CPUC workshop weighs updating general orders to require climate adaptation for electric utilities

The California Public Utilities Commission’s Safety Policy Division (SPD) and the Office of Energy Infrastructure Safety (Energy Safety) held a workshop to discuss whether and how the commission should update multiple general orders to incorporate climate adaptation measures for electric utilities.

SPD senior regulatory analyst Jeanette Ramon opened the session, noting that “AB 111 was passed in 02/2019 meant that mandated review as necessary safety and regulatory requirements for electric facilities along with recommendations related to climate change,” and that the workshop addresses phase 2, task 6 of rulemaking R.18-04-019.

SPD said its three-round analysis of the CPUC’s 94 general orders narrowed the list to six that staff judged both relevant to climate adaptation priorities and feasible to modify: General Orders 95, 128, 165, 166, 167B and 174. Maria Jaya, a senior public utilities regulatory analyst in SPD, described nine thematic areas that cross those general orders, including site selection, construction, equipment tolerance, repetitive loss, inspections, reporting, system-failure response, reconstruction and interagency processes.

The Office of Energy Infrastructure Safety proposed a set of practical changes for the commission to consider. Colin Lang, environmental policy supervisor at Energy Safety, said a starting point is asset inventories: “It is Energy Safety’s belief that, if the utilities don't know where and what their equipment is, they cannot plan for future climate scenarios adequately.” He recommended the commission consider requiring digital, geospatial asset inventories with standard attributes and nomenclature.

Energy Safety also urged the CPUC to consider requirements for on-site weather stations and data-collection standards to support operational decisions such as disabling reclosers or initiating public safety power shutoffs. Lang said SPD and Energy Safety should consider modifying General Order 95 so design, construction and maintenance rules require utilities to consider future climate forecasts and not only current local conditions.

Other Energy Safety recommendations included prioritizing replacement of nonexempt electrical equipment (for example, expulsion fuses and certain lightning arrestors) with equipment that is less likely to ignite vegetation; requiring risk-informed and prioritized inspections that include vegetation management; and adopting standards for remote monitoring and protective devices with fast response times. Lang also suggested aligning pruning practices with ANSI A300 tree-care standards and updating applicable General Order 95 provisions accordingly.

SPD researchers explained how they selected the six general orders for further consideration. Britney Gaines, a research data specialist in SPD, said the staff applied inclusion and exclusion criteria in three screening rounds that first limited the set to general orders within scope, then tested whether each order mapped to six state climate-adaptation priorities, and finally assessed feasibility of modification. SPD noted some general orders were excluded because other state or federal rules already govern the topic.

SPD presented three procedural approaches for implementing changes: (1) update individual general orders through separate or multi-track proceedings; (2) adopt a new umbrella general order on climate adaptation that would coordinate across the nine thematic areas; or (3) adopt commission decisions within R.18-04-019 that set climate-adaptive standards without directly amending existing general orders. SPD staff said the three approaches are not mutually exclusive and invited feedback on trade-offs between speed, flexibility and centralized coordination.

A panel of utility and agency representatives described how climate adaptation is already being incorporated and the practical barriers staff should weigh. Speakers included Sandy Portla, director for fire science and climate adaptation at San Diego Gas & Electric; Anna Rockway, senior advisor for integrated planning and climate adaptation at Southern California Edison; Nathan Benson, senior manager of enterprise climate resilience at Pacific Gas & Electric; and Colin Lang from Energy Safety.

Panelists said utilities are using climate-vulnerability assessments (CAVAs) and other planning tools to integrate climate projections into long-term planning and general rate case filings, but they identified three recurring challenges: (1) temporal resolution — many planning and load-forecasting models operate at hourly or daily resolution while climate projections are typically presented at decadal scales; (2) uncertainty — downscaling projections and translating them into actionable, defensible engineering inputs requires careful technical work; and (3) alignment — agencies, utilities and planners need common scenarios, assumptions and definitions to avoid inconsistent results across proceedings.

Nathan Benson said the climate-adaptation vulnerability assessments are a critical first step but noted a remaining need to translate CAVA outputs into risk metrics that feed capital-planning and risk-based decisionmaking frameworks. Anna Rockway and other utility speakers said the work is underway inside companies and across proceedings, and they urged phased, targeted approaches so requirements remain feasible for asset-specific engineering and local conditions.

Workshop participants discussed how general orders could be used to raise baseline expectations (for example through inspection, maintenance and reporting standards that permit commission audits) while leaving detailed design choices to utility engineering standards. A participant pointed out that a general-order framework also provides the commission a mechanism to audit compliance and require corrective actions; SPD confirmed a follow-up ruling with written questions to parties will be issued after the workshop and that the workshop recording will be posted.

Why it matters: The commission’s general orders set minimum safety, construction and maintenance rules for utilities. Updating those orders to require climate-aware siting, design, inspection and monitoring could change how utilities size, maintain and replace long-lived equipment, and could affect inspection regimes, reporting obligations and investment priorities that influence rates and reliability.

Next steps: SPD will circulate a follow-up ruling with questions for parties (staff said parties will have an opportunity to respond in writing). SPD and Energy Safety will continue coordination on topics raised, and the CPUC said the workshop materials and recording will be posted.