Cal Advocates proposes project‑level, spatial reporting for utility risk mitigation; IOUs raise feasibility and confidentiality concerns

Cal Advocates, the Public Advocates Office at the California Public Utilities Commission, presented draft data templates at a CPUC technical working group meeting to require program‑level and project‑level reporting on utility risk‑mitigation work and to include spatial location data that would enable mapping and analysis.

The templates are intended to be filed with utilities’ Risk Assessment Mitigation Plans (RAMP) and general rate case (GRC) applications and then updated annually. Cal Advocates said the forms would consolidate program identifiers, forecast versus actual costs and work units, pre‑mitigated (baseline) risk, forecasted and actual risk reduction, mitigation effectiveness, lifecycle cost estimates, and a geospatial key linking project rows to shapefiles or other mapping files for spatial analysis.

Cal Advocates said the change would give the Commission and parties a consistent way to compare projects and programs across filings and to verify whether utilities are prioritizing work in the highest‑risk areas. Cal Advocates also demonstrated examples of heat maps and circuit overlays — including an example tied to outages during Enhanced Power Line Safety Settings (EPSS) activity and an overlay using PG&E’s WDRM version 3 wildfire risk layer — to show how mapping could reveal where mitigations occurred and how much of at‑risk area was converted from overhead to undergrounding.

Why it matters The templates are pitched as a transparency tool for a regulatory process in which utilities submit a mixture of forecasts and later reports of actual work. Cal Advocates said annual, standardized reporting could help the Commission evaluate ratepayer impacts and the effectiveness of different mitigation options before the next multi‑year GRC cycle.

What Cal Advocates would collect - Program template: one file aggregating program‑level information across RAMP/GRC/WMP filings, including program IDs, whether a program is capital or expense, forecast and actual costs by year, forecast and actual work units, pre‑mitigated risk and forecasted/actual risk reduction, the risk‑scaling function used, program effectiveness and links to supporting workpapers. - Project template (per program): rows for each project or RRU with a unique project/RRU ID, county and location, forecast and actual cost and work units by year, mitigation effectiveness (as defined by the utility), constraints and rationale for selecting the project, and fields to compare alternatives (for example, cover conductor vs. undergrounding).

Key disagreements from utilities and parties Several investor‑owned utility representatives said the templates blur forward‑looking forecasts and after‑the‑fact analysis. A utility speaker noted many RAMP and GRC entries are forecasts, that utilities often do not have locationally precise data years in advance, and that some risk models are updated infrequently (every two to three years rather than annually). Another utility representative said tracking every RRU and updating lifecycle or actual asset‑life fields for thousands or millions of projects would be resource intensive and operationally complex.

Utilities also raised confidentiality and security concerns about location‑level data. One utility representative said locational risk or asset data can be sensitive and that utilities typically provide public and confidential versions of detailed files and make confidential datasets available to intervenors under non‑disclosure agreements or memoranda of understanding.

Points of procedural and technical clarification - Cal Advocates said blank cells or explanations would be acceptable where data are not available for forecasts; the office described the templates as recurring annual reports that would be updated as information becomes available. - Parties suggested adding tranche information to the project template so projects can be tied to tranches used in tranching approaches; Cal Advocates agreed to consider including that field. - Several participants recommended that spatial data be submitted in a format that ties shapefiles (or GDB features) to tabular records via a stable primary key (for example, an RRU ID plus an effective date), and that the Commission clarify whether public or confidential versions will be required. - On lifecycle cost, Cal Advocates said the intent is to capture full lifecycle (including retirement/removal) so the Commission can compare long‑term costs of capital versus expense approaches; utilities noted lifecycle calculations involve many variables (rate of return, depreciation, tax treatment) and asked for more guidance.

Next steps Cal Advocates said parties could refine the templates and asked that updated templates be submitted by the filing date they cited (February 18). SPD (Safety Policy Division) was scheduled to present the following day and parties flagged the need for additional, detailed exchanges on implementation (file formats, primary keys, confidentiality protocols, and which fields should be mandatory vs. optional).

The meeting closed with plans for further technical discussion and with Cal Advocates and utilities agreeing to continue to refine the templates and their implementation details.