CPUC staff unveils draft RAMP/GRC data templates; utilities press for flexibility on several fields

Eddie (Safety Policy Division staff) opened the California Public Utilities Commission technical working group by presenting SPD’s draft data templates for RAMP and GRC filings, saying the templates are intended to “help everybody get clarity on the field name, the field description, and the field value constraints for each variable” the staff proposal includes.

The templates are intended to collect linked, project-level information for each proposed mitigation — which SPD calls a Risk Reduction Unit (RRU) — and require each RRU to include one proposed mitigation and two alternative mitigations so reviewers can compare outcomes across options. SPD staff said the RRU identifier (RRUID) must include the GRC activity code and be simple, unique and non‑reusable; it will be the primary key linking data across tables in the submission.

SPD described seven tables that together form the submission: Table 1 (mitigation/control inventory and core risk/cost fields), Table 2 (cost causes breakdown), Table 3 (risk model change tracker, electric-only), Table 4 (HFTD-associated assets, electric-only), Table 5 (gas infrastructure inputs), Table 6 (financial inputs and constants such as discount rates and monetization values) and Table 7 (inputs used to monetize electric reliability via the ICE calculator).

Why it matters: SPD said standardized, machine-readable templates will make RAMP and GRC filings easier to compare, reduce double-counting and improve auditability of utilities’ rate requests. The templates would be submitted with a RAMP application and updated when utilities file GRCs, SPD said.

During Q&A, utility representatives raised practical concerns and asked SPD to allow flexibility in several fields. SCE and other utilities questioned the requested level of geographic granularity for ICE‑based monetization (SPD asked for operational-division breakdowns by HFTD and non‑HFTD), saying some utilities anticipate a territory‑wide ICE calculation or have modeling constraints that make very granular ICA inputs impractical. SPD responded that it expects to align template variables with the final ICE 2.0 tool and will consider adjustments if Lawrence Berkeley’s next ICE release changes input structure.

Another point of contention was whether present‑value revenue requirement (PVRR or PVRR‑style multipliers) must be included in benefit–cost ratio (BCR) calculations at the RRU level. PG&E staff explained that in their prior RAMP filing they included a PVRR multiplier (a customer revenue‑requirement adjustment) in the denominator of their BCR; other utilities said they did not and that the CPUC decisions do not require a PVRR at RRU granularity. SPD said it will reconsider how to treat PVRR in the templates and may adjust guidance after reviewing feedback.

SPD clarified several structural rules that generated follow-up questions: each RRU can only be associated with a single tranche (per the Phase 3 decision), the proposed/alternative mitigation rows mean there will typically be three rows per RRU in the main table (proposed + two alternatives), and Table 3 (risk model change tracker) is meant to capture renaming/splitting/merging or new data inputs so that risk scores across filings remain comparable.

Utilities and intervenors also sought clarity on non‑asset risks (for example, training or cybersecurity). SPD said the templates permit listing “systems” instead of physical assets and expects parties to explain system definitions in the narrative or cover letter so reviewers can interpret which personnel or processes are being mitigated.

Administrative outcomes and next steps: SPD requested that utilities file workshop summaries and completed templates to the docket. Timelines announced on the call: draft working group summaries from utilities were requested by Feb. 7; parties’ feedback to the utilities by Feb. 14; and PDFs of final summaries and the data‑template and guideline filings to the docket by Feb. 18 (utilities to provide a Word and an Excel version to SPD as well). SPD also said it will accept examples in the Excel submission to illustrate how fields should be populated.

There were no formal votes or regulatory decisions on the call. The session closed with SPD asking for written feedback and indicating it would refine the templates and guidance on the basis of workshop comments.

Ending: SPD said it will incorporate the feedback received, update templates where appropriate, and expects continued discussions in the technical working group and in written comments ahead of the next filing windows.