FURTHER QUESTIONS: Since June 2018, we've received or have noted questions that were not part of the original question list. PLEASE NOTE: this does not include the many follow-up questions based on the vague or incomplete answers by PG&E to many of the original questions. These are separate concerns.

New Questions

Gas Pipeline Questions for PG&E:

 

  1. Why did PG&E show a slide on Sept 10, 2018 at Lafayette City Council showing all cathodic protections were in place for all pipelines in Lafayette, and all working correctly when residents noticed that several days AFTER the Sept 10th meeting, PG&E had installed new cathodic protection coupon stations near 655 Glenside Ave on the Lafayette-Moraga Trail? The foreman at the site said coupon stations needed to be placed at exactly one-mile intervals, and long-time residents report coupon stations have never appeared in this area before. Why did the workers in this area say the pipeline wasn't located where they thought it should be, while they were digging?
     

  2. The application of herbicides is a surprise to many people when they are given the implementation details for the CPSI program. Which brand of herbicides will be applied to the freshly-cut stumps at each tree removal location? What decisions are made about the application given the location, and what public notification is posted before these chemicals are applied?
     

  3. Does PG&E agree that DNV's answer to the question "whether dead tree roots may initiate and/or accelerate pipeline corrosion growth," can be accurately summarized as:  "insufficient data collected and no conclusions reached"?  If PG&E disagrees, please explain.
     

  4. Does PG&E agree that the concern raised in the 2013 report about potential corrosion caused by dead tree roots is an issue that warrants thorough investigation?  If not, please explain.
     

  5. (Correspondence by Dave Kosters to PG&E, Aug 2018):
    "On May 16 I asked you about the contradictions among PG&E experts about whether its gas transmission lines are routinely de-pressurized before attempting repairs when a gas integrity emergency occurs.  I pointed out Les Putnam's response to me on May 9 at the open house, where he said each emergency response is different, so there is no way to meaningfully address my question apart from saying, "it all depends."  I also asked to see a copy of PG&E's emergency response procedure covering this topic.  Your July 18 letter to me says that my request to view PG&E's emergency response plan is being denied for national security reasons.  You go on to essentially validate what Les Putnam told me on May 9--it all depends on the situation.

    "On May 30 I attended a pipeline safety workshop in Richmond hosted by the Alamo Improvement Association, the Pipeline Safety Trust, and the Contra Costa County Hazardous Materials Commission.  Andy Wells, Manager, Gas Emergency Preparedness for PG&E, spoke at this meeting and I asked him to explain PG&E's current practice regarding de-pressurizing its gas transmission lines in the event of an emergency.  I explained that I had been told by another PG&E spokesperson (Mr. Putnam) that the procedure is situation-dependent and that it is not uncommon for PG&E to weld on active (pressurized) gas transmission lines to accomplish repairs in a gas emergency.  Mr. Wells said that in the past PG&E's practice was sometimes to make repairs to an active transmission line, but that PG&E has adopted new procedures for dealing with transmission line emergencies and attempting repairs to an active line is no longer necessary."

    My questions:
    Is Mr. Wells correct?  If not, please explain why PG&E's manager of gas emergency preparedness is unfamiliar with this rather significant aspect of the company's emergency response procedures.
     

  6. Regarding the above, in the past year I've asked this same question four times of PG&E experts on gas emergencies.  Twice I've been told the company routinely de-pressurizes gas transmission lines to make emergency repairs; twice I've been told that's incorrect--it's variable and every situation is different.  Are PG&E's emergency procedures so complex that the company's managers can't keep them in mind to answer the question I asked?  If not, what is the explanation for the inconsistent answers I've received?
     

  7. Regarding the above, I'm concerned that if every emergency transmission line incident requires a tailored, situation-based approach, then the decision making process may be slow and inappropriately-reliant on a small group of company experts who may not always be available.  Please explain how the decision is made about how to proceed in a gas emergency, what levels in the organization get involved, and the range in time required for this decision making.
     

  8. Less than two-weeks after the Sept 10 PG&E meeting with City Council, the Lafayette-Moraga Trail was marked up with many pipeline markings, including "NO PG&E", pipeline locations by alphabet designation, and other markings. What project is being conducted, for what purpose are the markings used, and what do each of these markings mean?
     

