THE CPUC HAS THE MEANS TO SUPPORT OR OPPOSE PG&E’S RATE INCREASES BY THEIR VOTE ON TWO COMPETING PLANS.

Below is what PG&E is now asking for and the two competing CPUC responses under consideration.

PG&E’s latest wish list: $15.4 B in 2023, a 26% increase over its budget of $12.2 B in 2022. This rate hike is primarily to pay for undergrounding 2,000 miles of overhead wires. At the current rate of 70 miles undergrounding/year, the job will take 28.6 years (circa 2052).

CPUC’s PD (Proposed Decision) plan balances the high cost ($3.3 million/mile) and slow process of undergrounding with cost effective covered wires and flame resistant metal poles. (See my previous change.org petition, “Stop PG&E’s Four Years of Rate Hikes” with updates on the  pros/cons of undergrounding and covered wires.) Specifically, PD calls for 200 miles of undergrounding along with 1800 miles of covered wires at a combined cost of $13.8 B, a 13% rate increase. 200 miles of undergrounding would complete within three years.

CPUC’s APD (Alternative Proposed Decision) originally called for undergrounding 983 miles of overhead wires and 1,027 miles of covered wires at a cost of $13.3 B, a 9% rate hike. However, two days before the November 2 CPUC meeting to vote on these two plans, the following update was inserted within a CPUC document under the heading, “frequently asked questions”.

“UPDATE: On Oct. 31, following a public comment period, the APD was modified to approve 1,230 miles of undergrounding -- up from 973 miles -- as well as 778 miles of covered conductor. This change increases the total hardened miles to 2,008. This increase in undergrounding miles boosts forecasted risk reduction, with an added cost of $454 million, but it’s still less expensive than PG&E’s proposal and is forecast to reduce more risk than PG&E’s proposal, while also providing PG&E with an opportunity to achieve economies of scale. The 1,230 approved undergrounding miles represent an historic opportunity for PG&E to invest in safer, reliable  improvements; the revised total nearly equals the number of miles PG&E requested to complete through the end of 2025” (https://www.cpuc.ca.gov/-/media/cpuc-website/industries-and-topics/documents/pge/grcs/updated_  ).

The CPUC and rate payers should oppose the APD because it is based on two fantasies. Fantasy one: the APD assumes the cost of undergrounding will decrease over time from the current $3.3 M/mile to an aspirational $1.8 M/mile. ($454M divided by the additional 257 miles = $1.8 M/mile). 
Fantasy two: the APD assumes it is possible to underground 1,230 miles of overhead wires in the four years of the proposed rate increases. But at the current speed of undergrounding, it would take 17.6 years to complete those 1,230 miles. 

Furthermore, the modified APD, with its 1,230 miles of undergrounding has yet to provide the public with the percent increase in rates and the additional billions of dollars to be raised from PG&E customers. This plan should be rejected for being half baked.

Note, the APD does not provide any evidence it is superior to the PD in mitigating wildfire risks. So there are no reasons to reject the PD, which is cost effective in undergrounding fewer miles and covering more miles of power lines. Furthermore, the PD goal of undergrounding 200 miles of overhead wires can be completed within three years so it is a reasonable and reality based goal

We should additionally push the CPUC to only approve rate increases for undergrounding one year in advance, based on the cost and speed of undergrounding the previous year. Rate payers should not have to spend today’s pay check to pay PG&E for undergrounding work projected years into the future. Evidence based payments will also simplify CPUC’s job of regulating; PG&E has a practice of hoarding monies advanced or not spending funds for their stated purpose. Furthermore, the public would be paying each year’s rate hikes based on the reality of current costs and accomplishments, not on aspirational, unrealistic goals and promises.

Discussion and voting on these two plans were canceled for the November 2 meeting. The next CPUC voting meeting is scheduled for November 16 in El Centro. Please make your voices heard by then, not only by signing this petition but also by commenting directly to the CPUC. Here’s how to comment remotely: 

In addition to or instead of speaking, you can also send comments to:     California Public Utilities Commission
Public Advisor's Office
505 Van Ness Avenue
San Francisco, CA 94102California Public Utilities Commission

Some advice: I listened to the first 25 phone comments at the November 2 meeting; about half of those comments were too soft to hear or not forceful enough to make an impression. So be sure to speak clearly, confidently and loudly enough to be heard.

Thank you,
Mary M Zhu, rate payer