Safety Model Assessment Proceeding (S-MAP)

Background

In May 2015, PG&E, Edison, and SDG&E, and SoCalGas filed Applications for CPUC review of their Safety Model Assessment Proceeding (S-MAP) frameworks and programs to evaluate risks and improve risk management practices of their operations.

In September 2015, the CPUC issued a Ruling stating that the purpose of the S-MAP proceeding is to develop Policies and Guidelines to:  
 

  1. Understand the utilities proposed models to prioritize programs/projects intended to mitigate risks.
  2. Establish standards and requirements for those models.

 

This S-MAP framework will set the foundation for the CPUC’s Risk Assessment Mitigation Phase (RAMP). The RAMP will precede utilities’ General Rate Case (GRC) filings, which will specifically address issues of safety and risk mitigation for each of the four large investor-owned utilities.

As directed in the proceeding to update the Energy Utility Rate Case Plan, the S-MAP is directed to accomplish certain objectives:    

  •  Perform a comprehensive analysis of each utility’s risk-based decision making approach.
     
  •  Compare the different approaches. 
      
  •  Identify common elements across approaches and models. 
      
  •  Assess whether various utility elements can be utilize by other utilities. 

 

The CPUC determined that evidentiary hearings were not needed in the S-MAP proceeding. Instead, parties provided input through Workshops and written comments.

 

CPUC Staff Report

On March 21, 2016, the CPUC issued its staff's Report on "Risk Evaluation Models and Risk-based Decision Frameworks" summarizing stakeholder workshops and making recommendations 2016. The Staff Report noted some of the strengths of utility risk models, but also provided examples of where models were lacking, such as comparing models to other utilities and considering shareholder financials.

The Report acknowledges S-MAP progress, but also issued a number of recommendations and potential improvements, including:

  • Adoption of a specific level of acceptable risk      
      
  • Continuation of improvements     
      
  • Standardization of the utility models     
      
  • Development of a process to find the optimal risk mitigation portfolio

 

Interim Decision

In August 2016, the CPUC issued Interim Decision 16-08-018. In that decision, the CPUC adopted the Joint Intervenor “Multi-Attribute” approach and directed the utilities to take steps toward a more uniform approach to risk management in Phase 2 of the S-MAP proceeding. The CPUC also directed the utilities to test drive the method proposed by the Joint Intervenors.

In December 2016, the CPUC issued a ruling outlining the topics to be resolved for Phase 2 of the S-MAP proceeding. In that ruling the CPUC noted that the questions to be resolved in this phase are:

  • Should the Joint Intervenor Approach be adopted as a uniform approach?
  • Should any of the utilities’ alternative approaches be adopted as a uniform approach?


The CPUC’s ruling also stated that these questions will be resolved via a series of public workshops, working group activities, and meet and confer sessions.

Thus far, the interested parties have participated in multiple workshops in order to learn about the approaches used by the Joint Intervenors as well as the approach proposed by the utilities. These workshops have also served for parties to clarify the specific risks that will be test driven.

 

Proceeding Status 

Subsequent S-MAP applications will be filed every three years.

 

 

ORA Position

ORA supports the S-MAP process and believes that the CPUC should provide clear guidance to utilities and parties to develop better data, prior to the CPUC adopting a particular modeling approach.  

ORA agreed with a number of the recommendations in the CPUC's March 2016 staff Report, such as shareholder financial considerations should be removed from models. ORA also recommends that the CPUC should establish:     

  • A detailed and clear roadmap to guide the S-MAP process should be established.
     
  • A technical working group in order to continue making progress.   

 

See ORA's April 11, 2016 Comments on the CPUC Staff's Report.

See ORA's April 25, 2016 Reply Comments.  

  

See ORA's February 12, 2016 Comments on the January 28, 2016 White Paper on “Intervenor Perspective Regarding an Improved Methodology to Promote Safety and Reliability of Electric and Natural Gas Service in California.”


See ORA's April 25, 2017 Comments on the Safety and Enforcement Division’s Report on the February 15, 2017 Workshop.

 
 

Proceeding Docket

See the CPUC’s S-MAP Proceeding docket.  

You can subscribe at the docket to receive regular updates to the proceeding. 

 

Resources

See the CPUC’s S-MAP Webpage for a record of Workshop activities and presentations.