  9. In the 2014 presentation to the CPUC titled "Threats Posed by Trees on ROW", PG&E employees outlined the following tree removal consideration: "Evaluate whether removal of tree on top of pipe (or in close proximity) could adversely impact pipeline integrity ❖ Determine whether vertical displacement occurs with tree removal. Unloading of pipe / potential to add strain to girth welds ❖ Consider what constitutes a tree 'on top of' or 'in close proximity' to the pipe." What follow-up evaluation did PG&E conduct since 2014 to evaluate the adverse impacts of tree removal as described here?
    (source: http://publicrecords.checksandbalancesproject.org/repository/20150130ReA1312012R/pdf/2014/04/SB_GT%26S_0024788.pdf)
     

  10. For the mature trees cut down by PG&E contractors, what happens to the wood and biomass? Does PG&E and/or the contractor monetize this resource in any way, including the exchange of value between contractor and PG&E, or other form of monetization?
     

  11. How many trees have been removed by PG&E as part of the CPSI program throughout the state of California?

101. Is the planned 2021 installation of two automated valves in Lafayette guaranteed to happen?

102. In 2007, Contra Costa County began requiring automatic gas shut-off devices in all new buildings and in existing buildings upon sale/significant modification. The purpose of this requirement is to reduce the risk of fire/explosion in the event of a major earthquake. Does PG&E agree that the above requirement is a prudent step to improve community safety?

103. Regarding the above, over the past 20 years, U.S. pipeline operators reported to PHMSA 47 transmission pipeline safety incidents where the cause was attributed to earth movement (2.3% of all incidents reported). What was PG&E’s transmission line incident rate due to earth movement in this period?

104. Regarding the above, what percentage of PG&E’s transmission line valves are manual, as opposed to automatic/remotely controlled? How has this percentage changed in the period 2010-2018?

105. Regarding the above, does PG&E agree that pipeline safety risk due to earth movement is a relevant consideration that weighs in favor of installing automatic/remotely controlled valves on transmission lines, and particularly when installing new and replacement lines in populated areas such as Lafayette?

106. In the 2010 San Bruno explosion, the NTSB said it took more than 90 minutes to shut down the gas supply, and NTSB experts concluded that this likely increased the community damage. In 2011, Rep. Jackie Speier introduced a bill in Congress that would require natural gas pipeline operators to install automatic or remote shutoff valves in all urban areas and within 10 miles of high-risk earthquake faults. The NTSB concluded as part of its San Bruno investigation that auto/remote controlled valves should be installed in HCAs and in class 3 & 4 locations; the 2011 Federal Gas Safety Act (signed into law January 2012) specifies auto/remote controlled valves for new and replacement gas transmission lines. Are explosions a more common event on transmission lines than on distribution lines when an unintentional gas release occurs?

107. Regarding the above, does PG&E agree that automatic/remotely controlled valves on transmission lines can improve community safety?

108. Regarding the above, does the San Bruno community that was most impacted by the 2010 transmission line explosion now have automatic/remotely controlled valves installed to enable fast shut-off in the event of an emergency?

109. Regarding the above, why is PG&E planning to install manual valves as part of its St Mary's Road pipeline replacement project?

110. How many sectionalizing block valves are currently installed in Lafayette's transmission lines to provide timely shut-off in the event of an emergency? What are the distances along each pipeline segment between these valves, and the associated federal classification for each segment (e.g., HCA, class 2, etc.)?

111. Which block valves in Lafayette will not accommodate in-line inspection as currently configured?

112. PG&E plans to replace the transmission line manual shut-off valve located near Reliez Station Road and Olympic with a remotely controlled valve within the next two years. Over the past five years, how many auto valves has PG&E installed in its transmission lines? How many remotely controlled valves?

113. Regarding the above, what are the considerations that most often drive the selection of auto vs remotely controlled valves on transmission lines in PG&E's system?

114. Regarding the above, can a modern auto valve accommodate a remote signal to close in essentially the same fashion as a remotely controlled valve?

115. Regarding the above, why has a remotely controlled valve been chosen over an auto valve for Reliez Station Rd and Olympic Blvd?

