All electrical utilities are required to construct, maintain, and operate their lines and equipment to minimize the risk of a utility-caused wildfire as well as undertake comprehensive mitigation measures through a Wildfire Mitigation Plan. This year, utilities filed comprehensive plans that cover a three-year period describing how the respective utility is: calculating risk; prioritizing infrastructure upgrades; and choosing mitigation strategies. While the Office of Energy Infrastructure Safety (Energy Safety) monitors wildfire mitigation expenditure data, the California Public Utilities Commission (CPUC) ultimately determines ratepayer costs during a utility’s General Rate Case.
Recently, RCRC provided feedback to Energy Safety as they consider approval of these Plans. RCRC recounted the experience with PG&E’s “Enhanced Powerline Safety Settings” (EPSS) program that has left many rural customers to suffer frequent power outages without notice, as well as the impacts of PG&E’s calamitous vegetation management activities in numerous counties. Additionally, RCRC seeks a greater reconciliation of the benefits of system hardening upgrades across utility service territories. Currently, insulated covered conductor replacing bare wires doesn’t provide consistent benefits, such as reducing Public Safety Power Shut-offs activations. Other public stakeholders also raised concerns with utility fast-trip settings that can result in unplanned power outages, echoing many of the suggestions made by RCRC and its joint petitioners at the CPUC nearly one year ago to balance greater accountability and protecting the public.
Additionally, it appears PG&E is withholding specific details on their 10,000-mile undergrounding initiative from the Wildfire Mitigation Plan and will instead provide a ten-year undergrounding plan for expedited review and approval to Energy Safety and the CPUC. Effectively, high fire threat communities in PG&E’s service territory will likely continue to experience wide ranging power outages as a primary utility risk avoidance measure on its highest risk circuits where more cost-effective covered conductor could be more quickly deployed. RCRC continues its advocacy before regulators to establish clear expectations for utilities to make system improvements to reduce the frequency and duration of power outages resulting from wildfire mitigation programs. Energy Safety is expected to produce a draft decision for each large investor-owned utility as early as the end of August 2023, with a parallel process for Small and Multi-Jurisdictional Utilities (e.g. Liberty, PacifiCorp).
RCRC’s comments can be viewed in full here (Opening Commets) and here (Reply Comments). For questions, please contact RCRC Policy Advocate Leigh Kammerich.