This week, RCRC submitted comments to the Office of Energy Infrastructure Safety on the 2022 Wildfire Mitigation Plan updates of large investor-owned utilities, including Pacific Gas & Electric (PG&E) and Southern California Edison. All electrical utilities are required to construct, maintain, and operate their lines and equipment to minimize the risk of a utility-caused wildfire and undertake comprehensive mitigation measures through a Wildfire Mitigation Plan.

In particular, PG&E promised more details on their 10,000-mile undergrounding initiative, but it is still in its preliminary stages and meaningful details remain to be seen. Given the new emphasis on undergrounding and lack of corresponding implementation details, RCRC is concerned that high fire threat communities in PG&E’s service territory will continue to experience wide ranging power outages as a primary utility risk avoidance measure and result of slow system hardening upgrades on its highest risk circuits. Southern California Edison is expanding their grid hardening strategies, which previously relied on the installation of covered conductor (insulated wires) to reduce ignitions.

RCRC provided several recommendations for the Office of Energy Infrastructure Safety to consider, such as providing an acceptable scope of undergrounding work along with performance criteria to ensure PG&E can keep up with the unprecedented pace and scale of promised grid hardening measures; requiring utilities to develop plans to co-trench multiple utilities (such as broadband) when undertaking undergrounding work; and developing consistent best practices for circuit settings programmed to cause a power outage (like PG&E’s Enhanced Powerline Safety Settings—or EPSS—program) including disclosing those outages in detail similar to the disclosure of proactive de-energization events, known as Public Safety Power Shut-offs (PSPS).

RCRC’s comments can be viewed in full here. Energy Safety will publish draft decisions on large utility Wildfire Mitigation Plans beginning in mid-May 2022. For more information, contact RCRC Policy Advocate Leigh Kammerich