Report 2021-117 Recommendation 6 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 #6 To: Energy Infrastructure Safety, Office of

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.

1-Year Agency Response

Energy Safety's current process already ensures that utilities focus mitigation activities in the areas of highest fire risk. The recommendation is an oversimplification of the evaluation process and is too rigid to permit Energy Safety's experts to exercise discretion based on their technical knowledge and trigger a Revision Notice where appropriate. Energy Safety does not intend to prejudge the severity of any issue before document submission and completion of Energy Safety's extensive evaluation process. Implementation of this recommendation would limit Energy Safety's ability to utilize its technical expertise in its evaluation of wildfire mitigation plans.

California State Auditor's Assessment of 1-Year Status: Will Not Implement

The Energy Safety Office's current process does not, in fact, ensure that utilities focus mitigation activities in the areas of highest fire risk. Its own assessments of utilities' mitigation plans that it approved contradict this statement. The Energy Safety Office itself found that PG&E did not describe in sufficient detail in its 2020 mitigation plan how it prioritized deployment of vegetation management initiatives, and the utility failed to demonstrate in its 2021 mitigation plan that it was properly prioritizing power line replacement and system hardening efforts. Similarly, the Energy Safety Office noted that SDG&E did not provide sufficient detail in its 2021 mitigation plan on how it prioritized high fire-threat areas for moving power lines underground and installing covered power lines.

Moreover, the Energy Safety Office's internal procedures already classify some items as critical issues that must be addressed before it approves a mitigation plan and others as deficiencies that may be addressed in a subsequent mitigation plan. We only recommend that the Energy Safety Office classify the prioritization of mitigation activities as a critical issue, as it has done with other issues. Thus, we stand by our recommendation.

6-Month Agency Response

Energy Safety's current process already ensures that utilities focus mitigation activities in the areas of highest fire risk. The recommendation is an oversimplification of the evaluation process and is too rigid to permit Energy Safety's experts to exercise discretion based on their technical knowledge and trigger a Revision Notice where appropriate. Energy Safety does not intend to prejudge the severity of any issue before document submission and completion of Energy Safety's extensive evaluation process. Implementation of this recommendation would limit Energy Safety's ability to utilize its technical expertise in its evaluation of wildfire mitigation plans.

California State Auditor's Assessment of 6-Month Status: Will Not Implement

The Energy Safety Office's current process does not, in fact, ensure that utilities focus mitigation activities in the areas of highest fire risk. Its own assessments of utilities' mitigation plans that it approved contradict this statement. The Energy Safety Office itself found that PG&E did not describe in sufficient detail in its 2020 mitigation plan how it prioritized deployment of vegetation management initiatives, and the utility failed to demonstrate in its 2021 mitigation plan that it was properly prioritizing power line replacement and system hardening efforts. Similarly, the Energy Safety Office noted that SDG&E did not provide sufficient detail in its 2021 mitigation plan on how it prioritized high fire-threat areas for moving power lines underground and installing covered power lines.

Moreover, the Energy Safety Office's internal procedures already classify some items as critical issues that must be addressed before it approves a mitigation plan and others as deficiencies that may be addressed in a subsequent mitigation plan. We only recommend that the Energy Safety Office classify the prioritization of mitigation activities as a critical issue, as it has done with other issues. Thus, we stand by our recommendation.

60-Day Agency Response

Energy Safety's current process already ensures that utilities focus mitigation activities in the areas of highest fire risk. The recommendation is an oversimplification of the evaluation process and is too rigid to permit Energy Safety's experts to exercise discretion based on their technical knowledge and trigger a Revision Notice where appropriate. Energy Safety does not intend to prejudge the severity of any issue before document submission and completion of Energy Safety's extensive evaluation process. Implementation of this recommendation would limit Energy Safety's ability to utilize its technical expertise in its evaluation of wildfire mitigation plans.

California State Auditor's Assessment of 60-Day Status: Will Not Implement

The assessments of utilities' past mitigation plans that we reviewed during the course of our audit contradict the Energy Safety Office's statement that its current process already ensures that utilities focus mitigation activities in the areas of highest fire risk. The Energy Safety Office itself found that PG&E did not describe in sufficient detail in its 2020 mitigation plan how it prioritized deployment of vegetation management initiatives, and the utility failed to demonstrate in its 2021 mitigation plan that it was properly prioritizing power line replacement and system hardening efforts. Similarly, the Energy Safety Office noted that SDG&E did not provide sufficient detail in its 2021 mitigation plan on how it prioritized high fire-threat areas for moving power lines underground and installing covered power lines.

Moreover, as we have previously stated, although we appreciate the need for the Energy Safety Office to exercise discretion, we also recognize the critical importance of ensuring that mitigation activities are properly prioritized, particularly given the issues Energy Safety highlighted in its evaluation of utilities' 2020 and 2021 mitigation plans and the number of miles of bare power lines in high fire threat areas, as we describe in our report. The Energy Safety Office's internal procedures already classify some items as critical issues that must be addressed before it approves a mitigation plan and others as deficiencies that may be addressed in a subsequent mitigation plan. Thus, we stand by our recommendation that the Energy Safety Office elevate the prioritization of mitigation activities to be a critical issue that must be addressed before a mitigation plan can be approved, as it has done with other issues.

All Recommendations in 2021-117

Agency responses received are posted verbatim.