HomeMy WebLinkAboutAGENDA REPORT 2022 0504 CCSA REG ITEM 09BCITY OF MOORPARK, CALIFORNIA
City Council Meeting
of May 4, 2022
ACTION APPROVED STAFF
RECOMMENDATION. (ROLL CALL
VOTE: 3-0, COUNCILMEMBERS
ENEGREN AND POLLOCK
ABSENT).
BY A. Hurtado.
B. Update on Public Safety Power Shutoff Advocacy with Ca. Public Utilities
Commission and Recommendation on Continued Advocacy Efforts. Staff
Recommendation: Scale back participation and continue to monitor filings and
Utility Presentation before the CPUC on behalf of the City.(Megan Somogyi,
Downey Brand LLP, Special Counsel for City of Moorpark)
Item: 9.B.
City of Moorpark’s
CPUC Advocacy
Megan Somogyi, Partner
May 4, 2022
Item: 9.B.
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Moorpark’s CPUC Advocacy
Moorpark became a party to the CPUC’s PSPS Rulemaking in March
2021
Joined a coalition of nine local governments in SCE’s and PG&E’s
territories
Moorpark, as part of the coalition, has provided recommendations
and input on the CPUC’s PSPS regulations and SCE’s PSPS operations
The CPUC has adopted the majority of the coalition’s
recommendations
Moorpark has provided input to the CPUC on SCE’s PSPS events
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SCE’s 2021 PSPS Events
Moorpark filed responses with the CPUC to the SCE PSPS events that impacted
the City, including the November 24 Thanksgiving event.
Moorpark raised the following issues and concerns:
SCE’s repeated failures to provide early—or any—notification before power
shutoff
SCE’s apparent failure to include historical data on frequently de-energized
circuits in its PSPS modeling
SCE’s failure to provide accurate and timely event information to City
emergency management
SCE’s failure to provide accurate or timely information regarding re-
energization
The hardship imposed on the City and its residents by PSPS events 21
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PSPS Regulations: CPUC Rulemaking 18-12-005
Moorpark and the coalition advocated for the following changes to the PSPS framework:
The CPUC must conduct meaningful review of whether the utility’s decision to shut
off the power was reasonable
SCE must improve its resource offerings, such as food replacement and hotel
accommodations, for impacted customers; education and notification alone are not
sufficient
SCE must ensure that backup batteries provided to medically vulnerable customers are
sufficient to meet the customer’s needs
SCE must ensure its Community Resource Centers are designed to meet impacted
customers’ needs
SCE must coordinate closely with local governments when siting and resourcing CRCs
SCE must ensure that PSPS event information is timely, accurate, and consistent
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What’s Next for PSPS?
The CPUC’s PSPS Rulemaking (R.18-12-005) remains open, which could allow for
additional changes to the PSPS regulations in the future.
The CPUC will not make changes to the PSPS regulations in 2022, however.
The CPUC originally considered formally consolidating the existing PSPS regulations,
which are spread across at least five orders, into a single document. In early 2022, the
CPUC indicated instead that it would issue an informal index, or guide, to the PSPS
regulations but would not consolidate them.
PSPS-related regulatory activity will continue:
–SCE, PG&E, and SDG&E recently issued a proposed list of all the agencies that receive priority (48-72
hours) notice of PSPS events and invited stakeholder input by June 1.
–SCE will continue to file its annual Wildfire Mitigation Plan with the Office of Energy Infrastructure
Safety.
–SCE will continue to conduct PSPS events and file post-event reports, on which parties can comment.
–SCE will continue to have quarterly and annual PSPS-related compliance filings.23
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Options for Future CPUC Advocacy
Recommended: Scale back the coalition and CPUC
participation to monitoring utility filings and activity,
with the option to submit our own filings as needed.
Disband the coalition, but keep Downey Brand “on
call” for the City on an as-needed basis.
Stop all participation in CPUC matters.
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San Francisco
455 Market Street | Suite 1500
San Francisco, CA 94105
tel: 415.848.4800
www.downeybrand.com
Thank You
Megan Somogyi
(415)848-8429
msomogyi@downeybrand.com
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