Small utilities tell CPUC: adapt assessments — surveys alone won’t work for tiny operators
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Summary
At a CPUC workshop, small‑utility and gas‑storage representatives warned that perception surveys are limited for organizations under ~50 employees and urged qualitative, scaled assessments (document review, field observation, interviews) and flexible, low‑cost third‑party options; an ALJ ruling to set filing dates was promised.
Small utilities and independent gas‑storage operators told the California Public Utilities Commission at a Safety Policy Division workshop that the safety‑culture assessment approach used for large investor‑owned utilities must be tailored in scale and method to be useful and feasible for small organizations.
Speakers from a range of small utilities — including storage operators and gas distributors with as few as seven employees — described a recurring problem: perception surveys, while common, often produce positively skewed scores that are hard to interpret and provide limited actionable insight at small sample sizes. "Surveys are of less value or not appropriate under 50 employees," Dr. Mark Fleming said in the workshop, adding that surveys can mislead if used as the primary assessment tool in small organizations.
Utility representatives described alternatives and practical needs. Greg Clark (Rockpoint) and Harold Gold said Rockpoint supplements surveys with interviews and department‑level review to identify trends and follow up with tangible improvements. PacificCorp’s Joe Cysna said comment fields and qualitative responses often surface the most useful insights. Several small distributors described daily, face‑to‑face safety communications and urged flexibility rather than one‑size‑fits‑all mandates: "When problems arise... it's always discussed and a way to move forward is already established," said Cindy of West Coast Gas.
Dr. Fleming recommended a scaled, qualitative approach for smaller entities: focused document analysis, field observation of operations and short interviews with staff and contractors — a process that could be completed in a day or two for the smallest operators. He cautioned against rigid employee‑count cutoffs and recommended an approach based on organizational needs and risk profiles rather than a single numerical threshold.
Cost and evaluator availability were recurring concerns. Several operators warned that third‑party firms that conduct multi‑week, IOU‑scale assessments may not be appropriate or affordable for small utilities; participants urged CPUC to allow short, tailored engagements and to test market availability before imposing rigid requirements.
The workshop closed with next steps: ALJ Chang said a ruling setting dates for comments and party proposals will be filed soon. Parties were invited to submit proposals describing scalable assessment methods; SPD said it will share slides and reference materials and host a follow‑up workshop to vet proposals.
Provenance: starts with SPD’s presentation summarizing filings (small utilities responses) and includes the roundtable comments and Dr. Fleming’s recommendations; ALJ’s procedural remark about a forthcoming ruling concluded the session.
