Regulators Miss the Mark on Wildfire Mitigation Plans… Again

Posted on July 11, 2025 by Charlotte Shuff
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On June 26, Oregon’s utility regulators approved wildfire mitigation plans for the state’s for-profit electric utilities. CUB is disappointed to see that once again, regulators have not held utilities responsible for meeting the bare minimum in these plans.

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.

Want even more information? See the dockets for Portland General Electric, Pacific Power, and Idaho Power’s wildfire mitigation plans.

Wildfire Mitigation Planning Still Missing the Mark

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 are tasked with ensuring that utilities create holistic, cost-effective plans each year.

Since then, independent evaluators have consistently found that these utilities are not meeting the requirements set out by the Commission and state law.

Intended Wildfire Mitigation Plan Requirements

Utilities’ wildfire mitigation plans include identifying wildfire risks where they deliver 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.

Required analysis 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 continued to miss the mark.

Regulators Are Not Addressing Advocate and Expert Concerns

Advocates, community members, and legislators have been raising flags since the start of wildfire mitigation plans that utilities have not been meeting the baseline of requirements. Regulators hired an outside expert, though their evaluation was largely not implemented in approving the utilities’ plans.

“We’re disappointed that regulators again approved the utilities’ wildfire mitigation plans, in spite of the concerns raised by advocates and the Independent Evaluator hired by the Commission.” - Jennifer Hill-Hart, CUB Program & Policy Director

Not Enough Community Engagement: For years, advocates have raised concerns about needing meaningful community engagement for its wildfire power shutoff protocol, and that keeps getting kicked down the road.

“Community voices aren’t even in the room. These plans and investments come with significant costs to customers, and that demands a higher standard of rigor, transparency, and equity. If we’re not seriously evaluating the public health impacts of fast trip shutoffs, we’re not truly protecting the communities these plans are meant to serve.” - Alessandra de la Torre, NW Energy Coalition

Failing at the Bare Minimum: The Commission, CUB, and other advocates also heard from legislators and community members that utilities are trimming trees and leaving the vegetation on the ground where it dries out, leaving homeowners concerned that this exacerbates wildfire risk.

“This work is critical, but it must be conducted in collaboration with those who are impacted. I do not believe the PUC currently has the ability to track performance; we need a third-party auditor or some other mechanism to make sure work is performed and completed to the appropriate standard.” - Oregon State Representative. Pam Marsh, in an email to the Public Utility Commission

Rushing Through the Process: The timeline for review of these plans is proving to be too short for thorough review and public comment opportunities. In many cases during this year’s planning, CUB and other advocates only received 2-3 business days to review materials and provide comments. The standard for legal reviews is a minimum of 5 business days.

The Commission is moving toward multiyear wildfire mitigation plan review, which could help address these problems if done correctly. We hope this process will provide more accessibility to the process by allowing more time for review and analysis, and an opportunity for public comment. This may, however, end up requiring a more formal process to fix.

Unchecked Wildfire Mitigation Plans Are Expensive for Customers

While wildfire mitigation costs are necessary, they are a major cost driver in electric utility rates. We continue to see a lack of cost-effectiveness of risk reduction investments and strategies, which is incredibly concerning. CUB will continue to scrutinize very, very closely in cost recovery proceedings.

In Pacific Power’s last request to increase customer bills in 2024, the majority of costs were wildfire-related. Of the $322 million request, $165 million was related to wildfire liability costs, insurance, and mitigation. While much of these costs never made it onto customer bills, regulators still approved about $25 million for wildfire restoration over the next three years.

CUB Joins Advocates in Calling for Change

This year, CUB again joined the NW Energy Coalition and Community Energy Project in responding to wildfire mitigation plans. Together, we called for changes in the process, analysis, and outcomes for this planning process.

Longer Timelines for Review
The timeline for reviewing the Independent Evaluator draft reports (12 business days) and Commission Staff’s summary reports (3 business days) was notably short. Wherever possible, we requested that more meaningful timelines be provided to allow for thorough engagement in these dockets and comment periods. We believe 30 days is a more reasonable timeframe, at a minimum, particularly as we move into multiyear planning.

Standardizing Utility Planning and Reporting
Each utility follows a unique format when submitting its mitigation plans, creating limitations. We support ongoing efforts to streamline the format and requirements of utility plans to enhance consistency, clarity, and efficiency in the planning, evaluation, and reporting processes as soon as possible.

Addressing Community Impacts
While there is a requirement for utilities to work with communities, this has not happened in a meaningful way. We strongly advocate for regulators to direct utilities to work collaboratively with communities to address how their wildfire mitigation strategies affect community services, like hospitals, communications, emergency shelters, and water systems. Regulators should also examine how wildfire planning ties into other utility activities, like meeting clean energy targets and community preparedness, to reduce costs to customers.

Holistic Risk Assessment
The analysis of “risk reduction” should be broadened to include both the risk of utility-started fires and cumulative community risk. Expanded risk includes wildfire smoke, displacement, outages, and economic disruption. Utilities should address whether the overall strategies reduce harm to people, not just the utility infrastructure and its chance of igniting a fire.

Community Partnerships
We would really like to see how the utilities are working with state and local governments and other organizations to share resources where available. This could include wildfire watch cameras, emergency outreach methods and strategies, and more. Collaboration is a means to reduce costs to customers—particularly given that wildfire mitigation strategies are and will continue to be a significant cost driver of rising utility rates.

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