Energy Safety found that PacifiCorp completed only seven of its 13 vegetation management initiatives and did not provide sufficient corrective action for completion of the remaining six initiatives. These included wood and slash management, pole clearing, clearance, high risk species, quality assurance and quality control, and open work orders.

Energy Safety concluded that PacifiCorp’s execution of necessary corrective actions to address deficiencies has not demonstrated a commitment to risk reduction and program maturity. While PacifiCorp is working to develop corrective actions to address these deficiencies, it did not provide a timeline for implementation.

Energy Safety will continue to review and inspect PacifiCorp’s progress on its vegetation management program maturity.

Opening comments must be received by June 1. Reply comments must be received by June 11. Comments and reply comments must be submitted to the Executive Compensation Guidelines Docket (#Guidelines-EC) via Energy Safety’s e-filing system.

Energy Safety does not set or approve the actual salaries of corporation executives.

The guidelines assist electrical corporations seeking Certificate (formerly safety certification) in developing their executive compensation structures. Electrical corporations are statutorily required (Pub. Util. Code § 8389(e)(4)(Pub. Util. Code § 8389(e)(6)) to have an executive compensation structure that meets specific criteria to be eligible for the Certificate.

The Certificate process is designed to encourage electrical corporations to invest in safety and improve safety culture to limit wildfire risks and reduce costs. An electrical corporation with a Certificate is presumed to have acted reasonably in proceedings before the CPUC to recover costs of a utility-caused wildfire unless demonstrated otherwise.

Certificate FAQs

Energy Safety found that HWT completed all (three of three) of its 2024 initiatives in its 2023-2025 Base WMP. On its overall 2024 WMP budget, HWT spent above the proposed amounts of its 2024 WMP initiatives by $149,000. This was mostly due to HWT incurring costs significantly above proposed amounts for asset inspections. Energy Safety and the independent evaluator did not find any systemic issues that hindered HWT’s ability to adequately implement its WMP in 2024.

Energy Safety will continue to monitor documentation and reporting on targets and initiative attainment to ensure that HWT remains consistent for future WMP cycles and to improve its ability to eliminate utility-caused catastrophic wildfires in California.

PacifiCorp is making an important advancement by implementing the first version of its investment planning model. This will enable PacifiCorp to identify the assets most at-risk from wildfires, assess the cost efficiency of its grid hardening activities, and map its High Fire Risk Areas.

Additionally, PacifiCorp is running power simulation models on de-energized transmission lines to learn of its induction risk and mitigations for coupled lines. While PacifiCorp took the initiative to evaluate induction risk, Energy Safety has required an induction risk assessment of all electrical corporations in their WMPs. PacifiCorp has also established risk remediation timelines for its vegetation management efforts, that if followed, will reduce wildfire risk.

However, there are areas where PacificCorp needs to improve, that include further implementation of its grid hardening management initiatives, and prioritizing mitigations based upon a more developed understanding of all risks. Progress in all areas must be demonstrated in PacificCorp’s future WMPs.

The audit covered 13 vegetation management initiatives in six programmatic areas of PG&E’s 2024 WMP. Energy Safety found that PG&E completed 12 of 13 vegetation management initiatives for 2024. Energy Safety has identified one outstanding initiative deficiency within PG&E’s vegetation management program regarding wood and slash management. PG&E has acknowledged this deficiency and has implemented a plan for corrective action.

Energy Safety’s assessment of TBC found that it did not have any WMP initiative work planned for 2024 in its 2023-2025 Base WMP and therefore, had no proposed budget. However, TBC spent $35,800 to install a fire suppression system in its spare parts building that was a carry-over expense from its 2023 WMP work. Also, the independent evaluator (IE) assigned relatively low scores to TBC’s quality assurance quality control program maturity, a clear indication that TBC must mature these programs moving forward.

Energy Safety’s assessment of LS Power found three of four of its 2024 initiative targets activities completed in its 2023-2025 Base WMP. LS Power failed to meet its target for one of its 2024 WMP initiative activities to install cameras at both its Orchard and Fern substation sites. Only the Orchard site had camera installations completed in 2024. LS Power also spent below its proposed amount, for initiatives applicable to 2024, by approximately $26,000 (88% of its proposed budget). LS Power explained that actual expenditures deviated from its proposed expenditures for various reasons, including emergency preparedness activities that required less resources than had been forecasted.

Energy Safety will monitor TBC’s and LS Power’s progress and expects improvement for both moving forward,

Liberty Utilities has been unable to satisfactorily demonstrate how it can identify and mitigate wildfire risk across its system effectively. Liberty must develop a wildfire mitigation plan that can be approved by prioritizing plan initiatives that reduce that risk, correct the deficiencies in their WMP, and resubmit a new plan.

Energy Safety has identified a series of steps Liberty should take to ensure that their WMP may ultimately be approved. It’s expected that Liberty will submit a new plan later in 2026.

Energy Safety found that SCE has made year-over-year improvements in achieving 12 of its 13 vegetation management initiatives for 2024. However, Energy Safety did identify one outstanding deficiency in open work orders. SCE has acknowledged this deficiency and has either planned or initiated implementation of corrective actions for it to be addressed.

An electrical corporation must demonstrate completion of seven statutory requirements to be eligible for a certificate. An electrical corporation with a certificate is presumed to have acted reasonably in proceedings before the CPUC to recover costs from a utility-caused wildfire unless demonstrated otherwise.

A certificate does not protect or shield an electrical corporation from liability, nor does it constitute an affirmation by Energy Safety that an electrical corporation has taken all possible steps to prevent its equipment from causing wildfire or is in full compliance with its wildfire mitigation plan or other laws and requirements.

Certificate FAQ

PacifiCorp is making an important advancement by implementing the first version of its investment planning model. This will enable PacifiCorp to identify the assets most at-risk from wildfires, assess the cost efficiency of its grid hardening activities, and map its High Fire Risk Areas. Additionally, PacifiCorp is running power simulation models on de-energized transmission lines to learn of its induction risk and mitigations for coupled transmission lines. While PacifiCorp took the initiative to evaluate induction risk, Energy Safety has required an induction risk assessment of all the electrical corporations in their WMPs. PacifiCorp has established risk remediation timelines for its vegetation management efforts, that if followed, will reduce wildfire risk.

There are areas where PacificCorp needs to improve that include prioritizing mitigations based upon an understanding of all risks. Further, PacifiCorp must overcome its grid hardening management challenges so risk reduction may be realized. Additionally, PacifiCorp must complete implementation of its enhanced safety settings to maximize the potential of the program. Progress in all these areas must be demonstrated in PacificCorp’s future WMPs.