The Highest-Stakes Filing You Can't Reconstruct: Wildfire Plans and the PSPS Decision Record
Post by
Tom Janes
This week the California Public Utilities Commission proposed a $22 million penalty against PG&E for the 2022 Mosquito Fire, which burned more than 75,000 acres in Placer County. What's worth the attention of every utility operator on the continent, not just those in California, is why.
The CPUC investigation found violations of the rules for the design, construction, and maintenance of overhead lines, and the proposed settlement forces PG&E to pay for an independent review of its inspection program. In other words, the penalty is about execution, not the plan, and specifically about whether the utility could show its field work met the standard it was held to.
That is the exact fault line I have been writing about across this series. Regulators have moved from grading the plan to demanding proof it was executed. Nowhere is that shift sharper, or the cost of failing it higher, than in wildfire, and the two documents at the center of it, the Wildfire Mitigation Plan (WMP) and the Public Safety Power Shutoff (PSPS) protocol, now carry more legal weight than almost anything else a utility files.
No Longer just a California Problem
It is tempting for a utility outside California to read a PG&E headline as someone else's issue. That view is a few years out of date. Catastrophic wildfire risk has spread across the West, the Southwest, Texas, the Upper Midwest, the Southeast, and well into Canada, and the regulatory response has followed.
A growing number of state commissions now require formal wildfire mitigation plans, and the underlying obligation to inspect and maintain the grid to a documented standard is not a state-by-state courtesy. It runs through NERC reliability standards that apply across North America, including the FAC-003 vegetation standard I have written about before.
The pattern is consistent wherever you operate. The plan gets more prescriptive, the documentation bar rises toward a uniform standard, and cost recovery increasingly turns on whether you can show you substantially did what you filed. The stakes are not abstract. PG&E has disclosed aggregate liability estimates of $1.3 billion for the 2019 Kincade fire, $2.2 billion for the 2021 Dixie fire, and $400 million for Mosquito. A utility does not need to be in California to recognize that this is now an existential category of risk, and that the difference between a defensible position and a disaster often comes down to what you can prove.
A WMP is a Promise about Thousands of Discrete Field Actions
A modern wildfire plan commits a utility like yours to a specific, countable set of work: circuit-miles of covered conductor installed, poles and lines inspected, spans cleared in high fire-risk areas, fast-trip settings enabled during fire season, weather stations and cameras deployed. Each of those commitments is a promise about field execution, made to a commission, on the record.
The trouble is that the evidence for those promises lives in fragmented places: Inspection results sit in one system. Vegetation clearance records sit in another. Asset hardening progress lives in the EAM. Contractor completion photos live on a phone or a shared drive.
When a plan commits to inspecting a defined set of assets in a high-risk area by a defined date, proving you did it should be a query. Today, for most utilities, it's a reconstruction project.
The Mosquito Fire settlement is what that reconstruction problem looks like when it fails. A regulator asks whether the design, construction, and maintenance of specific overhead lines met the standard, and the answer has to be assembled and defended after the fact, at shareholder expense. If a fire starts near a span you committed to clearing, the first question from investigators, plaintiffs, and your commission will be whether you actually cleared it, on schedule, to the standard in your plan. "We're fairly sure we did, let me pull the records together" is not an answer you want to be assembling under subpoena.
PSPS is a Judgement Call that must Survive Second-Guessing
If the WMP is a promise about planned work, a Public Safety Power Shutoff is the opposite: a high-consequence decision made in hours, under uncertainty, that will be scrutinized for months.
Every PSPS event is a genuine dilemma, as you know. De-energize too aggressively and you harm customers who depend on power for medical equipment, refrigerated medication, and water pumps, and you draw regulatory and political fire for over-reaching. De-energize too little and you risk an ignition a shutoff would have prevented. There is no safe default, there is only a defensible decision.
What makes a PSPS decision defensible is the record. Regulators reviewing an event, and courts reviewing it later, want to see the same chain: what weather and fuel-moisture inputs were in front of the decision-maker, what risk thresholds those inputs crossed, which circuits were scoped in and why, who reviewed the recommendation and signed off, how affected customers and public-safety partners were notified, and what field inspection cleared each line before re-energization. In several jurisdictions, the post-event report documenting all of this is due within days.
When those inputs are scattered across weather feeds, GIS layers, notification logs, and email approvals, the after-action report becomes exactly the manual scramble that a tight deadline and a hostile audience make worst. The decision may have been sound. If you can't show the reasoning, you're defending it from behind.
Byproduct Documentation Applies Cleanly to Wildfire
The pattern I described in Byproduct Documentation was built for exactly this problem: design the workflow so the compliance evidence is generated as a byproduct of the work, not reconstructed afterward. Wildfire is where it pays off most.
For WMP execution, that means every inspection, hardening job, and clearance is captured against the specific plan commitment it satisfies, at the moment it's completed, with the location, timestamp, standard applied, and completion evidence attached. Your plan-versus-actual status stops being a quarterly assembly exercise and becomes something you can pull up on demand, line by line. When a commission opens an inspection-program review, as it did with PG&E, you are exporting a record instead of building a defense.
For PSPS, it means the decision record writes itself as the event unfolds. The weather and risk inputs that triggered the scoping, the thresholds applied, the human review and sign-off, the notifications sent, and the re-energization inspections all land in one auditable trail tied to the event. As I argued in Why AI Without Orchestration Is Just Expensive Guessing, the point isn't to let a model make the call. It's to make a qualified person's judgment visible and documented at every step. That "recommended by the model, decided by a person, captured in the record" structure is precisely what commissioners increasingly expect for a de-energization.
None of this requires ripping out the systems you have. It requires governing the flow between them so the evidence is a product of doing the work, the same argument I've made across this series, now applied to the work where the stakes are highest.
What Utility Leaders Should Pressure-Test Before the Next Red-Flag Day
- Can you prove wildfire-plan compliance line by line, today? Pick a single high fire-risk commitment from your current plan and try to produce the completion evidence for it in an hour. If it takes a week, that's your exposure.
- Could you assemble a PSPS after-action report inside the regulatory deadline? Walk the last event backward from decision to notification to re-energization and see how much you'd have to reconstruct by hand.
- Is your decision reasoning captured, not just your decision? A defensible PSPS record shows the inputs, thresholds, and human sign-off, not merely that circuits were de-energized.
- Does field execution feed the evidence automatically? If your inspectors and crews are documenting for compliance in a separate step from doing the work, that step will be the one that fails under pressure.
Wildfire is the arena where the gap between a filed plan and provable execution stops being a rate-case inconvenience and becomes a matter of safety and liability. As the Mosquito Fire settlement shows, the exposure is not only the fire itself but the inability to demonstrate that the work matched the standard. The utilities that treat their wildfire and PSPS records as evidence they generate continuously, rather than narratives they assemble after the fact, are the ones that will be able to stand behind their decisions when it matters most.
At Macedon, we work side by side with utilities across North America to build the workflows that turn wildfire mitigation and PSPS execution into a defensible, always-ready record. If wildfire season has you thinking about what you could actually prove, that's the conversation worth having before the next red-flag day, not after the next event.
Want to continue the discussion? Schedule a chat with Tom.