116. What are PG&E’s standards for placing an automated (automatic or remote-controlled) valve in new or reconstructed transmission pipeline installations?--In what ways are these standards different for Class 1-4 and HCA locations?

117. PG&E confirmed that the valve that will be installed in the summer of 2018 at S. Lucille and St. Mary’s Road will be a manually operated valve to help facilitate future maintenance. However, in other communities manually operated valves are being replaced with automate valves. One example: 

 

“As part of its Pipeline Safety Initiative, PG&E is installing an automated gas valve system located on South Novato Boulevard across from Cowbarn Lane. This system includes above ground valve assemblies that are remotely controlled via a wireless antenna connection—allowing PG&E to shut-off the flow of natural gas through its pipelines in the event of an emergency. This is one of many safety improvements PG&E is making to its natural gas system throughout California. “ (Source: http://novato.org/about-novato/hot-topics/pg-e-community-pipeline-safety-initiative). 

 

What type of valve is being replace at S. Lucille Lane? Why is this safety improvement being made in Novato, but not  in Lafayette and Moraga?

 
Pipeline Infrastructure: Cathodic Protection

118. Have there been, or is there currently, any instances of inadequate cathodic protection in Lafayette? Please list the incidents.

119. Safety incidents on PG&E's transmission lines have been increasing in recent years, based on PHMSA data. What role does cathodic protection play in mitigating this risk?

120. How often does PG&E verify the proper functioning of the cathodic protection system on each of Lafayette's transmission lines? How does this frequency compare with PG&E standards and PHMSA regulations?

121. What the benefits of installing continuous monitoring (telemetry to central monitoring station) of the cathodic protection system? What is restraining the installation of such a system for Lafayette's transmission lines?

122. Cathodic coupon stations were newly installed last year along the Lafayette-Moraga Trail after residents raised safety concerns regarding the transmission pipeline. We're glad PG&E is responding to our safety concerns, but what was your reason for installing these stations at this time? What was your rationale for the locations selected?  What benefits/potential benefits do you associate with this change?  What other locations within Lafayette might benefit from a similar upgrade?

 

Pipeline Infrastructure: Coating

123. In PG&E’s May 2018 Open House information packet, (page 2), 11 instances of coating being damaged in the past 13 years is provided as “evidence” that tree roots cause pipeline corrosion, however this information doesn’t give a complete picture. What is the TOTAL number of coating damages, any cause (rocks, earth movement, age of coating, etc), reported during the last 13 years along PG&E’s entire gas transmission pipelines, and what were the causes of these incidences? Please rank cause of damage to pipeline by frequency. 

(Source: https://docs.wixstatic.com/ugd/de4240_e8e518be538e4df5be6f01e4cb58bc2d.pdf)

124. Regarding the above, what were the species of trees that caused this damage? what is the depth of pipeline in each instance, and distance from tree? Type of soil? Were there any instances of actual pipeline corrosion?

125. Regarding the above, how were these instances discovered by PG&E? 

126. During the May 2018 PG&E Open House in Lafayette, PG&E representatives said that the current standard for pipeline coating is an enamel epoxy that is installed during fabrication. What studies has PG&E conducted on tree root interference with this type of coating?  What were the findings and recommendations from these studies?

127. According to the 2014 Dynamic Risk Assessment report: “While additional investigation of the impact of tree roots on various coating types is warranted, the current data indicates PG&E can consider coating as an attribute for predicting the interaction with tree roots. Of the 45 sites where the external coating types were either hot applied asphalt or coal tar enamel, coating damage was identified at 38 sites (or 84%). For the 8 remaining sites where the external coating type was polyethylene tape, 2 sites (25%) identified coating damage. The reason for this difference was not resolved as part of this study.”  Given the extreme differences in root/coating interaction based on the type of coating, with tape being more protective than asphalt, what is the coating type at each proposed tree-removal location? What additional investigation has happened since this report was released?

