[{"_1":2,"_99":-5,"_100":-5},"loaderData",{"_3":4,"_26":27},"root",{"_5":6,"_17":10,"_18":19,"_20":21,"_22":10,"_23":-5,"_24":-5,"_25":10},"user",{"_7":8,"_9":10,"_11":10,"_12":-5,"_13":-5,"_14":15,"_16":-5},"roles",[],"isAuthenticated",false,"isPremium","planName","subscriptionStatus","featureFlags",{},"insightsBudget","isDevelopmentHost","userPreferences",{},"recaptchaSiteKey","6LcvOJcUAAAAAHsB-gPGfGktcRlKpH7OTIU_dMTD","isImpersonating","impersonation","affiliateStatus","isFreedomPortal","routes/v2/article/layout",{"_28":29,"_30":31},"notFound",true,"relatedArticles",[32,75,87],{"_33":34,"_35":36,"_37":38,"_39":40,"_41":42,"_43":44,"_45":46,"_47":48,"_49":50,"_51":52,"_53":54,"_55":56,"_57":58,"_59":60,"_61":62,"_63":64,"_65":66,"_67":68,"_69":70,"_71":72,"_73":56,"_74":56},"mediaId",6104085,"mediaKeyId","2792559-8464b3b1777b5af4db9e5fbfa1957113","parentId",2792559,"title","Division of Public Utilities says Rocky Mountain Power’s revised 2023 wildfire plan fails to show costs balance benefits","audioSeconds",507,"startMs",595000,"endMs",1102000,"viewUrl","/Search/View?dp=1&key=2792559-8464b3b1777b5af4db9e5fbfa1957113&start=595&end=1102","thumbnailUrl","https://assets.pipeline.soar.com/2792559-8464b3b1777b5af4db9e5fbfa1957113/thumbnail_595000.jpg","articleUrl","/articles/6104085/Utah/Division-of-Public-Utilities-says-Rocky-Mountain-Powers-revised-2023-wildfire-plan-fails-to-show-costs-balance-benefits","mediaUrl","https://secure.pipeline.soar.com/6104085-ed1b6e4fed76bcf14debba3be8e09699/orig.mp4?Expires=1770973378&Signature=MS37SfgVQwT3XNLWpBrwQFtIkwYQjxiGUID8DMmpBBPbe95xGRNhSMXwWPuXmPXhWHbYKo~BYmusfcfNb~4jeTVXvgOOpMNj2ksvHjEzVC8iN9Sms~SxCRRB4QBHfcnatkOmGb-QqWF~NwqFEwkBAazU4vYTcROVbRNzc2uEmLd3-FINC6tkbxgdVKFt6xZNJnOvPLgfn7rYnwCOKY593C1q~~immQX8Xex3oJ3qD8QZg3A5ljTjpIb06w2fDbZDkr2~5zv9cOpSW47XC12u-JpJPSGrKKWz0KrkxuCYdSvw4GlI4c4REmRmFZ5KJUiC2Eud1q-iUMIgn33HQfFhjg__&Key-Pair-Id=KUT5TJCACFTXG","author","","date","2025-03-26T23:30:31Z","article","Division of Public Utilities utility analyst Jonathan Lee told the Utah Public Service Commission he recommends rejecting Rocky Mountain Power’s revised 2023 Wildland Fire Protection Plan because it fails to show the required balance between mitigation costs and the reduction in wildfire risk.

Lee said the company’s revised plan asks for “$371,700,000 for wildfire-related capital expenditure and an additional $74,600,000 for wildfire-related operation and maintenance expense for the 2023–2025 period,” figures far above what the commission approved in 2020, and that the plan “does not properly balance cost with potential benefits.”

Why it matters: Utah law requires the commission to approve a wildland fire protection plan only if the evidence shows the plan is reasonable, in the public interest and “appropriately balances the cost of implementing the plan with the risk of a potential wildland fire.” Lee told commissioners the revised plan provides more descriptive material but does not give the commission the analysis it needs to judge whether the spending is just and reasonable for Utah ratepayers.

