The California Public Utilities Commission (CPUC), in ongoing actions to help utilities prepare for and minimize the impacts of Public Safety Power Shut-offs (PSPS), today issued for public comment a series of proposed additional guidelines that utilities would be required to follow prior to the 2020 wildfire season, if approved by the CPUC. The CPUC also issued today a Ruling by President Marybel Batjer identifying serious deficiencies in Pacific Gas and Electric Company’s (PG&E) weekly post-PSPS corrective action reports to the CPUC and requiring additional actions to improve PG&E’s preparation efforts for the 2020 wildfire season and beyond.
PSPS Proposed Guidelines
As part of its re-examination of how utilities use and institute PSPS events, the CPUC today issued through an Administrative Law Judge Ruling proposed guidelines from its staff that the state’s investor-owned utilities would be required to follow, if approved by the CPUC, in order to ensure improved communication with their customers before and during PSPS events and to minimize the impact to customers when PSPS events are implemented by utilities. The proposed PSPS guidelines, which would augment the guidelines already established by the CPUC in Decision 19-05-042, are available at: http://docs.cpuc.ca.gov/PublishedDocs/Efile/G000/M325/K985/325985221.PDF. Members of the public who would like to comment can email email@example.com, referencing proceeding number R.18-12-005. An Administrative Law Judge Proposed Decision for Commissioner consideration is expected in May 2020.
The proposed guidelines for the state’s investor-owned utilities include:
- Restore Service No Longer than 24 Hours After Event: Ensure that power to impacted PSPS areas is restored as soon as possible and no longer than 24 hours following the conclusion of conditions that necessitate a PSPS event.
- Engage in More Robust Regional Collaboration: Convene, at least monthly, regionalized working groups with tribal and local government entities and public safety partners and coordinate advisory boards that consist of public safety partners, local and tribal government officials, business groups, non-profits, and academic organizations to advise on best practices for wildfire issues and safety, community preparedness, regional coordination, and the use of emerging technologies.
- Conduct Exercises with Public Safety Agencies: Collaborate with the CPUC, the California Department of Forestry and Fire Protection (CAL FIRE), the California Governor’s Office of Emergency Services (Cal OES), and local emergency response officials to plan annual PSPS exercises throughout the utility service territories in the areas with the highest historical and forecasted risk for de-energization in advance of fire season.
- Ensure Communication Resiliency: Utilize all reasonable channels of communication to all populations potentially affected by a PSPS event and develop communication and notification plans with local authorities that anticipates the disruption of traditional communication channels.
- Meet Specific Needs of Vulnerable Populations: Design, test, and execute on a plan based on local demographic and survey data for meeting a variety of safety needs for vulnerable populations through the provision of community resource centers (CRCs) and in collaboration with public safety partners, local governments, and access and functional needs customer advocates, conduct a needs assessment.
- Strengthen Online Information Accessibility: Ensure there is available bandwidth capacity, either via a cloud service or on-premise, to manage a website that provides the public with access to information about the geographic areas impacted by potential PSPS events and all other critical information to maintain public safety prior to, during, and after a PSPS event.
- Publicly Articulate PSPS Decision-Making Process: Provide on utility websites a thorough and detailed indication of the quantitative and qualitative factors the utility considered in calling, sustaining, or curtailing each PSPS event (including information regarding why the PSPS event was a last resort option) and a specification of what factors must be present for the PSPS event to be concluded.
- Notify Communications Carriers Proactively: Provide communications carriers with the meter and circuit IDs to be de-energized and re-energized to ensure communication carriers receive actionable notification information that can inform proactive deployment of resources to minimize the impact of the PSPS events on communications infrastructure.
- Address Transportation Impacts: Implement a transportation resiliency taskforce with local, tribal, Federal, and State government agencies, and other private and public sector parties to develop a needs assessment and resilience plan in advance of fire season that would identify and describe transportation infrastructure and corridors throughout California in need of back up generation.
President Batjer’s Ruling on PG&E Post-PSPS Corrective Action Reports
On Oct. 14, 2019, President Batjer issued a letter to PG&E directing it to file updates on its progress toward a series of corrective actions intended to improve PG&E’s planning and execution of PSPS events following the PSPS events in October. The Ruling issued today finds that PG&E filed substandard reports, and subsequently stopped filing reports. The Ruling orders PG&E to reinitiate corrective action reporting on a biweekly basis, and imposes additional reporting requirements, such as expanding the level of detail in the reports and assigning a process owner at the director level.
“PG&E’s performance during PSPS events in 2019 was unacceptable and cannot be repeated in 2020,” said President Batjer. “The reports that I ordered PG&E to submit are part of the CPUC’s comprehensive review of the 2019 PSPS events. PG&E must invest the necessary resources to mitigate the need for, and impact of, future PSPS events, and it must demonstrate that both its internal and external communications regarding PSPS events has received the appropriate attention required.”
President Batjer’s Ruling also requires PG&E to take additional wildfire preparation actions, including:
- Provide the CPUC within 15 days a detailed plan that describes PG&E’s current capabilities, planned improvements, and anticipated challenges/concerns with regards to anticipated PSPS events.
- Update its PSPS operating protocols within 45 days and, at the discretion of the CPUC, be prepared to exercise them in collaboration with Cal OES, CAL FIRE, and CPUC staff. PG&E must also be prepared to hold a no-notice exercise to go through the process of executing on all necessary elements for an actual de-energization event.
- Establish within 30 days working groups with tribal and local governments across PG&E’s service territory in which the needs of tribal and local governments during, before, and after a PSPS event are identified and addressed. PG&E must also develop its 2020 PSPS protocols using feedback from the working groups.
- President Batjer’s Ruling on PG&E’s correction action reports is available at http://docs.cpuc.ca.gov/PublishedDocs/Efile/G000/M326/K172/326172052.PDF.
The CPUC has taken a number of steps to hold utilities accountable for PSPS events and minimize the impacts of future PSPS events, including:
- Make Immediate Corrective Actions: Ordered PG&E to take a multitude of immediate corrective actions after it encountered significant problems with communication, coordination, and management during the largest PSPS event in the history of California in October 2019;
- Question Top Utility Executives: Called an emergency meeting in October 2019 to publicly address the mistakes and operational gaps identified in PG&E’s October PSPS events and to provide lessons learned to ensure they are not repeated;
- Question Top Communications Executives: Held a hearing on the operations of communications companies during the October PSPS events;
- Investigate: Launched a formal investigation to determine whether investor-owned utilities prioritized safety and complied with the CPUC’s regulations and requirements with respect to their PSPS events in late 2019 (I.19-11-013).
- Re-Examine Protocols: Began an examination of PSPS protocol (R.18-12-005);
- Do Not Charge for Services Not Provided: Implementing measures to ensure utilities do not collect from their customers the charges that are a part of every customer’s bill so that customers are not charged for services they do not receive during PSPS events;
- Expand Wildfire Mitigation Plans to Reduce Need for PSPS: Directed utilities to expand their 2020 Wildfire Mitigation Plans to focus on increasing the safe performance of utilities, reduce the need for PSPS events, create more resilient communities, and provide results before the next wildfire season; and,
- Emergency Disaster Relief: Establishing an emergency disaster relief program for entities under CPUC jurisdiction (R.18-03-011).
The CPUC regulates services and utilities, safeguards the environment, and assures Californians’ access to safe and reliable utility infrastructure and services. For more information on the CPUC, please visit www.cpuc.ca.gov.