CPUC Fine-tunes Approach to Utility Climate Adaptation Program
Stakeholders Ask Commission to Avoid ‘Paralysis by Analysis’

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The California Public Utilities Commission is looking for ways to improve a utility-oriented climate adaptation program designed to help protect the most vulnerable people and lands in the Golden State.

The California Public Utilities Commission is looking for ways to improve a utility-oriented climate adaptation program designed to help protect the most vulnerable people and lands in the Golden State.

At an Aug. 27 workshop, CPUC staff and representatives from investor-owned utilities (IOUs), tribes and other stakeholder groups unveiled possible ways to improve IOUs’ Climate Adaptation Vulnerability Assessments (CAVAs). A CAVA identifies vulnerabilities and risks to IOU assets, operations and services stemming from the effects of climate change.

“Robust climate adaptation planning in a time of worsening climate impacts is a prudent next step to ensure the safety and reliability” of IOUs, the CPUC said in the “Climate Adaption” section of its website.

“This [workshop] is really critical work to ensure that equity is part of the [climate change reduction] solution,” Audrey Neuman, energy adviser to CPUC Commissioner Darcie Houck, said at the workshop.

In a CAVA, an IOU must describe possible ways to confront vulnerabilities to itself and its infrastructure. These options could be used to determine investments in climate adaptation work, the CPUC said.

The CAVA is part of the CPUC’s 2018 Order Instituting Rulemaking (OIR) 18-04-019 to consider strategies and guidance for climate change adaptation. IOUs must submit a CAVA to the CPUC every four years.

CPUC staff said they are currently working with stakeholders to help create “quantitative equity metrics,” such as a matrix that shows the adaptivity potential of vulnerable communities and infrastructure. Other possible metrics include quantifying a community’s access to resources during an outage; the cost burden of an outage; the impacts of outages on different populations; the impacts of high-frequency outages; and the impacts of long-duration outages.

At the workshop, some stakeholders said too much analysis would be harmful to people who need support now.

“We don’t need to tie together all of the various equity processes … in order to get to some actionable plan that is good enough now,” one stakeholder said. “There are things we know we need to do now, and we don’t have to wait for paralysis by analysis to get to the optimal answer.”

Pacific Gas and Electric representatives said the utility is currently defining which communities need the most attention. Part of the challenge, the representatives said, is that the definition of disadvantaged and vulnerable communities (DVCs) is not specific, which makes it difficult to determine the most vulnerable groups.

“We are looking to target the most vulnerable communities because the DVC definition is quite broad,” said Nathan Bengtsson, PG&E interim director of climate resilience and adaptation. “When we went to [research groups] with the [DVC] definition, almost every group said, ‘Wow, that doesn’t represent a lot of us. You’re leaving out farmworkers, you’re leaving out people with disabilities.”

In 2024, the CPUC required a CAVA to implement a model called the “global warming levels approach,” which seeks to draw a link between regional climate change and specific levels of global warming. This approach is meant to help reduce temperature bias in the CAVA program and “largely separates climate projections from underlying socioeconomic scenario assumptions,” as the climate generally acts uniformly at different global warming levels “regardless of how society gets itself there,” CPUC staff said in OIR 18-04-019.

CaliforniaCalifornia Public Utilities Commission (CPUC)Public Policy

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