Utility Risk Assessment and Safety Advisory

The mission of the Risk Assessment and Safety Advisory (RASA) section is to promote safety by ensuring that the regulated entities integrate risk analysis and risk management practices into their current operations, future planning, and decision-making processes. The section's professional engineers and analysts apply technical and regulatory policy expertise to a wide variety of Commission proceedings and initiatives in order to:
 
  • Identify, analyze, and mitigate present and potential risks in the natural gas & electric systems;
  • Promote risk-informed decision-making in Commission proceedings, particularly General Rate Cases;
  • Suggest improvements in audits and inspections performed by SED;
  • Coordinate with other Commission divisions, State and/or Federal agencies to promote safety in regulated utility operations and research expenditures;
  • Identify and promote new approaches to Risk Assessment and energy policy development through whitepapers, reports and presentations at industry conferences.

 

The Risk Assessment section is specifically tasked with monitoring proceedings and rate case testimony to ensure that relevant Safety concerns are adequately considered:

  • Identify safety concerns and issues that should be considered in new applications, rulemakings or investigations and provide recommendations to Commission decision-makers;
  • Refer to appropriate agencies with overlapping or parallel jurisdiction any Safety concerns that arise in proceedings;
  • Monitor compliance with Commission decisions and Ordering Paragraphs that provide specific directions to SED.

 

Accomplishments in 2017; Goals for 2018

During the past year, the Risk Assessment & Safety Advisory section was able to meet several critical milestones, including finalization of staff evaluation reports for Southern California Edison's General Rate Case and the Sempra Utilities' Risk Assessment Mitigation Phase (RAMP) proceeding, along with completion of a consultant's report in the Pacific Gas & Electric Safety Culture investigation, and staff reports on Physical Security of Electric Infrastructure and a Joint Report with CARB staff for the 2016 Natural Gas Leak Survey.
 
RASA staff has earned a reputation for high quality, timely work products, participatory workshops and technical group facilitation that all contribute to Commission decision making for some of the CPUC's highest profile, complex proceedings.
 
 For 2018, RASA's priority will be to help bring several ongoing proceedings to a successful conclusion, so that the safety-related policies being developed can be fully implemented and incorporated into utility practices.

 

Major Proceedings

Safety Model Assessment Proceeding (A.15-05-002, et al) After nearly a full year in which utilities and intervenors refined proposed methodologies for identifying, ranking and developing mitigations for top operational and safety risks, this S-MAP proceeding is targeted for completion during 2018.  In 2018, staff will be evaluating the utilities' risk assessment models for future use in RAMP and GRC cases, while finalizing policies for accountability reporting, safety performance metrics, and applying risk-informed ratemaking to smaller energy utilities.
 

Find documents for this proceeding here 

 

Gas Leak Abatement OIR (R.15-01-008)  In March 2018, respondent utilities will be filing their first mandatory compliance plans to incorporate the 26 Best Practices for methane leak detection, quantification and elimination, as ordered in D.17-06-015.  RASA staff will review and approve compliance plans and proposed pilots/R&D projects meant to contribute to the state's ambitious GHG reduction target.   Work continues on refining the annual report templates to meet changing informational needs, and working with the California Air Resources Board to revise emission factors to improve the utilities' reporting of emissions.

Find documents for this proceeding here

Investigation into Safety Culture of Pacific Gas and Electric Company and PG&E Corp. (I.15-08-019) With the completion of NorthStar's report and recommendations, the investigation is expected to enter into hearings in 2018.  Testimony from PG&E and parties is expected to help define the potential actions that the Commission may consider, with possible evidentiary hearings.

Find documents for this proceeding here  


  Physical Security of the Electric Supply System (R.15-06-009)

With the publication of a staff whitepaper providing an updated platform of information about the current state of utility physical security, the next step will be consideration of a Joint Utility Proposal for developing compliance and mitigation plans, and for sharing sensitive information with the Commission.   RASA staff has provided an evaluation and additional recommendations for the Joint Proposal, which will help form the record for a decision in this proceeding in 2nd Quarter 2018.  A second phase of the rulemaking, with a focus on emergency planning among energy, water and telecommunications companies with local jurisdictions, will commence in March.  RASA will continue to support the proceeding and has planned workshops to raise relevant issues.

Find documents for this proceeding here  

  

Rulemaking to Develop and Adopt Fire-Threat Maps and Fire-Safety Regulations (R.15-05-006) The adoption of new and revised regulations for high-fire zone areas in December 2017 (D. 17-12-024) and the adoption of the new Fire Map 2 together established a new regulatory structure for preventing utility-involved wildfires.  SED will continue working with Cal FIRE and utilities to further refine maps and assess new policy directions.

