To: Sonoma County Board of Supervisors
Department or Agency Name(s): County Counsel and County Administrator’s Office
Staff Name and Phone Number: Petra Bruggisser, ext. 3744
Vote Requirement: Informational Only
Supervisorial District(s): All
Title:
Title
Update on Sonoma County’s Advocacy at the California Public Utilities Commission and Response to Electric Infrastructure and Power Reliability Needs
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Recommended Action:
Recommended action
Receive an informational update on Sonoma County’s advocacy efforts at the California Public Utilities Commissions, and collaboration with local stakeholders on a response to electric infrastructure and power reliability needs. (Informational Only)
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Executive Summary:
In May 2018, the Board identified a county-wide Climate Change Framework to reduce greenhouse gas emissions, promote a sustainable, climate-resilient economy, and built resources to withstand the impacts of climate change.
In December 2018, the Board approved the Recovery & Resiliency Framework, including a comprehensive list of potential activities and actions that, if implemented, would help the County and community recover and become more resilient to future disasters. Staff provided the Board and community with regular updates on disaster recovery efforts throughout 2019, and presented the 2019 Recovery and Resiliency Framework Implementation Report Annual Report to the Board on January 14, 2020.
In line with the County’s identified priorities, the Board also authorized County participation in proceedings at the California Public Utilities Commission (CPUC) involving wildfire mitigation and related matters, as well as the retention of legal counsel Megan Somogyi at Goodin, MacBride, Squeri & Day, LLP to provide specialized legal advice and representation in up to a not-to-exceed amount of $150,000, as well as $50,000 funding for County Counsel to oversee and coordinate this work with County staff and partner counties.
This report provides an informational update to the Board on two actions the County is taking to further the Board’s goals identified in the Climate Change and Recovery & Resiliency Frameworks: (1) advocacy at the CPUC on issues related to wildfire mitigation, infrastructure hardening, disaster preparedness, and de-energization events, and (2) collaboration with local stakeholders to respond to electric infrastructure and power reliability needs.
Discussion:
CPUC Proceedings
As part of the County’s ongoing efforts to advocate for the needs of our community to be better prepared and more resilient to disasters, the County has initiated participation in a number of regulatory proceedings at the CPUC. To maximize impact, the County has partnered with other local governments and formed a strong coalition of counties and cities to voice concerns and propose solutions on issues related to wildfire mitigation, infrastructure hardening, disaster preparedness, and de-energization events. For example, the largest coalition now consists of the Counties of Sonoma, Napa, Mendocino, Nevada, Marin, Santa Barbara, Solano, Kern, and the City of Santa Rosa in the de-energization proceeding to advocate jointly for local government and community needs during power shut-off events.
The County, as part of the local government coalition, is represented at the CPUC through legal counsel Megan Somogyi. The local governments have pooled their resources together to share the cost for legal services on matters of joint interest.
A comprehensive list of the County’s filings and related activities is outlined in Attachment A.
The County is currently participating in the following proceedings:
• Rulemaking 18-10-1007 (SB 901 - Wildfire Mitigation Plan)
This rulemaking was opened in 2018 in response to Senate Bill 901, which requires investor-owned electric utilities to submit annual wildfire mitigation plans. It will provide guidance on the form and content of plans, provide a venue for review of plans, and develop and refine the content of and process for review and implementation of future wildfire mitigation plans.
• Rulemaking 18-12-005 (De-Energization)
This rulemaking was opened in December 2018 to specifically address de-energization issues. It examines best practices, notification protocols, utility coordination with state and local first responders, minimizing impact on vulnerable populations, reporting requirements, and other issues related to de-energization of utility power lines.
• Rulemaking 17-05-010 (Rule 20A Undergrounding)
This proceeding was initiated in May 2017 to consider whether changes are warranted to “Electric Rule 20.A,” which governs the system of credits that PG&E must grant to public entities toward the cost of undergrounding electrical utility lines.
• Application 18-12-009 (PG&E 2020 General Rate Case)
PG&E filed its 2020 general rate case in December 2018, seeking to increase utility rates beginning in 2020 to cover costs that PG&E estimates will be incurred from now through 2022 for a proposed Community Wildfire Safety Program.
• Rulemaking 19-01-006 (Financial Stress Test)
This proceeding was opened in January 2019 to implement Public Utilities Code § 451.2(b), which is the provision of SB 901 that was designed to cap utility shareholder liability for wildfire-related costs, also referred to as the “stress test.”
• Investigation 19-06-015 (2017 Sonoma County wildfires)
In June 2019, the CPUC issued an Order Instituting Investigation (OII) to determine whether PG&E violated any laws, rules or requirements pertaining to the maintenance and operation of its electric facilities that were involved in igniting fires in its service territory in 2017.
• Investigation 19-11-013 (2019 PSPS Events)
Following the widespread power shutdowns in the Fall of 2019, the CPUC opened a formal Investigation in November 2019 to investigate the 2019 PSPS events conducted by all three large utilities, including how the utilities communicated and coordinated with local governments, how effective that communication and coordination was, and the impacts of ineffective notification and communication.
• Investigation 19-09-016 (PG&E’s Chapter 11 Bankruptcy)
This Investigation was opened in September 2019 to consider ratemaking and other implications of PG&E’s proposed reorganization as the utility emerges from Chapter 11 bankruptcy.
• Rulemaking 19-09-009 (Microgrids and Resiliency Strategies)
The CPUC opened this Rulemaking in September 2019 to explore ways to optimize the existing resiliency programs, revamp the utilities’ interconnection tariffs, and provide near-term mitigation for PSPS events.
