wildlfire conferees ltr 7 12 2018

CLECA California Large Energy Consumers Association July 12, 2018 The Honorable Bill Dodd Co-Chair, Conference Committ...

0 downloads 14 Views 279KB Size
CLECA California Large Energy Consumers Association

July 12, 2018

The Honorable Bill Dodd Co-Chair, Conference Committee on Wildfire Preparedness and Response California State Senate California State Capitol, Room 5064 Sacramento, CA 95814 The Honorable Chris Holden Co-Chair, Conference Committee on Wildfire Preparedness and Response California State Assembly California State Capitol, Room 5132 Sacramento, CA 95814 RE: Ratepayer Issues for Conference Committee on Wildfire Preparedness and Response Dear Co-Chairs Dodd and Holden: This communication is on behalf of major California electric utility ratepayers interested in the work of the Conference Committee on Wildfire Preparedness and Response. As you begin the conference committee process considering and proposing changes that will affect the generation, transmission and distribution of electricity in California, we strenuously encourage and request that you focus on the potential impact to ratepayers. This focus requires inclusion of representatives of our coalition in the conference committee proceedings both as participants in hearings as well as substantive discussions regarding the ultimate work product of this committee.

Ratepayer Issues for Conference Committee on Wildfire Preparedness and Response July 12, 2018 Page 2

For ratepayers across all classes electric costs already represent a significant burden on the finances. From agricultural to commercial and industrial to residential ratepayers, California electric rates represent some of the highest in the nation as various policies and other decisions increase system costs that all ratepayers share. Your work as members of the Conference Committee on Wildfire Preparedness and Response (Conference Committee) will set the stage for how we handle future major incidents and may alleviate or exacerbate ratepayer burdens. In the announcement of the Conference Committee’s formation, you were charged with fulfilling several foundational principles: • Strengthen fire prevention activities such as vegetation removal, infrastructure maintenance, utility company inspections and temporary shut off of power during extreme weather; • Continue to ensure that those who cause wildfires are held accountable for damages associated with them; • Appropriately determine responsibility for a wildfire; • Ensure fair allocation of wildfire prevention and response costs in a manner that protects ratepayers; and • Require utilities to annually submit to the state more expansive and detailed wildfire and emergency preparedness plans. Particularly because some of these specific principles involve activities, such as removal of dead trees, undergrounding of power lines, hardening of utility infrastructure and other measures designed to reduce the number and destruction caused by future utility-caused wildfires, ratepayers are justifiably concerned about becoming the “insurer of last resort” for investor-owned utilities (IOUs). Additionally, consideration of proposals that seek to alleviate or mitigate the immediate financial impact of IOU business decisions must be considered in light of the impact to ratepayers. We urge you to follow the following principles in your deliberations: • • • •

Under no circumstance should ratepayers be expected to bail out utilities that caused fires due to negligence or failure to operate their facilities in a safe manner. Do not change existing law to weaken ratepayer protections against being charged for utility mistakes. Any proposals to modify CPUC review of utility safety plans must work within the risk assessment and prioritization framework and due process safeguards built into the CPUC’s current RAMP and GRC process, rather than circumventing it. Any solution that includes securitization of utility wildfire liabilities must look to non-ratepayer sources, as ratepayers are already expected to pay for future wildfire mitigation.

We also strongly encourage the Conference Committee to evaluate the use of a fault-based standard in place of the existing strict liability standard for Inverse Condemnation.

Ratepayer Issues for Conference Committee on Wildfire Preparedness and Response July 12, 2018 Page 3

In order to meet the charge given the Conference Committee, and because the conference report is not subject to amendment, we respectfully request that you include the representatives of ratepayer interests signed below early in your discussions and development of proposals. Sincerely, California Manufacturers & Technology Association AARP California African American Farmers of California Agricultural Energy Consumers Association Asian Pacific Environmental Network California Agricultural Aircraft Association California Citrus Mutual California Cotton Ginners and Growers Association California Farm Bureau Federation California Fresh Fruit Association California Large Energy Consumers Association California League of Food Producers Far West Equipment Dealers Association Nisei Farmers League The Utility Reform Network Western Agricultural Processors Association Western States Petroleum Association

cc: Wildfire Preparedness and Response Conferees – Senator Anthony Canella Senator Ben Hueso Senator Hannah-Beth Jackson Senator Jeff Stone Assembly Member Brian Dahle Assembly Member Chad Mayes Assembly Member Eloise Gómez Reyes Assembly Member Jim Wood Senate President pro Tempore Toni Atkins Assembly Speaker Anthony Rendon Catalina Hayes-Bautista, Office of Governor Edmund G. Brown, Jr.