Find documents for this proceeding here

Vehicle Electrification (A.17-01-020/-021/-022) The Commission has approved a SED-proposed structure for Safety Plans for new electric vehicle "priority plans", and may extend work on safety to technical working groups.

 Find documents for this proceeding here

 

Other Proceedings

General Rates Cases During 2018 Throughout the year, RASA has worked closely with utilities and intervenors to develop  the framework and substance for new aspects of the Rate Case Plan that are being developed in the S-MAP proceeding (see above) to incorporate a risk-informed approach to General Rate Cases.   Each GRC exhibits a deeper and more refined set of expectations for utilities to show how they are identifying, prioritizing and addressing safety and operational risks.  This effort is unique in utility regulation nationally, and the RASA provides expert analysis and assistance to bring about successful collaboration to resolve what could be highly contentious issues and proceedings.

 

Find SED RASA's recent evaluation reports here.

  • PG&E 2017 General Rate Case (A.15-09-001) The May decision (D. 17-05-013) to mostly adopt the GRC settlement indicated the strength of the new RAMP process for identifying safety risks, as most of PG&E's proposed mitigations were accepted.  In 2018, SED RASA and Energy Division will focus on PG&E's compliance with safety spending accountability reporting and safety metrics reporting. Click here for the March 7, 2016, SED evaluation report.
  • SCE 2018 General Rate Case (A.16-09-001) When a Proposed decision is ready for review, SED RASA will review aspects related to program spending for those operations associated with electric safety, and will recommend accountability reporting provisions. Click here for the Jan. 31, 2017, SED evaluation report.  
  • SDG&E/SoCal Gas Risk Mitigation Assessment Phase (RAMP) (I.16-10-015/016) and SDG&E/SoCal Gas GRC (A.17-10-07/008) This first-of-its-kind proceeding established the utilities' proposed safety risk and mitigation portfolio for the 2019 GRC filed in October 2017.  RASA is reviewing the GRC application to see how the utilities have integrated the RAMP evaluation and comments, and will provide a review of safety/reliability incidents per SB 900.  Click here for SED report.
  • PG&E RAMP (I.17-11-003): SED RASA will review PG&E's risk and safety mitigation proposals made as part of the RAMP.  The evaluation report dated March 30, 2018 has been issued, and a public workshop has been scheduled for April 17, 2018. This evaluation will inform PG&E's next GRC, scheduled to be filed in September 2018.  Click here for the March 30, 2018, SED evaluation report.
  • PG&E's Gas Transmission & Storage (A.17-11-009): In parallel with the PG&E RAMP evaluation, SED RASA will review those safety risks and mitigation plans that are proposed for funding through the GT&S case. Staff is also looking into prospective Safety issues that could arise from the utility's proposal to close or dispose of two natural gas storage facilities.

 

Risk Assessment Documents Archive

Find seminal documents and relevant reports from 2011 - 2017 here  

 

Miscellaneous:

  • In order to help close out two major proceedings (PG&E 2014 GRC and Risk-Informed Ratemaking OIR) RASA staff analyzed over 50 consultants’ report recommendations to determine whether they were being addressed in related proceedings or if further action was required. In November, 2015, this analysis was incorporated into an Assigned Commissioner’s ruling in R.13-11-006 deferring residual matters into proceedings listed above (esp. PG&E 2017 GRC, SMAP and Leak Abatement).

 

 Dedicated Pages

Recent Reports and Other Work Products

·       Risk and Safety Aspects of RAMP Report of San Diego Gas & Electric Company and Southern California Gas Company (I.16-10-015 et al) - March 3, 2017

Staff Report on 2016 Sempra General Rate Case (A.14-11-003 and A.14-11-004) - March 27, 2015

 

 Recent Documents

The Risk Assessment Section recently held the following public workshops:

Fire Map 2 workshop, August 18, 2016: Presentation from SDG&E on a Proposed Workplan for Developing the Map

Fire Map 2 Workshop, August 11, 2016: Status Check on Progress Toward Developing a Workplan for Fire Map 2

 Workshop on SED's Risk Assessment Report on the Pacific Gas & Electric 2017 General Rate Case (GRC) (A.15-09-001), March 25, 2016, presentations:

  1. SED: Overview and electric distribution example
  2. SED: S-MAP and RAMP overview
  3. PG&E: The Risk Informed Budget Allocation (RIBA)
  4. SED: Gas distribution example
  5. SED: Energy supply example
  6. SED: Senate bill 900 -- safety incidents
  7. SED: Next steps

 

 


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