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Regulators Investigate New Rules for Utility Wildfire Mitigation Plans

Clearing in a forest after a wildfire with burnt trees on the ground

This wildfire season, communities like Talent were left without power in 100+ degree heat. While the intent was to reduce the risk of wildfires, these planned shutoffs created new safety issues. Preventing wildfires should not make us less safe. Our communities need to be consulted and informed of how our utilities plan for wildfires.

This summer, regulators are beginning to address the issues with utilities’ wildfire mitigation plans. CUB, the NW Energy Coalition, and other advocates are asking regulators to improve the process and tighten requirements for utilities’ wildfire mitigation plans. We are working to make sure that these plans are made to support community needs and solutions, and do so affordably.

What is a Wildfire Mitigation Plan?

Wildfire mitigation plans are meant to show how electric utilities plan to handle wildfire danger in their service areas. These plans must identify high-risk areas for wildfires. They need to show utilities’ policies and investment plans for reducing the risk of wildfires. And utilities are required to collaborate with local communities in the planning process.

In 2021, the Oregon State Legislature passed a law that requires utilities to create comprehensive plans for lowering the risk of wildfires in Oregon. This law applies to the state’s three for-profit electric utilities: Portland General Electric, Pacific Power, and Idaho Power.  Regulators at the Public Utility Commission ensure that utilities create holistic, cost-effective plans each year.

Intended Wildfire Mitigation Plan Requirements

Each year, electric utilities must file a plan to handle wildfire danger in their service areas. These plans include identifying wildfire risks where they are delivering electricity. Utilities also must identify risks around where they are moving electricity across distances. (e.g. power lines).

Through their analyses, utilities must include a description of what they are doing to reduce wildfire risk. This includes:

  • Vegetation management (tree trimming, removal, etc.)
  • System hardening (insulating wires, sensors for downed lines, etc.)
  • Investment decisions (new line locations, power plant locations, etc.)
  • Operational decisions (when to shut off power based on weather, etc.)

In theory, there are many other requirements. Utilities must also show that their plans include best practices for lowering the risk of starting wildfires. They must analyze the cost-effectiveness, risk reduction effectiveness, and overall plan strategy. They must show how they will collaborate with community leaders and first responders. And they must give updates on lessons learned from previous years.

In practice, the wildfire mitigation plans have been missing the mark.

Wildfire Mitigation Plan Fall Short of Requirements

In reality, utilities have filed their wildfire mitigation plans and regulators have approved them while chastising the utilities for their lack of analysis. 2024 marks the third year that utilities haven’t shown their work and proved that they are using the best strategies.

Utilities are not showing their work. They are not showing how they are analyzing multiple strategies, including robust cost-effectiveness and risk reduction analysis. They have not been meaningfully engaging with communities. There are no updates on what has worked and what hasn’t. And there have been no justifications for changes from the previous year.

This means that utilities are creating plans without showing they are considering cost-effective strategies, how effective they are, and how they will impact communities’ lived experiences. While CUB understands that regulators have been more lenient as this process has started, it is time to create a better strategy.

The lack of community engagement is having a real impact on Oregonians. In Talent, local residents, and even the mayor, have serious questions about how Pacific Power plans for planned shutoffs. Oregonians across the state have been left with questions and concerns about our utilities’ plans for wildfire safety.

We need our utilities to consult and inform communities about wildfire plans and their impact on people’s lives.

Regulators Push to Tighten Requirements for Utilities

This summer, regulators are attempting to fix some of the issues with the wildfire mitigation plans. The Public Utility Commission is working to standardize the process and require greater analysis from utilities. We agree with this decision. CUB has been concerned that utilities are not putting enough emphasis on community engagement and are pushing to fix that.

For the first three wildfire mitigation plans, regulators gave the utilities some flexibility to adapt to a new process. This year, they are planning to tighten the reigns. The Public Utility Commission is working on creating clear guidelines for how these plans should be structured.

Regulators proposed a new structure in July 2024 with a few big changes to how wildfire mitigation plans are created and reviewed:

  • Creating a template for the information included in plans
  • Standardizing review process for plans across utilities
  • Creating criteria for evaluating plans across utilities
  • Moving to a multi-year plan with an annual review instead of a one-year plan

While these procedural changes are important, they do not address the lived realities of the people utilities are attempting to protect. Utilities need stronger requirements for meaningfully engaging with communities.

