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Erroneous SDG&E/IOU WEBA Assumption – Part I

After comments and protests were received by California's Public Utilities Commission following the filing of an amended A0908020 application by attorneys for San Diego Gas and Electric, Southern California Edison, and Pacific Gas and Electric companies as investor owned utilities (IOUs in CPUC documents), the IOU attorneys filed a joint response to address the concerns in those protests by various agencies, firms and individuals.

In the IOU response, one error made by the attorneys was stating that wildfires were natural disasters, in the same context as “earthquakes and other natural disasters,” and wildfires are therefore subject to the same Catastrophic Event Memorandum Account treatment as those other natural disasters.

In SDG&E employee testimony to CPUC's Consumer Protection and Safety Division regarding SDG&E's role in the 2007 San Diego Wildfire Complex, it was revealed that the managing director of SDG&E's Vegetation Management Program failed to have a tree trimmed according to a VMP computer system notice given by an on-site “pre-inspection” contractor that the tree needed trimming in the next “0-3 months.” Three months later, the untrimmed tree was the ignition point of the Rice Fire. The SDG&E VMP manager further testified that because the contractor did not send a written memo repeating the earlier VMP system input, the SDG&E manager then chose to rely on computer forecasts that declared the tree was not ready for trimming.

In early September this year, a San Bruno high-pressure gas transmission line operated by PG&E catastrophically failed and destroyed about fifty homes in a gas-fed wildfire worthy of national headlines. Among the dead was a CPUC employee investigating earlier reports by PG&E that the pipeline needed replacing, but PG&E failed to take the initiative and make repairs to the inspected defense preparedness activity which was ultimately destroyed with loss of lives.

Neither case is comparable to earthquakes or other natural disasters because in both cases, slow public utility responses to previously-detected problems ultimately led to catastrophic incidents of national significance.

If approved by CPUC, the Wildfire Expense Balancing Account (WEBA) billing authority to IOUs will allow SCE, SDG&E, and PG&E to bill customers for any legal or other costs relating to their uninsured wildfire liabilities. Major objections by CPUC's own CPSD and Division of Ratepayer Advocates include the unlimited liability to consumers in the IOU proposal along with no provisions to exclude costs attributable to negligence, regulatory violations or illegal acts by utilities.


Other WEBA protests on file with CPUC are noted in my previous post Many Opponents to new SDG&E/IOU Proposed WEBA Liability Limit which may be found by using the blog post title in the Reader site search box at the top of this page.

See previous post SDG&E Computer Model Failed to Predict 2007 Rice Wildfire regarding SDG&E's VMP manager testimony, with a link to that testimony before CPUC CPSD. The CPSD investigation was terminated by a settlement as described in previous post On "SDG&E reaches accord in wildfires".

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After comments and protests were received by California's Public Utilities Commission following the filing of an amended A0908020 application by attorneys for San Diego Gas and Electric, Southern California Edison, and Pacific Gas and Electric companies as investor owned utilities (IOUs in CPUC documents), the IOU attorneys filed a joint response to address the concerns in those protests by various agencies, firms and individuals.

In the IOU response, one error made by the attorneys was stating that wildfires were natural disasters, in the same context as “earthquakes and other natural disasters,” and wildfires are therefore subject to the same Catastrophic Event Memorandum Account treatment as those other natural disasters.

In SDG&E employee testimony to CPUC's Consumer Protection and Safety Division regarding SDG&E's role in the 2007 San Diego Wildfire Complex, it was revealed that the managing director of SDG&E's Vegetation Management Program failed to have a tree trimmed according to a VMP computer system notice given by an on-site “pre-inspection” contractor that the tree needed trimming in the next “0-3 months.” Three months later, the untrimmed tree was the ignition point of the Rice Fire. The SDG&E VMP manager further testified that because the contractor did not send a written memo repeating the earlier VMP system input, the SDG&E manager then chose to rely on computer forecasts that declared the tree was not ready for trimming.

In early September this year, a San Bruno high-pressure gas transmission line operated by PG&E catastrophically failed and destroyed about fifty homes in a gas-fed wildfire worthy of national headlines. Among the dead was a CPUC employee investigating earlier reports by PG&E that the pipeline needed replacing, but PG&E failed to take the initiative and make repairs to the inspected defense preparedness activity which was ultimately destroyed with loss of lives.

Neither case is comparable to earthquakes or other natural disasters because in both cases, slow public utility responses to previously-detected problems ultimately led to catastrophic incidents of national significance.

If approved by CPUC, the Wildfire Expense Balancing Account (WEBA) billing authority to IOUs will allow SCE, SDG&E, and PG&E to bill customers for any legal or other costs relating to their uninsured wildfire liabilities. Major objections by CPUC's own CPSD and Division of Ratepayer Advocates include the unlimited liability to consumers in the IOU proposal along with no provisions to exclude costs attributable to negligence, regulatory violations or illegal acts by utilities.


Other WEBA protests on file with CPUC are noted in my previous post Many Opponents to new SDG&E/IOU Proposed WEBA Liability Limit which may be found by using the blog post title in the Reader site search box at the top of this page.

See previous post SDG&E Computer Model Failed to Predict 2007 Rice Wildfire regarding SDG&E's VMP manager testimony, with a link to that testimony before CPUC CPSD. The CPSD investigation was terminated by a settlement as described in previous post On "SDG&E reaches accord in wildfires".

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