 
Pipeline Infrastructure: Manufacturing

128. In the April 23, 2018 presentation to Lafayette City Council, PG&E showed a slide titled "Pipeline Scope and Background" which characterized DFM 3001-01 as follows: "The existing welded steel pipelines in Lafayette are considered critical infrastructure and were installed along St. Mary's Road in 1952. Pipe installed in this era was welded before modern radiography was used to inspect welds and as such the welding inspection was only visual. Additionally, modern manufacturing practices are far superior to those of that historic era." In fact, numerous City of Lafayette communications confirms this project is to “replace the aging pipeline.”  If PG&E is replacing this pipeline from S. Lucile to Rheem, in part due to age and construction concerns, how is PG&E unconcerned with the remainder of the same pipeline with the same characteristics, north of S. Lucile to downtown Lafayette?

129. What are the top five transmission pipeline maintenance practices that impinge on pipeline lifespan?  Please quantify the potential lifespan-shortening effect for each of the maintenance practices if they are not followed.

130. One finding of the NTSB after San Bruno was the fact the pipeline was "fabricated at an unknown facility to no known specification". Please tell us where the Lafayette pipelines were fabricated, and to what specification.

(Source: https://www.pipelinelaw.com/wp-content/uploads/sites/24/2013/07/NTSB_Final_SB_Report.pdf

131. The effects of wrinkle bends on the long-term integrity of pipelines are a recognized concern in the industry. According to a 2009 article in Pipeline and Gas Technology magazine, “At the time, contractors commonly used a process of conforming steel pipe to the surrounding topography by forcefully compressing the pipe to create a bend in it. This technique created what have come to be known as "wrinkle bends" in the pipe."  Are there any wrinkle bends in any of the pipelines in Lafayette?
(Sources: http://compositerepairstudy.com/downloads/Evaluating_the_effects_of_wrinkle_bends_(September_2009).pdf  and http://www.naturalgasintel.com/articles/89168-southern-seeks-to-iron-out-wrinkle-bend-hazards-on-pipe-system )

132. PG&E reports that Lafayette pipeline includes Electric Resistance Welds (ERW), Furnace Butt Welds, Lap Welds, Seamless and Spiral weld types. Low frequency ERW, Furnace Butt, and Lap welds are known to be of poor quality and are obsolete. As PG&E reports, in-line inspection (ILI) is not currently available to Lafayette. How has PG&E been historically testing integrity of these seam welds to regulatory standard? (source: 192.241 weld inspection)

133. According to PG&E’s May 2018 Open House document, “The U.S. Department of Transportation’s Pipeline & Hazardous Materials Safety Administration, for example, states that the life of a pipeline is virtually endless if it is constructed and maintained correctly. That’s one of the reasons why this gas safety program is so important.” Given the answers to other questions listed here regarding construction of older pipeline, untested welds, no in-line inspections, lack of strength testing for over 30 years, as well as self-reported lapses in cathodic protection, what assurance does PG&E have that each pipeline in Lafayette is safe and free of latent hazards? (source: https://docs.wixstatic.com/ugd/de4240_e8e518be538e4df5be6f01e4cb58bc2d.pdf)

134. In 2010, PG&E transmission line 132 in San Bruno exploded as the result of a defective longitudinal seam weld. Twenty-two years before this (in 1988), line 132 experienced a leak attributable to a defective longitudinal seam weld at a point about 9 miles south of the 2010 rupture. The repair in 1988 involved replacing about 12 feet of line 132. Four years after the 1988 incident (in 1992), a defective longitudinal seam weld was detected in another part of line 132 when a tie-in girth weld was x-rayed. In light of the serious nature of the 1988 defect (which provided evidence of longitudinal seam welds in line 132), why wasn't an aggressive risk assessment and mitigation program immediately initiated for all of line 132, including the section located in San Bruno?

(Source: https://www.ntsb.gov/investigations/AccidentReports/Reports/PAR1101.pdf)

135. Regarding the above, can state-of-the-art In-Line Inspection (ILI) technology in 2018 detect the kind of defect that was present in San Bruno line 132 in 2010?

136. Regarding the above, has line 132 been retrofitted to enable use of In-Line Inspection (ILI)? How much of the line is ILI capable? When was this capability added for each segment of line 132? 

137. Are there any "pups" on Lafayette pipeline that have manufacture and/or installation dates from the 1950s? If so, which lines are these pups incorporated into? (NTSB says pups from 1956 did not meet industry quality control or welding standards then in effect; 5 out of 6 pups on SB Line 132 were sub-standard, either overlooked or ignored; one pup ruptured, causing the explosion).  What is PG&E’s level of confidence about its answer regarding use of pups in Lafayette’s lines?

