This week, the California Public Utilities Commission (CPUC) issued a long-awaited report on 2019 public safety power shutoffs (PSPS) events and outlined a number of recommendations. While the CPUC’s Safety and Enforcement Division’s (SED) report “provides an initial assessment” of utility notifications, communications, and mitigation actions, it does NOT evaluate the reasonableness of the utilities’ decisions to shut off power or their conduct during the PSPS events. The SED noted that such an evaluation would require a far more extensive inquiry than is currently available.

The SED noted that all investor-owned utilities (IOUs) ineffectively coordinated with public safety partners, inadequately considered access and functional needs (AFN) communities, and failed to comprehensively consider public safety risks caused by PSPS events.

The report makes the following recommendations for future CPUC PSPS guidelines:

  • Clarify identification of public safety partners.
  • Clarify when notices are required, rather than recommended, to be provided to public safety partners, critical facilities, and the general public.
  • Require priority notification to transmission-level customers.
  • Require utilities Emergency Operations Center staff to have emergency management experience or training.
  • Require utilities to coordinate with local and tribal governments to proactively identify and share lists of medical baseline customers.
  • Require utilities to develop partnerships with local organizations to improve outreach and assistance for AFN communities.
  • Require coordination with locals to comprehensively identify critical facilities and infrastructure.
  • Require coordination with local governments and community-based organizations to deploy community resource centers and mobile assistance vehicles.
  • Require utilities to report on projects that improve situational awareness, including weather stations and high-resolution cameras.
  • Allow public safety partners to opt out of some utility notifications.
  • Increase and improve the information contained in utility post-PSPS event reports and improve their consistency across all utilities.

The SED report recognizes that utilities have room to improve efforts to minimize public impacts through CRCs, but somewhat troublingly, also urges the CPUC to recognize that resources to mitigate PSPS impacts were also provided by local governments. This comment fails to recognize that locals were often left with no alternative to dedicate resources to mitigate PSPS impacts because they were left with few other choices in the absence of utility mitigation efforts.

The report relies heavily on utility reports and comments made in CPUC proceedings by RCRC, CSAC, and the Joint Local Governments (Kern, Marin, Mendocino, Napa, Nevada, San Luis Obispo, Santa Barbara, and Sonoma Counties and the City of Santa Rosa). RCRC has been supportive of efforts to require the CPUC to evaluate last year’s PSPS events and determine the reasonableness of the utilities’ actions in initiating and implementing those events.