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 RASA staff whitepaper that maps California’s response to new threats to the electric grid, and assesses existing conditions, the CPUC has responded to directives of SB 699 and PU Code 364 to ensure the safety and security of those electric grid assets subject to Commission oversight. Also, in response to a Joint Utility Proposal that seeks to outline new criteria and requirements for identifying “critical” assets and developing threat assessment and mitigation plans, RASA staff has put forward a set of recommendations for additional provisions to the Joint Proposal. A Proposed Decision from the Commission is expected to be made available in the 3rd Quarter of 2018.
Find documents for Phase 1 of this proceeding here
Water and Electric
Utilities Disaster Preparedness and Emergency Response – Coordination with
Local Governments (R.15-06-009, Phase 2) A second phase of the R.15-06-009 rulemaking that responds to AB 1650, and Section 768.6 to the Public Utilities Code is in progress. These directives require, among other things, that water and electric utilities develop disaster and emergency preparedness plans, and seek local government input so as to improve communication with the public, and mitigate the effects of catastrophic events. A scoping memo outlining the priorities to be addressed and prescribing a series of public workshops has been made available.
Find documents for Phase 2 of 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
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
Find the May 2017 Report and recommendations from NorthStar Consulting 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 has reviewed the GRC application to see how the utilities have integrated the RAMP evaluation and comments and has also prepared a report to review the safety/reliability incidents per SB 900:
Final SED report on Sempra RAMP
Final SED SB 900 report on Sempra 2019 GRC
- 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
For information on Rulemaking 15-06-009 (R.15-06-009) Regarding the Policies, Procedures and Rules for the Regulation of Physical Security for the Electric Supply Facilities, click here
Recent Reports and Other Work Products
Recent Documents