Independent evaluator says RMP risk approach broadly follows standards; FFSL says revised plan complies with statute

The independent evaluator retained in the consolidated dockets told the Utah Public Service Commission that Rocky Mountain Power’s risk‑mapping methods generally comport with industry practice, but the evaluator and other technical reviewers flagged limitations — especially the lack of a complete, monetized cost‑effectiveness analysis tied to mitigation selection.

Independent evaluator findings: The evaluator’s executive summary said RMP’s risk‑assessment methodologies and maps “generally comport with industry standard practices,” and it acknowledged that RMP set out comprehensive programs to address identified risks. But the evaluator also said additional granularity would help better define the company’s High Consequence Fire Areas (HCFA) and that an RSC‑style cost analysis could not be completed because key data were unavailable. The evaluator recommended improved data collection and a more explicit cost‑effectiveness evaluation.

FFSL position: The Utah Division of Forestry, Fire and State Lands (FFSL) told the PSC it actively reviewed RMP’s 2023 filing, worked with the company to provide technical feedback (including on fuel and vegetation inputs) and concluded the revised plan contains the information required by Utah Code § 54‑24‑201. FFSL explicitly said it does not express an opinion on the cost‑benefit analysis debate and instead focused on hazard mapping and mitigation appropriateness.

Points of disagreement in the record: The independent evaluator and FFSL agree on the need for better granularity and that RMP’s revised submission clarified several items. But OCS witnesses and the Division of Public Utilities say the record is still incomplete without a monetized cost‑vs‑risk analysis to allow the PSC to decide whether the plan’s spending levels are reasonable for ratepayers.

Technical detail: Critics in the hearing noted differences between RMP’s HCFA mapping and the independent evaluator’s proxy mapping; OCS and DPU witnesses said those differences show the modeling can yield widely different HCFA footprints depending on inputs and assumptions. RMP’s witnesses have defended their choice of the Fireside (or similar) model and the underlying data.

Ending: The IE’s finding that RMP’s methods generally align with industry practice keeps the debate technical: commissioners must decide whether the existing modeling and reviewer comments provide a sufficient record to approve large new spending levels — or whether RMP must supply additional, monetized cost‑effectiveness evidence before the commission allows expanded rate recovery.