Report 2021-117 Recommendation 7 Responses

Report 2021-117: Electrical System Safety: California's Oversight of the Efforts by Investor‑Owned Utilities to Mitigate the Risk of Wildfires Needs Improvement (Release Date: March 2022)

Recommendation #7 To: Energy Infrastructure Safety, Office of

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.

1-Year Agency Response

Through its annual update of the Wildfire Mitigation Plan (WMP) Guidelines, Energy Safety implemented this recommendation in its "Lessons Learned" section of the 2023 WMP Guidelines. The WMP Guidelines, issued on December 7, 2022, require that electrical corporations detail lessons learned from any and each catastrophic wildfire ignited by its facilities or equipment in the past 20 years. Electric corporations must also detail specific mitigation measures implemented as a result of these lessons learned and demonstrate how the mitigation measures are being integrated into the electric corporation's wildfire mitigation strategy.

For each lesson learned, the electrical corporation must identify the following:

- Year the lesson learned was identified

- Subject of the lesson learned

- Specific type or source of lesson learned

- Brief description of the lesson learned that informed improvement to the WMP

- Brief description of the proposed improvement to the WMP and which initiative(s) or

activity(s) the utility intends to add or modify

- Estimated timeline for implementing the proposed improvement

- Reference to the documentation that describes and substantiates the need for improvement.

If any lessons learned were derived from quantifiable data, visual/graphical representations must be provided as supporting documentation.

California State Auditor's Assessment of 1-Year Status: Fully Implemented

The Energy Safety Office's 2023 Mitigation Plan Guidelines (guidelines) require that utilities detail lessons learned due to ongoing monitoring and evaluation initiatives, collaboration with other electrical corporations and industry experts, and consider feedback from Energy Safety and other regulators. The electric corporation must also detail specific mitigation measures implemented as a result of these lessons learned and demonstrate how the mitigation measures are being integrated into the electric corporation's wildfire mitigation strategy. Thus, we consider this recommendation to be fully implemented.

6-Month Agency Response

Through its annual update of the Wildfire Mitigation Plan (WMP) Guidelines, Energy Safety is implementing this recommendation in revisions to its "Lessons Learned" section of the 2023 WMP Guidelines. The 2023 draft WMP Guidelines, released on September 19, 2022, require that electrical corporations report on lessons learned from Energy Safety or other regulators, including findings from post-wildfire investigations conducted by Energy Safety, CAL FIRE, and any other relevant state/local wildfire safety agency.

For each lesson learned, the electrical corporation must identify the following:

- Year the lesson learned was identified

- Subject of the lesson learned

- Specific type or source of lesson learned

- Brief description of the lesson learned that informed improvement to the WMP

- Brief description of the proposed improvement to the WMP and which initiative(s) or activity(s) the utility intends to add or modify

- Estimated timeline for implementing the proposed improvement

- Reference to the documentation that describes and substantiates the need for improvement, as well as the corrective action plan

If any lessons learned were derived from quantifiable data, visual/graphical representations must be provided as supporting documentation.

Because these guidelines have only been released in draft form and are not yet final, Energy Safety designates this response as "Not Fully Implemented." Energy Safety intends to adopt the final 2023 WMP Guidelines on or around December 1, 2022

California State Auditor's Assessment of 6-Month Status: Pending

We look forward to determining whether these new guidelines address our recommendation when Energy Safety provides them.

60-Day Agency Response

The department will evaluate the need for any changes to the Wildfire Mitigation Plan Guidelines, including changes to the Lessons Learned section, through its established annual process. The 2023 Guidelines are currently under development, and Energy Safety anticipates they will be issued later this year.

California State Auditor's Assessment of 60-Day Status: Pending

We look forward to reviewing the 2023 mitigation plan guidelines and evaluating whether the Energy Safety Office has added requirements for utilities to address issues identified by oversight mechanisms—such as external audits—in their mitigation plans.

All Recommendations in 2021-117

Agency responses received are posted verbatim.