Pacific Gas & Electric and Southern California Edison are opposing a slew of wildfire safety metrics proposed by the California Public Utilities Commission's Office of the Safety Advocate and other stakeholders.
California's utilities and independent transmission owners in February filed wildfire mitigation plans with the CPUC, which the commission approved on May 30 (see CEM No. 1554). The next phase of the WMP development process—Phase 2—requires utilities and other energy entities to develop metrics to evaluate a mitigation plan's effectiveness.
A broad and expansive set of metrics is necessary to understand the impact of mitigation measures that utilities are planning to undertake in their respective WMPs, the OSA said in a Nov. 6 filing. An insufficient set of metrics could negatively impact safety, according to the OSA, which added that the commission has documented a number of instances in which past performance-based ratemaking has resulted in unintended consequences.
The OSA recommended tracking and evaluating the age of overhead conductors on a utility's system, but PG&E in a Nov. 19 response said it does "not believe this metric is insightful" because "age distribution by itself is not an indicator of fire risk."
The OSA also said the total miles of circuit that conforms to current design standards as a percentage of total miles for distribution and transmission would be valuable in assessing a WMP, but PG&E said it "does not feel that this metric provides value" because the utility's design standards "are constantly evolving."
PG&E is not opposed to having additional metrics aligned with wildfire risk mitigation work as long as they actually measure factors that show a reduction in wildfire risk, according to the utility's filing.
SCE also opposes requirements to provide certain data as part of its WMP. The investor-owned utility said the OSA requested the "backlog of repair items associated with overhead conductor integrity." However, SCE said in its comments that "it is not apparent how adopting this as a 'metric' will yield any conclusive findings related to the effectiveness of wildfire mitigations."
"The presence of a backlog related to overhead conductor integrity does not indicate a lack of effectiveness of a specific mitigation," SCE said.
In its April proposed decision, the CPUC said the utilities expressed a concern that metrics would be based on how much work the utility would perform (i.e., how many trees it would cut, how many miles of conductor it would install), rather than on the results of this work (reduction in wildfires or other events that cause wildfires).
According to the CPUC, stakeholders such as The Utility Reform Network are also concerned that the utilities' proposed performance metrics do not measure actual outcomes. Metrics should, among other things, measure "number of deaths or injuries resulting from utility-caused wildfires" or "number of catastrophic wildfires or acres burned resulting from utility-caused wildfires," the stakeholders said.
While the proposed wildfire mitigation plan metrics are being reviewed, California regulators are also trying to find qualified entities to evaluate whether utilities are complying with their plans (see CEM No. 1557).