(Source: https://www.ntsb.gov/news/events/Pages/Pacific_Gas_and_Electric_Company_Natural_Gas_Transmission_Pipeline_Rupture_and_Fire_San_Bruno_California.aspx)

138. PG&E's information about San Bruno Line 132 was both inaccurate and incomplete. Why should the city of Lafayette and Lafayette residents believe that PG&E's records about Lafayette gas transmission lines installed in the same era provide reliable, complete, and accurate  information?

 

Other

139. Federal law requires that gas pipeline operators adhere to the legally recorded easement agreements between PG&E and the property owner to determine what activities are explicitly allowed in the easement. What language in the easements where PG&E operates in Lafayette explicitly allow for tree removal?

140. Removal of trees are known to increase the risk of soil erosion and landslides. Lafayette is prone to this type of land movement during wet winter months. What studies can PG&E provide that will reassure us that removal of roots holding pipelines in place will not make conditions for erosion, landslides, and liquefaction worse?

141. During a 2017 walk with Lafayette residents, PG&E employee Joey Perez answered the question “Won’t land become more unstable with tree removal?” by saying that they assume after time, and by the time tree roots decompose in a few years, other trees will take root and help stabilize the slope. Please explain the thinking behind this answer.  Is PG&E counting on the continued encroachment of its right of way in order to maintain land structure integrity?

142. We asked pipeline expert Richard Kuprewicz, president of Accufacts, about the need for cutting down trees, and he is on the record stating in an email 9/3/17: "Something else is going on here and safety isn’t the major reason, because the bulk of the arguments are, shall we say, bogus. Nothing like trying to steal a pipeline ROW. In some states that would be very illegal..." Why do independent pipeline experts dispute PG&E's rationale for tree cutting?

143. On 6/19/13, Roland Trevino approved PG&E’s Utility Standard TD-4490S pertaining to “Pipeline Rights-of-way Management.”  Is this the current version of this standard, or has it been superseded? If it has been superseded, please provide a copy of the current standard pertaining to this topic. (Source: ftp://ftp2.cpuc.ca.gov/PG&E20150130ResponseToA1312012Ruling/2013/07/SB_GT&S_0263354.pdf)

144. Regarding the above, TD-4490S requires removal of trees larger than 8” diameter that are within 10 ft of the outer edge of a gas transmission pipeline, and removal of trees larger than 36” diameter that are within 14 ft. Tree removal timing is subject to decisions by Integrity Management personnel. In the city of Lafayette, PG&E initially identified more than 1,000 trees that were designated as “unacceptable risk” and designated for removal. Later, PG&E concluded that the Lafayette trees it regarded as unacceptable risk were those within 5 ft of the pipeline, and this reduced the total number designated for removal to 272. Have the roughly 750 trees that were removed from the unacceptable risk category merely been placed in a “delayed removal” status per Section 2.6 of the standard, or have these trees been exempted from removal per Section 6.1 of the standard?

145. Regarding the above, if some of the trees discussed above have been exempted from removal, please provide a copy of the documentation describing the rationale for the exemptions and the analysis supporting these decisions, as required by Section 6.2 of TD-4490S.

146. Given that the St. Mary’s Road pipeline replacement is being installed on a corridor that was described by PG&E as being only 22’ in width, and that one of the benefits of replacing this line is to replace pipelines with unknown welds and aging infrastructure, why hasn’t PG&E seriously considered replacement of similar aged pipelines in Lafayette located in areas of similar access width, such as on the Lafayette-Moraga Trail, downtown, and the Reservoir Rim Trail?

147. Why did PG&E divert $100 Million in gas safety and operations money and spend it on other purposes, including stockholder profit and executive bonuses, as disclosed by a CPUC audit? (Source: https://www.sfgate.com/bayarea/article/PG-E-diverted-safety-money-for-profit-bonuses-2500175.php)

148. Does PG&E acknowledge that, according to the Code of Federal Regulations, specifically Title 49 CFR 192 and the US Department of Transportation’s Pipeline and Hazardous Materials Administration, there is no legal requirement to remove trees along gas transmission pipelines, and that this is a discretionary program being implemented by PG&E? Does PG&E dispute the fact that this tree removal program benefits are for potential ongoing maintenance accessibility and ease of visual patrolling by aircraft? 

