Support for natural gas proceedings, public advocacy, and prudent pipeline replacement, including utility filings, safety record review, and testimony before Public Service and Utilities Commissions.
Discuss a ProceedingUtilities are asking commissions to approve record levels of pipeline replacement and safety spending. Much of that work is necessary. Ratepayers are entitled to evidence that each dollar buys a measurable reduction in risk, and that the programs they fund address the right pipe first.
Safety and affordability are not competing goals. Both depend on spending that follows the risk.
Federal rules require every distribution operator to identify threats, rank risk, and measure performance under its Distribution Integrity Management Program. A replacement plan should trace to that ranking. If it does not, the commission should ask why.
49 CFR 192.1007Leak backlogs, repair times, and excavation damage rates drive both safety and cost decisions. When a metric is tied to performance targets or incentives, it can drift away from conditions in the field. Reported figures should be tested against work orders and leak records before they support a rate request.
State inspection findings, notices of probable violation, and incident reports show whether a utility's programs are working. Repeat findings on the same issue indicate a gap that additional capital alone may not close.
49 CFR Part 191Prudence review should compare alternatives, including repair, targeted replacement, and enhanced surveillance, rather than accept the most capital-intensive option by default.
Clearpath supports consumer advocates and commission staff in natural gas proceedings, from the first review of a utility's filing through testimony.
Our analysis distinguishes what regulations require, what industry practice supports, and what is a matter of judgment, so decision-makers can weigh each on its merits.
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