We need regulators to ensure utilities’ wildfire plans support community needs and solutions.

Advocates Push to Center People in Wildfire Planning

While some parts of wildfire mitigation plans do not have major impacts on Oregonians’ daily lives, many strategies do. We need plans that prioritize consulting and informing communities of strategies that impact health and safety.

Utilities’ plans can include solutions ranging from trimming trees to preventing energy running to downed lines. But they can also include larger strategies like public safety power shutoffs. While these shutoffs are critical to preventing wildfires, they have a big impact on customers. During a planned shutoff, neighborhoods or whole cities may go without power for many hours in the middle of the summer.

Advocates from CUB and the NW Energy Coalition are calling on regulators to center people in wildfire mitigation plans. We are asking that utilities:

  • Include communities’ input on strategies when creating plans
  • Detail plans for comprehensive outreach to communities after plans are created
  • Expand access and coordination for resources, such as Community Resource Centers, for public safety power shutoffs

Include Community Input: While utilities already have data to know where the risk of wildfire is highest and where they need to invest, communities can help guide investments. Community knowledge is critical to support the people who are impacted by wildfire mitigation strategies.

Comprehensive Community Outreach: Utilities often communicate with the public by sending an email to customers or posting on social media. This misses a huge section of the community when communicating important information. Utilities should create community-informed plans for meeting people where they already are, like at community events, working with local nonprofits, and more.

Expand Community Resource Centers: Sometimes public safety power shutoffs are a necessary strategy. But when the power is out, especially on extremely hot days, people need places they can go to be safe. Having strategic and community-informed locations for resource centers can be lifesaving, in both rural communities and more densely populated areas

Wildfire Mitigation Plans Are Already Impacting Oregonians

We have already seen utilities request huge amounts of money to cover wildfire-related costs in the past few years. This year, communities in wildfire-prone areas have seen what happens when utilities’ plans do not adequately engage with the communities they serve. Because of the impact we’re already seeing, the changes regulators are proposing are more important than ever.

Communities Face Unsafe Conditions Without Effective Planning

In a report by KDRV on August 16, Talent Mayor Darby Ayers-Flood expressed issues with ongoing power outages by Pacific Power. The city has faced “crisis level outages” with power shut-offs that are “prolonged or consistent during triple digit weather.” Pacific Power has not communicated these planned outages to local government, much less customers.

While shutting off power to prevent wildfires is a key strategy for utilities, it also has a major impact on communities. This is why lawmakers included community outreach and collaboration in the creation of wildfire mitigation plans. Without key input from the public and communication to Oregonians, utilities are causing a different issue of public safety for customers.

This summer, many Oregonians have been left in the dark—literally and figuratively—about utility plans to shut down power grids to prevent wildfires. When people are unprepared for a planned shutoff, there are lasting impacts on health, safety, and livelihood. Those with medical devices are left at risk for a health issue. Emergency services are harder to access without a way for people to call for help. If businesses are unable to open, workers and owners lose income.

Wildfire Costs Are Driving Up Energy Bills

Over the past few years, we have seen a dramatic increase in how much utilities are spending on wildfire mitigation. While many of these costs are necessary, it’s impossible to tell what is necessary and what is not without plans that include thorough analysis.

Pacific Power alone has already spent tens of millions of dollars of customers’ money on wildfire mitigation. Pacific Power’s billing rates increased 21% in 2023, with the largest driver being wildfire mitigation. This year, Pacific Power is proposing charging customers $21.2 million per year for wildfire mitigation starting in 2025.

People are already paying for wildfire mitigation plans. We need to have a say in how that money is spent. And we need our utilities to be investing in solutions that work for the people they serve.

Submit Public Comment by August 30, 2024

Regulators are asking advocates and members of the public to submit comments before August 30th on these new rules. CUB recommends that comments should focus on increasing community involvement with the creation of wildfire mitigation plans.

Action Form: You can use this CUB form that includes a template for public comment. For a greater impact, make sure you customize the message to regulators!

Email/Phone: Email .(JavaScript must be enabled to view this email address) (include “Comments on UM 2340 in the subject!) to submit comments directly. Comments can also be shared over the phone at 503-378-6600.

Commission Website: You can also use the Commission’s online form to submit comments. Select “UM 2340 - STAFF INVESTIGATION INTO GUIDELINES FOR WFM PLANS” in the docket field. For Industry, select Public Utility Commission. For Company, select PUC.

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