In response to Rulemaking 18-12-005, the “Order Instituting Rulemaking to Examine Electric Utility De-Energization of Power Lines in Dangerous Conditions,” the California Water Association (CWA) submitted comments in advance of the hearing scheduled for February 19, 2019. The intent of the Rulemaking is to examine the California Public Utilities Commission’s (CPUC) rules allowing CPUC-regulated electric utilities to de-energize power lines in case of dangerous conditions that threaten life or property.

As best practices are considered, CWA urged the CPUC to take into account the impact of de-energization events on water utilities and the importance of maintaining water service during periods of emergency to meet fire-protection requirements, water quality, and customer needs. CWA advised the CPUC to focus on advance communication and coordination with all water utilities since disruption in water service can lead to unsanitary conditions and health risks. Additionally, the comments addressed the investments water utilities must make before the 2019 fire season begins on back-up generators, additional water storage tanks, booster pumps, enlarged/additional water pipelines, and other resources, as well as the cost of maintenance, service, and repairs. CWA also commented on the need for waivers by water utilities to use fossil-fuel-burning portable generators that conflict with California’s greenhouse gas emission-reduction goals.

In February, CWA also filed comments on Rulemaking 18-04-019, the “Order Instituting Rulemaking to Consider Strategies and Guidance for Climate Change Adaptation.” The comments suggested that the definition of “adaptation” should be specific to the utility industry and the definition of “climate change adaptation” should be precise and meaningful. The comments also noted that “this proceeding should appropriately distinguish between the concepts of ‘adaptation’ and ‘resilience’ in the context of climate-change planning.”

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