(Source: https://www.phmsa.dot.gov/regulations/title49/interp/PI-76-0108 https://www.phmsa.dot.gov/regulations/title49/interp/PI-00-0102 http://pstrust.org/wp-content/uploads/2014/12/Mulligan-Pipeline-Safety-Trust-ROW-Clearing.pdf)

149. What assurances does PG&E give us that pipeline maintenance operations are performed per pipeline safety law requirements?

150. Save Lafayette Trees is applying for a federal grant from the Department of Transportation, specifically, the Pipeline Safety Information Grants to Communities: Technical Assistance Grants (TAG), that provide funding for technical assistance to local communities and groups for technical assistance related to pipeline safety.  The TAG purpose states: “Pipeline Safety is a shared responsibility and informed communities play a vital role in the safety and reliability of pipeline operations.” Our application includes allowances for a 3rd party technical engineer / analysis of pipeline safety risks in Lafayette and objective to work collaboratively with community, municipality, utility, and agency stakeholders that have common interest in optimal pipeline safety in Lafayette and building relationships between stakeholders. The goals of the TAG project include creating a basis to rebuild trust in PG&E and pipeline maintenance operations in Lafayette. Whether or not we receive the grant, could PG&E commit to work with us on this shared goal? Is PG&E willing to designate a PG&E employee that can represent the organization in these efforts?

Questions for the City of Lafayette

 

1. According to the City Council Meeting on March 27, 2017, page 12: “Councilmember Mitchell said when the Council heard this proposal two years ago PG&E had mapped out the pipe and it looked like the pipe was going through the Plaza Park area. He asked Ms. Canales to address this area. Ms. Canales stated initially they had shown a few trees for removal in the Plaza Park area as well as indicated the City would have to re-design the trellis in the plaza. There have been a number of discussions with PG&E and staff’s understanding is that PG&E has agreed to move their line in that location and the park can be left as is.”  and also email dated February 9, 2017 from Megan Canalis to Steven Falk “Thanks, Steven! Appreciate the update on your meeting with Tom and so glad to hear they are willing to move the line near the Trellis (smiley face icon)” How did the City get comfortable negotiating for the retention of the plaza park trellis, recognized as a visible and cherished element by our community, knowing residents would be required to remove their trees, many of which are similarly cherished by their families, with this agreement? Why did the City not contact these residents notifying of this potential development prior to signing the Tree Cutting Agreement?

2. Regarding the above, at some point of time, the City of Lafayette must have heard from PG&E that the pipeline would not be rerouted, and would continue to run underneath the trellis structure. How did the City continue to defend the need for the Tree Cutting Agreement as a safety measure as warranted by PG&E (which states the need to provide immediate access to all points of the pipeline) knowing such a safety requirement would not be implemented in this public city space? There are other structures that PG&E is targeting for removal on the pipeline easement. Although these are on private property, like the majority of trees targeted for removal, did Mr. Falk speak with PG&E about saving other structures from removal?

 

3. When the City of Lafayette signed the Tree Cutting Agreement of March 27, 2017, the City received the monetary value of the in-lieu mitigation fees for residents’ trees without the residents’ knowledge, and set in motion the process where PG&E is seeking agreements with private property owners. Some residents have chosen to decline making agreements and we have direct knowledge that residents in other cities who made similar decisions have been threatened with legal action (by this billion dollar company).  This same scenario has a chance of playing out in Lafayette. On top of an undue burden of decision, to agree to tree removal or not, for “community safety”, the idea of legal action is unfair and possibly coercive. What did the City of Lafayette do to inform residents of the pending agreement? It seems Lafayette had at least one meeting in which other stakeholder representatives were present, i.e. EBMUD, EBRPD. Who represented residents?  If it was a person on city staff, how was meeting information distributed to residents for comment? At the March 27, 2017 meeting in which Council voted to sign the agreement, then Mayor Anderson commented people would be upset. For such an impactful decision, could Council have delayed motion to accept agreement to a later time? Does Council believe this is the proper code of conduct for a city, especially considering the insufficient public notice leading up to the City Council’s decision to enter into its agreement with PG&E? 

