Professor Catherine Sandoval submitted comments to the California Public Utilities Commission (CPUC) Wildfire Safety Division examining safety gaps in PG&E’s 2020 Wildfire Mitigation Plan (WMP). Her comments highlight: 1) the lack of sufficiently detailed analysis and explanation in PG&E’s WMP; 2) PG&E’s failure to develop a WMP that considers and addresses layers and interrelationships of fire risk factors; 3) PG&E’s failure to adequately discuss risk factors associated with joint use utility poles and PG&E’s reporting policies; 4) PG&E’s failure to adequately account for the public impacts of its Public Safety Power Shutoffs (PSPS) and WMP and to integrate public comment into its operation; 5) PG&E’s failure to learn lessons from its fires, near misses, and other utilities such as focusing on the types of trees most likely to cause fires.

PG&E’s poor record-keeping, procedures such as its “run to condition” policy for equipment such as insulators including C-hooks implicated in the Camp Fire and the Kincaide Fire, and failure to examine the interrelationship of wildfire risk factors exemplify PG&E’s safety failures and safety culture problem, Professor Sandoval’s comments stated. With COVID-19 anticipated to resurge in Fall 2020 concurrent with high wildfire risk season, she urged the CPUC and PG&E to add conditions to PG&E’s WMP to limit PSPS. Professor Sandoval’s comments propose several conditions including enhancing opportunity for public input into PG&E’s operation, planning, and complaint process to improve PG&E’s WMP and protect public safety.

Professor Catherine Sandoval teaches and conducts research on Energy Law, Communications Law, Contracts, and Antitrust Law at Santa Clara University School of Law. She served a six-year term as a Commissioner of the California Public Utilities Commission from January 2011-January 2017.

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