Details: Lee recounted that Rocky Mountain Power spent well above the amounts contemplated by the 2020 plan, reporting that RMP’s actual wildfire capital spending was many times the approved 2020 levels in 2022–2024. He told the commission the Division recommends the revised plan be rejected and that, in the meantime, the commission set test-year 2025 allowable wildfire capital at $40,500,000 and O&M at $4,800,000 — figures the Division considers more reasonable and tied to the previously approved plan.

Lee also urged that the commission deny RMP’s request to recover through Schedule 97 (the wildfire mitigation balancing account, or WBA) approximately $21,000,000 of deferred costs from 2021–2023. He told the commission that some of those deferred amounts include spending not authorized by the 2020 plan and that the Division sees limited evidence that the company’s accounting properly distinguishes incremental wildfire costs from amounts already reflected in base rates.

Lee’s testimony acknowledged climate-driven wildfire risk is rising, but he said that makes it all the more important that the commission be able to evaluate whether the scale and pace of mitigation spending are cost-effective for Utah ratepayers. \"Without a meaningful cost-benefit analysis provided by the company, it’s problematic for the commission to determine if the WMP actually balanced risk with potential costs,\" Lee said on the record.

What the Division asked the commission to do: reject the revised 2023 WMP, limit the 2025 test-year capital and O&M amounts to the Division’s recommended levels, and deny recovery now of the roughly $21 million in deferred costs. The Division said those amounts could be revisited if the company returns with an approved plan that demonstrates the required balancing of costs and risks.

Context & next steps: The Division’s position puts it at odds with Rocky Mountain Power’s revised filings but aligned with Office of Consumer Services witnesses who also urged stronger, quantified cost–risk evidence before full recovery. The PSC will weigh the record — including testimony from the Division, OCS, the independent evaluator and other parties — before issuing its decision.

Ending: Lee’s recommendations leave the commission with a procedural question: accept the revised plan and allow wider recovery now, or require RMP to provide a clearer, quantified cost-versus-risk justification before allowing the higher spending levels to be charged to Utah ratepayers.","mediaType","Video","parentTitle","Phase III Hearing on Fire Plan Docket Issues (24-035-04, RMP's Rate Case)","oneSentenceSummary","Division of Public Utilities utility analyst Jonathan Lee told the Utah Public Service Commission he recommends rejecting Rocky Mountain Power’s revised 2023 Wildland Fire Protection Plan because it fails to show the required balance between mitigation costs and the reduction in wildfire risk.","taxTitle","Utah Public Service Commission, Utah Subcommittees, Commissions and Task Forces, Utah Legislative Branch, Utah","taxId",72399,"location","Utah","headline","shortSummary",{"_33":76,"_35":36,"_37":38,"_39":77,"_41":78,"_43":79,"_45":80,"_47":81,"_49":82,"_51":83,"_53":84,"_55":56,"_57":58,"_59":85,"_61":62,"_63":64,"_65":86,"_67":68,"_69":70,"_71":72,"_73":56,"_74":56},6104074,"Independent evaluator says RMP risk approach broadly follows standards; FFSL says revised plan complies with statute",1478,2668000,4146000,"/Search/View?dp=1&key=2792559-8464b3b1777b5af4db9e5fbfa1957113&start=2668&end=4146","https://assets.pipeline.soar.com/2792559-8464b3b1777b5af4db9e5fbfa1957113/thumbnail_2668000.jpg","/articles/6104074/Utah/Independent-evaluator-says-RMP-risk-approach-broadly-follows-standards-FFSL-says-revised-plan-complies-with-statute","https://secure.pipeline.soar.com/6104074-412cd6967e272ccfa1e3a4fc4179f447/orig.mp4?Expires=1770973378&Signature=dZ2DX6BzHpvNFYOJthuplxHNmvM86mAkeSVRoj5-EweNgMpbp2A69zH4sAUYuwtIp5xI46uHWQLN-YmKxW29Tt6t-KCKcYKbbk87bdBeEJo8m4kZknZRy9KMAuPprGVVPGFjm4NuPN-grqnlhaSRBvCTMRg0L4S565~6O5VlL9qa6tTTCSpS5tDJCvcBTVjc9Gn6HbqJ9XHulX8Fzv8XZir15Enh5NchVRjynd4fbT9W20AkcVVgJ6Ob5DMZY8vMi7E3oOkXUxVegMOnc5DCKiTmhhmVEgMDMVkY~lPXpI0iyiXUiU6Efb8elIzMpa2s9Lv-B-zff2-96-9rYvC-fw__&Key-Pair-Id=KUT5TJCACFTXG","The independent evaluator retained in the consolidated dockets told the Utah Public Service Commission that Rocky Mountain Power’s risk‑mapping methods generally comport with industry practice, but the evaluator and other technical reviewers flagged limitations — especially the lack of a complete, monetized cost‑effectiveness analysis tied to mitigation selection.

