IOUs Seek Approval to Handle Distribution Capacity & Wildfire Project Overlaps Under Existing Planning Framework

PG&E, SCE, and SDG&E jointly filed an advice letter seeking Commission approval of a proposed method for addressing situations where distribution capacity needs identified in the Distribution Planning Process overlap with non-capacity distribution work, such as wildfire mitigation projects.

The filing responds to a 2024 decision (D.24-10-030) in the High DER Future proceeding (R.21-06-017) and asks the CPUC to affirm that the utilities’ existing engineering and planning processes already satisfy the Commission’s requirements without the need for new analytical frameworks or procedural changes.

• The utilities explain that, in practice, when a non-capacity project is scheduled before a known future capacity need on the same assets or line path, engineers routinely evaluate whether modestly upsizing equipment at the outset is more cost-effective than performing a separate upgrade later. They contend that incorporating future capacity needs into initial projects is almost always less costly due to avoided permitting, mobilization, and construction inefficiencies, with exceptions only in cases of unusual technical or permitting complexity.
• Drawing on examples presented at two CPUC-facilitated workshops in October and November 2025, the utilities emphasize that no parties identified substantive flaws in their current processes and that their engineering judgment, informed by load forecasts and standards, is sufficient to balance cost, risk, and feasibility.

Their proposed method formalizes this approach through an engineering decision framework that:

• Identifies distribution needs;
• Applies existing standards;
• Evaluates overlaps across workstreams; and
• Where necessary, conducts targeted economic analysis to compare incremental upsizing costs against avoided future projects.

The utilities stress that this framework already accounts for wildfire risk, forecast uncertainty, and operational constraints, and that forthcoming Commission action on scenario planning (Draft Resolution E-5414) and pending loads (Draft Resolution E-5413) will further refine forecasting inputs. (Note that the CPUC has tentatively moved those two draft resolutions to the Consent Agenda for its December 18 voting meeting, meaning their unanimous adoption is near-guaranteed).

Protests are due January 5.

INSTANT ANALYSIS: The utilities' advice letter asks the Commission to validate current IOU practice rather than require a new planning construct. Approval would confirm that utilities may continue handling capacity and non-capacity overlaps through engineering judgment, with early asset upsizing treated as the preferred solution when it avoids follow-on projects. That approach shifts future disputes away from process design and toward fact-specific challenges, such as whether forecasts were reasonable or whether a particular upsizing decision was justified under the applicable standards.