PSPS notification is an industrial-safety issue
A Public Safety Power Shutoff (PSPS) is a preemptive de-energization to reduce wildfire ignition risk. For most customers it is a hardship; for a steel mill or a cement kiln it is a safety event. Molten processes cannot be safely shut down on a few hours' notice, and an uncontrolled outage can damage equipment, endanger workers, and take production offline for weeks.
Across thirty-seven filings, most of them in R.18-12-005, CLECA's position has been consistent: transmission-level customers should receive priority notification at least forty-eight to seventy-two hours before a PSPS event, with the same discrete location information given to Public Safety Partners, and the Commission should not grant utilities "best judgment" discretion to withhold or narrow that notification. In its comments on the proposed decision, CLECA supported a 48-to-72-hour window for public safety partners and critical facilities and 24 to 48 hours for other affected customers — and argued large industrial customers belong in the first group. The stakes are quantified in the record: the October 2019 PSPS event carried an estimated economic impact approaching $2 billion.
Securitization needs specific authorization and real oversight
The other half of the wildfire record is cost recovery. Under AB 1054 — the Wildfire Fund statute, cited in twenty-four CLECA filings — utilities finance wildfire-related costs through securitization bonds recovered from ratepayers over decades. CLECA's position across A.20-04-013, A.20-04-023, A.20-07-008, A.21-01-004, A.21-06-016, and R.19-07-017 is that financing-team oversight for AB 1054 securitization must be robust, and that each new financing transaction must be specifically authorized rather than waved through under existing precedent.
In PG&E's $7.5 billion recovery bond application, A.20-04-023, CLECA's testimony tested the claimed ratepayer benefits against PG&E's roughly $14 billion retail revenue requirement and examined the shareholder contributions to the Customer Credit Trust that were supposed to make ratepayers whole.
How wildfire costs are allocated
Wildfire cost recovery is large and structurally contested. CLECA argues that distribution-based allocation of recovery costs follows cost causation — wildfire risk arises overwhelmingly from the distribution system — and is therefore more equitable than equal-cents-per-kilowatt-hour allocation, the approach TURN typically supports and CLECA typically opposes. Equal-cents allocation departs from cost causation entirely, loading a disproportionate share onto high-load-factor industrial customers whose usage did not cause the distribution-level risk. In R.19-07-017, CLECA flagged that the Wildfire Fund charge would ultimately impose over $10 billion on ratepayers, with the Department of Water Resources authorized to issue up to $10.5 billion in bonds.
Wildfire mitigation spending itself receives the same scrutiny. As far back as the 2019 Wildfire Mitigation Plan reviews, CLECA questioned PG&E's proposed plan costs of up to $2.3 billion, and in the general rate cases it has examined how wildfire mitigation distribution costs — vegetation management, system hardening — are classified and allocated across classes.
Coalition and legislative work
CLECA and EPUC have joined on most of the substantive wildfire briefs, part of a partnership spanning twenty-three joint filings. The advocacy extends to legislation: CLECA opposed SB 254's amendment placing up to $6 billion of fire-risk mitigation costs in utility equity rate base, arguing the affordability consequences for industrial ratepayers had not been examined. The consistent thread is discipline — wildfire mitigation is necessary, but its costs must be specifically justified, equitably allocated, and recovered under just and reasonable rates.