December 19, 2019

CSAC has been actively tracking and advocating on the development of Investor Owned Utility (IOU) Public Safety Power Shutdown (PSPS) policy for the past year through multiple regulatory processes, and through advocacy in the Legislature and the state budget process.

In December 2018 the CPUC opened a de-energization rulemaking (Rulemaking R. 18-12-005). This rulemaking has two phases, the first phase examined utilities’ PSPS processes and practices, the impacts of PSPS on communities and functional needs populations, efforts to reduce the need for PSPS, and how to mitigate PSPS implementation. In May 2019, the CPUC made its decision on the first phase of this rulemaking which aimed to make improvements to utility notification and communication procedures. CSAC engaged in this rulemaking with significant input from counties and submitted several letters advocating for improvements to help counties across California. You can find letters CSAC submitted to the CPUC here. 

The CPUC opened its second phase of the 18-12-005 rulemaking in August of 2019. The second phase of the rulemaking will focus on indemnification and communications with access and functional needs populations, communication with customers while the power is off, communication during reenergization, mitigation measures, coordination with first responders, and transmission-level de-energization. CSAC has submitted comments on the phase 2 scoping memo which can be found here.

While these rulemakings will be helpful in the long term, the PSPS events this fall demonstrated quite clearly that much more work needs to be done. As a result, the CPUC opened an official investigation to examine recent PSPS events to ensure utilities are held accountable for their actions during these events. The formal investigation will assess whether the IOUs properly balanced the need to provide safe and reliable service when planning and executing their recent PSPS events. CSAC has asked for feedback from counties on this issue, and will submit formal comments to the CPUC soon.

In addition to submitting comments through the formal regulatory policy development process, CSAC has also been tracking the release of mandated IOU after action PSPS reports. These after action reports are submitted by the IOUs to the CPUC to describe the circumstances of initiated PSPS events. The public is encouraged to provide comments on these documents. CSAC has been actively sending these after action reports out to counties for feedback, and submitted comments of our own based on feedback received. A list of recent PSPS after action reports can be found on the CPUC website for de-energization here.

The use of PSPS is expected increase as an attempt to reduce the likelihood of utility caused wildfires during wildfire season. CSAC will continue to track the development of PSPS policy through multiple forums, and will continue to advocate within the Legislature for additional resources to local governments to deal with these events.