CPUC staff seek clarity on SB 884 data template; utilities told to report latest project data through 'used and useful'

At a technical working group meeting, California Public Utilities Commission staff asked utilities to provide feedback on a draft SB 884 project‑list data template and said utilities must submit the most up‑to‑date information in phase 2 applications and in subsequent progress reports until a project is “used and useful.”

The template is intended to standardize how utilities report undergrounding project information so data are comparable, traceable and aligned with CPUC resolutions, CPUC staff presenter Amin Amrani said. That information will feed cost‑benefit calculations and oversight of Phase 2 applications and later progress reports.

The meeting focused on detailed questions PG&E and other stakeholders had submitted in writing: when and how cost‑benefit ratio (CBR) and unit‑cost forecasts should be updated; whether CapEx and OpEx fields should reflect lifetime or construction‑only costs; how to report pre‑ and post‑mitigation risk values; how to identify the granular “assets or systems” that a project affects; and how project, subproject and RRU identifiers should map across Energy Safety and CPUC datasets.

CPUC staff said utilities should submit the latest available or calculated data when filing a Phase 2 application and should repeat all table fields in every six‑month progress report until the project is used and useful. "The primary goal of the template is to establish a structured and consistent way for utilities to submit...project information in compliance with the SB 884 application," Amin Amrani said.

PG&E representatives sought confirmation that forecasted CBR and unit costs could change as projects progress and be updated at lifecycle milestones such as the end of scoping or design. Justin Sadler, senior director for undergrounding strategy and programs at Pacific Gas and Electric Co., said, “we would provide the latest information that we have” in each report, and PG&E engineers described plans to use subprojects and order numbers to break projects into component work.

CPUC and Energy Safety staff clarified that the Phase 2 application includes forecasted values that serve as the benchmark for later variance calculations. Eddie Schmidt of CPUC staff noted there is a forecasted CBR in the Phase 2 filing that becomes the baseline for measuring future variance. Energy Safety staff member Estefan added that if a project’s scope or outputs change after screening, the utilities should present updated screen‑3/4 and subproject tables in the next progress report so the final, completed project numbers are reflected.

On CapEx and OpEx, PG&E asked whether table fields should include lifetime operations and maintenance or only construction costs. CPUC staff said the template intends the totals reported across tables to align and asked PG&E to provide written suggestions clarifying which items to include in lifetime O&M so the CPUC can finalize field definitions.

Stakeholders also raised technical questions about the template’s “tranche” (trench) and “assets or systems” fields. CPUC staff said the term is intended to be more granular than circuit segments and encouraged utilities to propose precise definitions in writing. Ian (participant) described how utilities model risk at the asset type level (poles, lines, transformers) and said the template should map to that granularity for clean comparisons.

To preserve comparability when utilities submit project‑level data initially and later report subprojects, CPUC staff described three backcast fields that will allow an “apple‑to‑apple” comparison of the original forecast to updated subproject figures, including a backcasted present‑value benefit, backcasted present‑value cost and backcasted CBR.

The CPUC team said primary keys in tables — project ID, subproject ID and RRU ID — are intended to match corresponding IDs in Energy Safety/OES datasets so the files can be joined. Staff reiterated that when utilities move from project to subproject reporting, the reporting date on each progress report will distinguish successive submissions.

No formal rulings were issued at the workshop. Staff asked stakeholders to submit written comments and signaled a follow‑up technical working group focused on the ICE calculator (version 2) on June 24, when Lawrence Berkeley National Laboratory will present updates and utilities may describe adoption plans.

The meeting included sustained, technical debate over how to preserve benchmarking across a multi‑stage project lifecycle, and stakeholders repeatedly requested clearer written definitions for items such as lifetime O&M, asset‑level identifiers and the rules for locking or updating reported fields. CPUC staff repeatedly invited written follow‑up: they will review comments received and adjust the template or guidance as appropriate.

Next steps: utilities were asked to submit written clarifications on specific fields (for example, which costs count toward lifetime OpEx), to use the template fields in six‑month progress reports through used‑and‑useful, and to participate in the June 24 session on the updated ICE calculator.