Report 2021-117 Recommendations

To ensure that utilities are targeting the areas of highest fire risk for mitigation activities, the Energy Safety Office should revise its internal procedures for reviewing mitigation plans by March 2023 to designate the prioritization of mitigation activities as a critical issue that must be appropriately addressed before a mitigation plan can be approved.

To make mitigation plans more responsive to the causes of fires and serious concerns raised through oversight mechanisms, the Energy Safety Office should require in its 2023 mitigation plan guidelines that utilities address issues identified by oversight mechanisms—such as external audits—in their mitigation plans.

To prevent power shutoffs rather than only reducing their scope and impact, the Legislature should amend the shutoff reduction law to require that utilities describe in their mitigation plans the improvements that would be necessary to prevent power shutoffs on the circuits routinely affected by them—such as installing covered power lines—and the costs of those improvements.

To address the risks and hazards resulting from future unplanned outages, the Legislature should amend the shutoff reduction law to include circuits frequently de-energized as the result of utilities' power-line setting measures. In doing so, the Legislature will create a requirement that utilities identify in their mitigation plans the circuits frequently de-energized as a result of their power-line setting measures and the improvements they have made or plan to make to those circuits.

To ensure that safety certifications encourage utilities to invest in safety and limit wildfire risks, the Legislature should require that as a prerequisite of issuing a safety certification, the Energy Safety Office's most recently completed compliance assessment of a utility's mitigation plan must conclude that the utility has substantially implemented that plan.

To better hold utilities accountable for safely operating the electrical grid, the Legislature should require the CPUC to create and implement a risk-based audit plan for transmission and distribution infrastructure audits that prioritizes districts based on risk factors, including high fire-threat areas, and aligns with the requirement established in its audit manual to audit each district at least once every five years.

To better hold utilities accountable for safely operating the electrical grid, the Legislature should require the CPUC to create a schedule of penalties for violations identified through its audit process and apply the schedule pursuant to its existing authority to impose penalties established in state law.

To ensure that it does not authorize cost recovery, and the resulting rate increases, for activities that were part of a utility's previous general rate case, the CPUC should perform audits of the utilities' wildfire mitigation costs before approving recovery of those costs. In addition, the CPUC should implement sufficient safeguards to ensure the appropriateness of the costs passed on to customers

To ensure that utilities do not over-recover, or charge ratepayers more than they should for the activities they perform, the CPUC should make certain that if utilities request reimbursement for the costs questioned in the contractor audits, the utilities provide sufficient quantifiable and detailed analyses to substantiate that the costs were not paid for through the utilities' previously approved rates.