On Thursday, RCRC submitted comments on the third set of proposed guidelines of the California Public Utilities Commission (CPUC) for utilities to conduct proactive de-energization events, also known as Public Safety Power Shut-offs (PSPS). Notably, in a future action the CPUC will consolidate its multiple rules and guidelines into a single reference document, improving clarity for stakeholders and the public.
RCRC was particularly concerned with the CPUC’s new posture that responsibility for ensuring that utilities reduce the need for future PSPS event should shift to the new Office of Energy Infrastructure Safety at the California Natural Resources Agency. Also surprising was the CPUC’s public disclosure about its reticence to conduct reasonableness reviews of PSPS events out of a fear that it would inhibit utility flexibility. RCRC and other parties pushed back hard on both fronts, arguing that the CPUC is uniquely and ideally situated to ensure that Californians have reliable access to electricity and that it must review utility actions to ensure that utilities acted reasonably in both calling and conducting PSPS events.
While these Phase 3 rules generally improve the planning, notification, and execution of PSPS events, RCRC requested several specific changes, including:
- Re-iterating the overarching intent to reduce PSPS over time through utility system hardening and resiliency improvements;
- Minimizing PSPS-mitigation burdens on local governments, paratransit agencies, and community based organizations;
- Clarifying that paratransit agencies will be reimbursed for services rendered at the request of a utility; and
- Including additional customer impact metrics in PSPS reports, such as the maximum length customers were left without power.
The CPUC is expected to take action on this Proposed Decision as soon as June 24th. Click here to submit public comments. For additional information, contact John Kennedy by email or call 916-447-4806.