineers Standard B.31.8 (and its subsequent
revisions), General Order 112 (and its subsequent revisions), and Rule 1.1 of the Commissions Rules of Practice and
Procedure. Many of these violations occurred over a number of decades, for a total of 18,447,803 days in violation.
In some cases, the violations lasted for nearly 60 years. PG&E identified some violations in prior years, and some
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PG&E Incidents: Other Acts

later violations prevented the identification and/or correction of prior violations. Records indicating the deficient
materials, installation techniques, and pipeline locations were lost, in some cases with PG&Es knowledge that
records were missing, PG&E deferred some needed pipeline integrity investments, even though the Commission had
authorized rate recovery for gas transmission safety investments. Where violations accumulate in the manner PG&E
allowed, the accumulation compounds the risk to the safety of the public and to workers. Our decision to use a mix
of penalties and remedies is based on our intention to penalize PG&E for its violations and to deter similar behavior
and violations in the future.

09-2015

10-2015

http://docs.cpuc.ca.gov/PublishedDocs/Published/G000/M151/K034/151034091.PDF
http://docs.cpuc.ca.gov/PublishedDocs/Published/G000/M150/K539/150539121.PDF
OII WHETHER PG&E CORPORATION PRIORTIZES SAFETY - The CPUC instituted an investigation to determine
whether PG&E Company and PG&E Corporation had an organizational culture and governance that prioritized safety and
adequately directed resources to promote accountability and achieve safety goals and standards. During the first phase of
this proceeding, the CPUC directed its Safety and Enforcement Division to evaluate the Companys and Corporations
organizational culture, governance, policies, practices, and accountability metrics in relation to PG&Es record of
operations, including its record of safety incidents, and to produce a report on the issues and questions contained in this
order. In a later phase of this investigation, the CPUC reserved the right to revise existing orders or imposing new orders
and conditions on PG&E or PG&E Corp. as necessary and appropriate to optimize public utility resources and achieve the
operational standards and performance record required by law. DOCUMENT# I.15-08-019.
http://docs.cpuc.ca.gov/PublishedDocs/Published/G000/M154/K363/154363217.PDF
COLLAPSE OF ELECTRIC TRANSMISSION TOWERS Electric transmission tower collapses result in significant
equipment and structure damage and customer outages. Root cause analysis: Inadequate design and construction;
inadequate tower design training, inadequate maintenance of drawings, inadequate training for identification of field
tolerances and issues.

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