Office of Consumer Services, OCS experts press PSC to require quantified cost–risk analysis before approving RMP’s expanded plan

Office of Consumer Services witnesses and consultants told the Utah Public Service Commission the record in RMP’s Wildland Fire Protection Plan docket lacks the quantified cost–versus‑risk evidence the commission needs to decide whether to allow recovery of substantially higher wildfire spending.

OCS summary: OCS witness Bela Bastag and consultants Dennis Stevens and Paul Álvarez argued that the company did not include a cost‑effectiveness analysis sufficient to permit the PSC to find the plan appropriately balances implementation cost with wildfire risk. The OCS recommended the commission reject the revised 2023 WMP or, if the commission does not reject it, limit the 2025 test‑year amounts for ratemaking and deny recovery now for deferred 2021–2023 costs that exceed the previously approved 2020 plan.

Why it matters: Multiple OCS witnesses said the statutory standard — that the plan be reasonable and appropriately balance cost and risk — requires quantified evidence. OCS argued the independent evaluator and several parties identify the lack of a meaningful, monetized cost‑benefit or “risk‑informed benefit‑cost” analysis as the central shortcoming.

Experts’ proposals: Dennis Stevens explained the analytical approach he and OCS endorse: estimate the monetary consequence of ignition (dollars per event), estimate the probability an equipment fault produces ignition, and estimate how a mitigation reduces that probability — then compute the present‑value benefits of mitigation and compare to mitigation cost. Stevens said that approach yields a transparent, per‑segment measure that regulators and intervenors can test and that can be used to prioritize mitigations.

OCS economist Paul Álvarez used that comparison to illustrate tradeoffs. He presented examples comparing undergrounding, covered conductor and vegetation management on a dollars‑per‑mile and miles‑covered basis. Álvarez argued vegetation management can yield more miles of risk reduction per dollar in many cases and urged the commission to approve a higher O&M allowance directed to vegetation management while holding capital recovery to previously approved levels pending a full cost‑risk analysis.

OCS recommendations on numbers: OCS recommended using the previously approved 2020 plan as the base for ratemaking immediately and proposed test‑year limits of $40,500,000 capital and $24,900,000 O&M for 2025 (OCS explained the higher O&M figure is intended to prioritize vegetation management). OCS also recommended reducing the $21,028,285 WBA deferral request by amounts that OCS says are not incremental or were misallocated.

What OCS told the PSC: "The company has not provided the required evidence demonstrating to the commission that the 2023 plan appropriately balances costs with wildfire risk," OCS witness Bela Bastag said. Independent contractor Dennis Stevens testified the standard model should be supplemented by historical fault and ignition data and monetized consequences to quantify risk reductions.

Context and next steps: OCS urged the commission to require RMP to produce and file risk‑informed benefit‑cost analysis in the next update of its WMP and warned that creating a separate stakeholder docket (as RMP suggested) could delay necessary improvements and shift the primary burden from the company to intervenors.

Ending: The OCS position raises a procedural choice for the PSC: require RMP to produce a quantified, monetized cost‑risk analysis now and limit recovery until that is reviewed, or accept a less‑quantified record and allow broader recovery immediately. The PSC will decide as part of its order.