4. Did the City of Lafayette research the rights of each owner with respect to their PG&E gas easements, including City property, EBRDP property, EBMUD property, and private properties? What explicit rights do these easements give for tree cutting? 

5. It seems that the City opted to make the agreement with PG&E so they might avoid litigation from PG&E. PG&E first approached City of Lafayette a few years prior with a its tree clearance program, Pipeline Pathways, in which PG&E sought to clear a wider swath around the pipeline (for which they might not have had easement rights to do so anyway). At that time, Lafayette clearly reacted to the number of trees, approx. 1200, that PG&E proposed to remove as did other local cities, including Walnut Creek, that led initial efforts to bring suit against PG&E and subsequently worked on a framework with PG&E to assess trees individually for safety risk.  Did PG&E threaten or imply litigation if Lafayette did not sign the agreement? What precedent did the city of Lafayette use in terms of another city being sued by PG&E if tree removal wasn’t signed? 

6. We are glad that CPSI proposes a lesser number of trees for removal, but what did the City understand were the new parameters for tree removal per CPSI as opposed to Pipeline Pathways? It is our understanding that the cities like Walnut Creek and Danville who were party to the opposition efforts, had at most, a handful of trees removed by PG&E (unfortunately not including unaccounted for resident trees). Why did Lafayette choose not to engage in this local city effort to challenge the tree removal program? Did Lafayette city staff investigate the results of these efforts to adopt “best agreement practices”? The agreement that PG&E made with Lafayette seems very non-substantive in terms of mitigation of trees, aside from in-lieu mitigation fees provided for in municipal code adopted subsequent to the Pipeline Pathways proposal. What other safety risk mitigation options did city staff consider with PG&E? Did city staff confer with any other cities approached by PG&E? If not, why not?

7. Why has the money that the City has received from PG&E been put into an east-end-of-town median planting fund where 1) the replacement trees would be planted far from their removal sites, 2) ornamental trees would be planted instead of the natural habitat large oaks that will be removed, and 3) according to the City Manager, there isn’t enough tree planting currently contemplated for this project to spend down this amount? Why is this money not being used to restore or otherwise attempt to recompense the neighborhoods which will be impacted by large, iconic heritage tree removal? 

8. What is the City doing to address the discrepancies between the arborist report/tree list upon which the agreement was struck and the CPSI targeted tree removal list that PG&E provided? There is at least a 10% discrepancy in these lists which could mean more trees will be removed than intended and/or the wrong trees will be removed. 

9. The City seems to not have made any provision for in-lieu mitigation aside from receipt of associated fees. Why did the City fail to consider the loss and calculation for value of benefits of trees including air purification, shading, screening, wildlife impact, aesthetic value, community heritage value, etc?

10. Why is the City not requiring PG&E to post tree-removal signs on the trees proposed for removal, as has been done in other communities, in the interest of full transparency to the public? What benefit does the community receive by not being aware of the specific trees to be removed? 

11. Have ALL the Lafayette structures as identified by PG&E as being encroachments over the gas pipeline right of way been removed? Why or why not? 

12. What happened to the dead tree in Lafayette Plaza park? Was there a PG&E gas leak that killed the tree? Did the City remove the tree or PG&E?

13. Save Lafayette Trees is applying for a federal grant from the Department of Transportation, specifically, the Pipeline Safety Information Grants to Communities: Technical Assistance Grants (TAG), that provide funding for technical assistance to local communities and groups for technical assistance related to pipeline safety.  The TAG purpose states: “Pipeline Safety is a shared responsibility and informed communities play a vital role in the safety and reliability of pipeline operations.” Our application includes allowances for a 3rd party technical engineer / analysis of pipeline safety risks in Lafayette and objective to work collaboratively with community, municipality, utility, and agency stakeholders that have common interest in optimal pipeline safety in Lafayette. The goals of the TAG project include creating a basis to rebuild trust in PG&E and pipeline maintenance operations in Lafayette and build relationships between stakeholders. Whether or not we receive the grant, can the City commit to work with us on this shared goal? Is the City willing to designate a staff employee that can represent the organization in these efforts?

PG&E Responses

 
1. PG&E Gas Operations Responses

2. Appendix: