Institute for Policy Integrity submitted joint comments with Columbia Law School's Sabin Center for Climate Change Law on the California Public Utilities Commission's (CPUC) Order Instituting Rulemaking to Update Rules for the Safety, Reliability, and Resiliency of Electrical Distribution Systems. The joint comments emphasize the importance of a comprehensive approach to climate resilience planning across utility sectors. Key recommendations include:
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The CPUC should clarify that the scope of relevant climate risks and impacts includes chronic environmental changes, not just extreme weather events. Specifically:
- Rising average temperatures will affect electricity demand, asset efficiency, and maintenance schedules
- Sea level rise poses risks of nuisance flooding, storm surge, and permanent inundation to coastal infrastructure
- These chronic impacts have implications for daily grid operations and long-term planning
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The CPUC should recognize that many emerging threats, risks, and priorities affecting the electric distribution system also impact other utility systems, particularly natural gas. The Commission should:
- Address the suitability of current oversight practices for ensuring safety, reliability, and resilience of natural gas distribution system.
- Consider the interactions and interdependencies between electric and natural gas systems
- Coordinate this proceeding with any corresponding efforts related to natural gas systems