The County, as part of the local government coalition, has met with Commissioners and staff, participated in workshops, and submitted more than a dozen of filings in these proceedings requesting a wide variety of quantifiable measures to ensure the effectiveness of PG&E’s proposed steps and action items to
• reduce the risks of wildfires,
• reduce the impacts of de-energization events,
• improve communication protocols to ensure public safety priorities,
• restructure existing underground criteria, and
• enhance the health, safety and well-being of our community, vulnerable populations, medical service providers and first responders
The local government filings, critique and proposals have garnered much attention, both at the regulatory and legislative level state-wide. For example, the CPUC has adopted many of our recommendations in the de-energization and wildfire mitigation plan proceedings, which now require PG&E to
• partner with local governments and first responders to ensure effective notice and improve communications before, during and after de-energization events,
• work with local governments to improve the utility’s medical baseline registry and to develop ways to improve outreach to AFN populations,
• conduct better outreach and education for tenants of master-metered properties, such as mobile home parks,
• share its internal situational awareness information (e.g., weather and fire modeling data and metrics) with local governments and first responders, measure its effectiveness and assess future improvement possibilities,
• coordinate locations of Community Resource Centers with local governments,
• participate in increased table-top exercises with local public safety partners, and to continue readiness preparations throughout the year,
• ensure that PSPS communications and educational material is provided in California’s threshold languages,
• consider ingress/egress constraints when undertaking system hardening activities (i.e., should power lines be underground),
• coordinate closely with local governments to develop a successful wildfire mitigation program, and
• provide local governments with direct communication from PG&E’s Wildfire Safety Operations Center.
In addition, the County has been working with its partners, including the Rural County Representatives of California, at the legislative level to inform pending legislation about local government and community needs on these issues, especially de-energization related matters. The County will continue its advocacy efforts on all fronts to help implement the Board’s priorities to move the County forward into a more resilient future.
These efforts now also include a collaboration with other local governments and organizations to ask the CPUC for an emergency or interim order creating special rules for PSPS events during the COVID-19 outbreak.
Microgrid Rulemaking & Collaboration on Electric Infrastructure and Power Reliability Needs
In addition to the County’s disaster and emergency resiliency goals, the Board also identified a county-wide Climate Change Framework in May 2018, to reduce greenhouse gas emissions, promote a sustainable, climate-resilient economy, and built resources to withstand the impacts of climate change. In line with all of these goals, the County recently joined a CPUC proceeding on microgrids and resiliency strategies. The County is recommending that the CPUC adopt the following measures to facilitate local resiliency planning, including
• enhanced information sharing regarding PG&E’s local distribution and transmission network, and planned infrastructure upgrade projects,
• development of a resiliency project engagement guide to make the process of developing microgrids less opaque,
• creation of a dedicated team for local government projects, to help with advance planning information, prioritizing projects to maximize resources, and
• creation of a separate web portal for local governments to allow sharing of project-related information, circuit maps, PSPS information, etc.
To supplement our advocacy at the regulatory level, the County has also taken steps to initiate collaboration among local stakeholders to coordinate a response to electric infrastructure and power reliability needs in a sustainable way. Sonoma County recently participated in a meeting hosted by Sonoma Clean Power, which was attended by a wide variety of stakeholders, including representatives from local municipalities, emergency departments, water districts, air quality boards, and rural counties. A number of action-items were identified for near- and longer-term collaboration in areas of data access, funding, transmission outages, and microgrids, including the following:
• Identify regional priority backup power needs for 2020 if PG&E is unable to fulfill its September 2020 installation goals for all locations in the Distributed Generation-Enabled Microgrid (DGEMS) program,
• Review local transmission system to improve advocacy relating to DGEMS, identify critical loads, and emphasize public safety needs to repair/harden necessary transmission and distribution lines,
• Advocate at CPUC to design permanent solution for PG&E’s DGEMS program, seek broad political support for renewable districts that backup critical loads, require PG&E to take care of immediate backup power needs for 2020 (with proper air district permits),
• Explore local biomass potential to reduce the significant cost and impacts of out-of-county trucking, and to supply a substation-level baseload resource to support power year-round and through PSPS events,
• Explore how to get HEPA air purifiers for schools and other places of refuge, and
• Plan for two-factor disasters, such as PSPS+fire or PSPS+coronavirus.
Staff will provide period updates to the Board on the County’s continued efforts to collaborate with County partners and local stakeholders to develop solutions to increase the health and resilience of social, natural, and built resources to withstand the impacts of climate change, local disaster and emergencies.
Staff will bring a recommended contract renewal to your Board soon for the legal services agreement with the County’s CPUC counsel Megan Somogyi.
This item provides an informational update only. No Board action is requested.
Prior Board Actions:
May 8, 2018: Board adopted the Climate Change Action Resolution to support a county-wide framework for reducing greenhouse gas emissions and to pursue local actions that support the identified goals therein
December 11, 2018: Board authorized County participation in California Public Utilities Commission wildfire related proceedings
February 26, 2019: Board authorized funding for outside counsel and County Counsel to provide legal advice and representation in CPUC proceedings up to a not-to-exceed amount of $150,000, as well as $50,000 funding for County Counsel to oversee and coordinate this work with County staff and partner counties
April 2, 2019: Board received an informational update on the County’s participation in CPUC proceedings
Fiscal Summary
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Narrative Explanation of Staffing Impacts (If Required):
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Attachments:
Attachment A: Summary of CPUC Proceedings
Related Items “On File” with the Clerk of the Board:
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