Independent evaluator findings: The evaluator’s executive summary said RMP’s risk‑assessment methodologies and maps “generally comport with industry standard practices,” and it acknowledged that RMP set out comprehensive programs to address identified risks. But the evaluator also said additional granularity would help better define the company’s High Consequence Fire Areas (HCFA) and that an RSC‑style cost analysis could not be completed because key data were unavailable. The evaluator recommended improved data collection and a more explicit cost‑effectiveness evaluation.

FFSL position: The Utah Division of Forestry, Fire and State Lands (FFSL) told the PSC it actively reviewed RMP’s 2023 filing, worked with the company to provide technical feedback (including on fuel and vegetation inputs) and concluded the revised plan contains the information required by Utah Code § 54‑24‑201. FFSL explicitly said it does not express an opinion on the cost‑benefit analysis debate and instead focused on hazard mapping and mitigation appropriateness.

Points of disagreement in the record: The independent evaluator and FFSL agree on the need for better granularity and that RMP’s revised submission clarified several items. But OCS witnesses and the Division of Public Utilities say the record is still incomplete without a monetized cost‑vs‑risk analysis to allow the PSC to decide whether the plan’s spending levels are reasonable for ratepayers.

Technical detail: Critics in the hearing noted differences between RMP’s HCFA mapping and the independent evaluator’s proxy mapping; OCS and DPU witnesses said those differences show the modeling can yield widely different HCFA footprints depending on inputs and assumptions. RMP’s witnesses have defended their choice of the Fireside (or similar) model and the underlying data.

Ending: The IE’s finding that RMP’s methods generally align with industry practice keeps the debate technical: commissioners must decide whether the existing modeling and reviewer comments provide a sufficient record to approve large new spending levels — or whether RMP must supply additional, monetized cost‑effectiveness evidence before the commission allows expanded rate recovery.","The independent evaluator found Rocky Mountain Power’s modeling generally aligns with industry practice but recommended more granular cost‑effectiveness work; Utah Division of Forestry, Fire and State Lands told the PSC it provided input and considers the revised plan to meet statutory filing requirements",{"_33":88,"_35":36,"_37":38,"_39":89,"_41":90,"_43":91,"_45":92,"_47":93,"_49":94,"_51":95,"_53":96,"_55":56,"_57":58,"_59":97,"_61":62,"_63":64,"_65":98,"_67":68,"_69":70,"_71":72,"_73":56,"_74":56},6104081,"Office of Consumer Services, OCS experts press PSC to require quantified cost–risk analysis before approving RMP’s expanded plan",8724,8896000,17620000,"/Search/View?dp=1&key=2792559-8464b3b1777b5af4db9e5fbfa1957113&start=8896&end=17620","https://assets.pipeline.soar.com/2792559-8464b3b1777b5af4db9e5fbfa1957113/thumbnail_8896000.jpg","/articles/6104081/Utah/Office-of-Consumer-Services-OCS-experts-press-PSC-to-require-quantified-costrisk-analysis-before-approving-RMPs-expanded-plan","https://secure.pipeline.soar.com/6104081-fdaab1fbdc81e5be8807a0d909d201aa/orig.mp4?Expires=1770973378&Signature=GBxny9W14Sqw8IwtP5nKbejR-MXT5kdHyf-j9-nbhIGgXriDgzD3xW8OsY-0TNx95PsM6n5~HAJD1lLzn8w5Ky~cgx3FLRu-PvvY82MsoplSn5esSqg6zqdBYERakh-rSxXX7EilTghxY1LmQOp5jnPKpF-b5OWXn0frbCYCmMfHzYtUZo8MIfOVBB9x0BOvI8fub8xtA23cA2ySKXsippV6JtsCsvyZlcn8nnPLBkwadDlDup2Ig3JdxntbXv~dN6Vp968OufaNM6wi6nWkD9oGqmI3OAB2xLUziYd3xr1O9HgSTydd0qR2J9hvSfIaDCNT-n4yJMNuJzRnaUX8hQ__&Key-Pair-Id=KUT5TJCACFTXG","Office of Consumer Services witnesses and consultants told the Utah Public Service Commission the record in RMP’s Wildland Fire Protection Plan docket lacks the quantified cost–versus‑risk evidence the commission needs to decide whether to allow recovery of substantially higher wildfire spending.

