Division of Public Utilities says Rocky Mountain Power’s revised 2023 wildfire plan fails to show costs balance benefits

Division of Public Utilities utility analyst Jonathan Lee told the Utah Public Service Commission he recommends rejecting Rocky Mountain Power’s revised 2023 Wildland Fire Protection Plan because it fails to show the required balance between mitigation costs and the reduction in wildfire risk.

Lee said the company’s revised plan asks for “$371,700,000 for wildfire-related capital expenditure and an additional $74,600,000 for wildfire-related operation and maintenance expense for the 2023–2025 period,” figures far above what the commission approved in 2020, and that the plan “does not properly balance cost with potential benefits.”

Why it matters: Utah law requires the commission to approve a wildland fire protection plan only if the evidence shows the plan is reasonable, in the public interest and “appropriately balances the cost of implementing the plan with the risk of a potential wildland fire.” Lee told commissioners the revised plan provides more descriptive material but does not give the commission the analysis it needs to judge whether the spending is just and reasonable for Utah ratepayers.

Details: Lee recounted that Rocky Mountain Power spent well above the amounts contemplated by the 2020 plan, reporting that RMP’s actual wildfire capital spending was many times the approved 2020 levels in 2022–2024. He told the commission the Division recommends the revised plan be rejected and that, in the meantime, the commission set test-year 2025 allowable wildfire capital at $40,500,000 and O&M at $4,800,000 — figures the Division considers more reasonable and tied to the previously approved plan.

Lee also urged that the commission deny RMP’s request to recover through Schedule 97 (the wildfire mitigation balancing account, or WBA) approximately $21,000,000 of deferred costs from 2021–2023. He told the commission that some of those deferred amounts include spending not authorized by the 2020 plan and that the Division sees limited evidence that the company’s accounting properly distinguishes incremental wildfire costs from amounts already reflected in base rates.

Lee’s testimony acknowledged climate-driven wildfire risk is rising, but he said that makes it all the more important that the commission be able to evaluate whether the scale and pace of mitigation spending are cost-effective for Utah ratepayers. "Without a meaningful cost-benefit analysis provided by the company, it’s problematic for the commission to determine if the WMP actually balanced risk with potential costs," Lee said on the record.

What the Division asked the commission to do: reject the revised 2023 WMP, limit the 2025 test-year capital and O&M amounts to the Division’s recommended levels, and deny recovery now of the roughly $21 million in deferred costs. The Division said those amounts could be revisited if the company returns with an approved plan that demonstrates the required balancing of costs and risks.

Context & next steps: The Division’s position puts it at odds with Rocky Mountain Power’s revised filings but aligned with Office of Consumer Services witnesses who also urged stronger, quantified cost–risk evidence before full recovery. The PSC will weigh the record — including testimony from the Division, OCS, the independent evaluator and other parties — before issuing its decision.

Ending: Lee’s recommendations leave the commission with a procedural question: accept the revised plan and allow wider recovery now, or require RMP to provide a clearer, quantified cost-versus-risk justification before allowing the higher spending levels to be charged to Utah ratepayers.