Energy Safety seeks industry input on implementing SB 254 45‑day revised WMP requirement

Nicole Dunlap, Program Manager in the Electrical Safety Policy Division at the Office of Energy Infrastructure Safety, opened the workshop by summarizing SB 254’s new requirement that electrical corporations submit a revised Wildfire Mitigation Plan to Energy Safety within 45 days of a CPUC general rate case (GRC) decision and that the revised WMP “must align with the revenue authorized in the GRC decision.”

Energy Safety framed the discussion around using the existing petition‑to‑amend process as a starting point and asked utilities which aspects of a 45‑day revised WMP submission would be most and least challenging. Blythe Denton, a utility lead for WMP evaluations at Energy Safety, said the agency is seeking concrete suggestions to inform forthcoming guideline language.

Utility speakers raised three recurring implementation concerns. First, several utilities said GRC decisions often lack the program‑level granularity needed to map authorized dollars to the WMP’s initiative‑ and activity‑level targets. As one participant, Jonathan, said, “the granularity isn't quite there for us to break down the programs or make amendments to the programs,” noting that GRC decisions typically authorize only the first (test) year of a four‑year cycle.

Second, utilities urged clarity on the 45‑day clock and on which event (GRC decision versus WMP approval) should start it. Jay, speaking from a PG&E perspective, told the workshop that a prior change‑order process took “roughly about 45 days to compile and submit,” and suggested aligning the filing window with whichever of the two decisions occurs later to avoid truncating utilities’ preparation time.

Third, multiple participants described operational constraints that can force firms to request lower near‑term targets even when long‑term authorization exists. Kyle Fourie of SCE described lifecycle and permitting limits for commodities such as covered conductor, saying his company sought lower cumulative near‑term targets while still aiming to achieve the full authorized amount later in the GRC cycle.

Energy Safety presented a draft WMP‑to‑GRC crosswalk and asked which columns (for example, targets, annual versus cumulative units, narrative references and page numbers) would be useful versus too granular. Utilities generally supported a mapping column but warned that some GRC forecasts are reported only in large buckets (distribution, transmission, vegetation) and would not yield line‑item parity with WMP initiatives.

Participants recommended several practical steps Energy Safety could adopt in guidelines: allow utilities to submit a crosswalk and redlined narrative; permit early coordination between utilities and Energy Safety on proposed CPUC decisions; consider cumulative rather than strictly annual targets to provide flexibility when a GRC decision arrives mid‑cycle; and clarify whether the 45‑day period should begin on a GRC decision or on an approved WMP when those events are not concurrent.

The workshop concluded with Energy Safety asking stakeholders to submit example crosswalks and written comments; Steve Kerr, supervisor at Energy Safety, reminded attendees that written comments to the WMP guidelines docket were due by 05/14/2026. The agency said the results of these workshops will inform draft guidelines to be published later in the year.