OCS summary: OCS witness Bela Bastag and consultants Dennis Stevens and Paul Álvarez argued that the company did not include a cost‑effectiveness analysis sufficient to permit the PSC to find the plan appropriately balances implementation cost with wildfire risk. The OCS recommended the commission reject the revised 2023 WMP or, if the commission does not reject it, limit the 2025 test‑year amounts for ratemaking and deny recovery now for deferred 2021–2023 costs that exceed the previously approved 2020 plan.

Why it matters: Multiple OCS witnesses said the statutory standard — that the plan be reasonable and appropriately balance cost and risk — requires quantified evidence. OCS argued the independent evaluator and several parties identify the lack of a meaningful, monetized cost‑benefit or “risk‑informed benefit‑cost” analysis as the central shortcoming.

Experts’ proposals: Dennis Stevens explained the analytical approach he and OCS endorse: estimate the monetary consequence of ignition (dollars per event), estimate the probability an equipment fault produces ignition, and estimate how a mitigation reduces that probability — then compute the present‑value benefits of mitigation and compare to mitigation cost. Stevens said that approach yields a transparent, per‑segment measure that regulators and intervenors can test and that can be used to prioritize mitigations.

OCS economist Paul Álvarez used that comparison to illustrate tradeoffs. He presented examples comparing undergrounding, covered conductor and vegetation management on a dollars‑per‑mile and miles‑covered basis. Álvarez argued vegetation management can yield more miles of risk reduction per dollar in many cases and urged the commission to approve a higher O&M allowance directed to vegetation management while holding capital recovery to previously approved levels pending a full cost‑risk analysis.

OCS recommendations on numbers: OCS recommended using the previously approved 2020 plan as the base for ratemaking immediately and proposed test‑year limits of $40,500,000 capital and $24,900,000 O&M for 2025 (OCS explained the higher O&M figure is intended to prioritize vegetation management). OCS also recommended reducing the $21,028,285 WBA deferral request by amounts that OCS says are not incremental or were misallocated.

What OCS told the PSC: \"The company has not provided the required evidence demonstrating to the commission that the 2023 plan appropriately balances costs with wildfire risk,\" OCS witness Bela Bastag said. Independent contractor Dennis Stevens testified the standard model should be supplemented by historical fault and ignition data and monetized consequences to quantify risk reductions.

Context and next steps: OCS urged the commission to require RMP to produce and file risk‑informed benefit‑cost analysis in the next update of its WMP and warned that creating a separate stakeholder docket (as RMP suggested) could delay necessary improvements and shift the primary burden from the company to intervenors.

Ending: The OCS position raises a procedural choice for the PSC: require RMP to produce a quantified, monetized cost‑risk analysis now and limit recovery until that is reviewed, or accept a less‑quantified record and allow broader recovery immediately. The PSC will decide as part of its order.","OCS witnesses and outside experts told the Utah PSC the record lacks a quantified cost-vs-risk (cost-benefit) analysis; they urged the commission to reject the revised 2023 plan or limit recovery now and to require a risk‑informed benefit‑cost analysis for future plans","actionData","errors"]

Article not found

Division of Public Utilities says Rocky Mountain Power’s revised 2023 wildfire plan fails to show costs balance benefits

Independent evaluator says RMP risk approach broadly follows standards; FFSL says revised plan complies with statute

Office of Consumer Services, OCS experts press PSC to require quantified cost–risk analysis before approving RMP’s expanded plan