PG&E Corporate Responsibility and Sustainability Report 2021

COVID-19 Response

Compliance

Our commitment to environmental leadership is reflected in our environmental policy, which requires strict adherence to all applicable environmental laws and regulations.

Our Approach

Environmental Management System

A female PG&E employee in a hardhat PG&E’s operations are subject to extensive federal, state and local environmental laws and regulations. These requirements relate to a broad range of activities, including preventing the discharge of pollutants; safely transporting, handling and storing hazardous materials; properly managing hazardous wastes; protecting threatened and endangered species; and reporting and reducing emissions of air pollutants and greenhouse gases such as carbon dioxide, methane and sulfur hexafluoride.

To meet these requirements, PG&E employs an Environmental Management System (EMS) modeled after the ISO 14001 environmental management standard and consistent with the ISO standard’s “Plan, Do, Check, Act” model for continuous improvement. In addition, we align our EMS and environmental operations to PG&E’s Compliance and Ethics Maturity Model. This allows us to integrate our compliance activities with the rest of PG&E, and to use common compliance performance measurements.

The Vice President, Shared Services of Pacific Gas and Electric Company oversees our commitment to meeting environmental requirements. Compliance performance updates are reviewed monthly by the Vice President of Shared Services, and an annual environmental compliance summary is presented to the Sustainability and Governance Committee of the PG&E Corporation Board of Directors.

Reviews and Corrective Actions

Auditing is critical to ensure compliance with the many environmental laws and regulations relating to our business.

We review and audit environmental performance in three ways: self-assessments, internal audits and compliance testing and risk reviews:

  • Self-Assessments: Environmental personnel perform self-assessments of facilities or projects they oversee. Each assessment evaluates a facility or project for compliance with environmental regulations.
  • Internal Audits: The Internal Auditing department—which reports directly to the PG&E Corporation and Pacific Gas and Electric Company Vice President and Chief Audit Officer—conducts systemic and programmatic controls-based audits to independently analyze the effectiveness of our environmental compliance management systems.
  • Compliance Testing and Risk Reviews: These reviews, designed to assess the adequacy of controls and risk mitigation, as well as compliance work processes, are conducted by the Risk and Compliance function.

We also participated in a third-party audit of our compliance programs as a part of a PG&E-wide initiative to strengthen compliance. We incorporated the findings into our EMS and operational processes to further strengthen our compliance management.

2020 Milestones

Planning

In 2020, PG&E continued to leverage our EMS to manage and improve environmental compliance and performance. Using defined criteria, we reviewed and scored the impacts of more than 180 aspects of our operations. We are using this analysis to identify top environmental risks across our operations and help prioritize areas of compliance.

Implementation and Operation

PG&E employs a variety of operational controls to help ensure that the actions we take in meeting our environmental compliance obligations are correct and repeatable. We also learn from our experiences and integrate any lessons into our work processes and staff development.

In 2020, we continued to expand on opportunities to apply technologies and processes to further our compliance efforts and minimize impacts on the environment. Key EMS initiatives included:

  • Centralizing all land and environmental compliance processes into a single cloud-based platform to gain a more holistic view of our environmental release to construction process and associated information.
  • Incorporating our new programmatic permits into a cloud-based platform, allowing complete and accurate annual compliance reports to agencies.
  • Making other system integration and technology enhancements to share environmental data more effectively across PG&E to support decision making.

We also obtained a multi-region Habitat Conservation Plan (HCP), a programmatic permit with the U.S. Fish and Wildlife Service that will lead to improved compliance and operational efficiencies.

Measuring Progress

Operational Performance

PG&E tracks and reports a wide range of annual environmental compliance performance indicators. This section covers our performance results for 2020.

Reported Unintentional Releases and Permit Exceedances

We report unintentional releases that exceed regulatory thresholds, as well as many smaller releases, in an effort to provide operational transparency to local agencies. We reported a total of 124 releases, defined as an unintentional discharge of a regulated substance that required notification to the State of California or exceeded thresholds allowed in applicable permits.

Unintentional releases mostly result from equipment failure due to severe weather, utility pole vehicle strikes or vandalism and unintentional spills of small volumes of mineral oil from overhead transformers. Spilled material is cleaned up by PG&E first responders or environmental clean-up crews.

Agency Inspections

In 2020, a total of 376 agency inspections were conducted at our facilities. The majority of these inspections were performed by Certified Unified Program Agencies, such as city and county environmental health departments and fire departments.

Environmental Sanctions and Penalties

To measure compliance results, we categorize all written enforcement actions issued by a regulatory agency as minor, significant or critical. In doing so, we consider the level of impact to the environment, potential or actual monetary damages including restoration costs, and the number of repeat incidences. All enforcement actions are reviewed by the environmental leadership team on a monthly basis. We also track the percentage of agency inspections that do not result in written enforcement actions.

We received four enforcement actions in 2020 that were considered critical. Our rate of inspections without a written enforcement action was 96%, 5 points above our 2019 results.

In 2020, PG&E paid a total of $34,793 in environmental penalties.

Compliance Data
2018 2019 2020
Critical Enforcement Actions Footnote 1 9 4
Percentage of Inspections Without a Written Enforcement Action 93% 91% 96%
Releases/Exceedances 166 37 124
Penalties Paid $93,000 $47,033 $34,793
Agency Inspections 552 570 376
Audits Performed Footnote 2 8 11 39
Self-Assessments Performed 3,101 4,294 3,846
  • 1. In 2019, PG&E began categorizing all written enforcement actions issued by a regulatory agency as minor, significant or critical. In doing so, we consider the level of impact to the environment, potential or actual monetary damages including restoration costs, and the number of repeat incidences. This categorization better aligns with industry benchmarks.1
  • 2. Includes system audits, internal audits, and compliance and risk management reviews performed by PG&E.2