Organizational Structure
The Executive Branch provides support to internal staff and engages and informs the public.
- The Budget and Administrative Services (BAS) Section provides support to management and staff in a wide range of areas. This includes administrative and human resources work, budgeting and contracting, office support, recruitment, and website management.
- The Policy & Planning Section conducts monthly meetings with Public Advocate Office’s Energy, Water and Communications Teams to discuss policy concerns and legislation before the Legislature. The Section manages the public, governmental, and legislative affairs. Staff advocate on behalf of the millions of utility customers throughout the state via policy efforts at the state capitol. The section provides educational briefing on CPUC ratemaking, rate design, and other utility policy issues. In addition, the section provides outreach to the public and the press on key policy issues and legislation. Lastly, the Policy and Planning Section prepares and submits the Annual Reports to the Governor and the Legislature.
The Electric Pricing & Customer Programs Branch focuses on electric rate design and customer-facing electric and gas programs, including distributed energy resources and low-income programs. The branch develops policy recommendations to achieve the state’s important equity and environmental goals to ensure no community is left behind. The branch’s two sections work closely together as customer program designs and rate structures often influence one another and must be coordinated to effectively promote the State’s energy policy goals.
- The Customer Programs Section evaluates a wide range of customer-facing programs and makes recommendations to make the programs effective and useful. Program areas include energy efficiency, building decarbonization, demand response, distributed generation, and as well as low-income programs and programs to assist customers in disadvantaged communities.
- The Electricity Pricing Section evaluates and makes recommendations on rate structures to promote the state’s policy goals through encouraging efficient use of electricity and equitable distribution of utility costs. The section has been the driver of important policy improvements to rate design such as time-of-use pricing and mechanisms to collect fixed costs.
The Electricity Planning & Policy Branch has primary responsibility for representing ratepayers on matters related to integrated resource planning, resource adequacy, procurement cost recovery, provider of last resort, the renewable portfolio standard, and climate change policies.
- The Climate Change Initiatives Section oversees renewable and energy storage procurement and policy, greenhouse gas emissions analysis, Cap-and-Trade program compliance, and other climate change policies. Major climate change policy issues currently being addressed by the Climate Change Initiatives Section include cost-effective renewable procurement and integration of renewable energy onto the electric grid, utilization of cost-effective energy storage in strategic locations, GHG Cap-and-Trade implementation and products, GHG emissions reductions strategies, and consideration of emerging technologies.
- The Procurement Cost Recovery Section oversees energy cost recovery to ensure rate requests for fuel, purchased power, and other costs are reasonable. For this work, the team reviews investor-owned utility forecasts of electric procurement cost revenue requirements and conducts regulatory compliance reviews of utility owned generation, energy resource contract administration, least-cost dispatch, fuel procurement, and balancing accounts. The team also advises on cost allocation issues among the utilities, community choice aggregators, and direct access providers through the power charge indifference adjustment and other cost sharing mechanisms.
- The Resource Planning Section focuses on procurement planning to ensure California maintains grid reliability and meets its greenhouse gas reduction goals while minimizing impacts on ratepayer bills. The team provides recommendations to improve Resource Adequacy, Integrated Resource Planning, and related California Public Utilities Commission (CPUC), California Independent System Operator (CAISO), California Energy Commission (CEC), and California Air Resources Board (CARB) stakeholder processes.
The Energy Cost of Service and Natural Gas Branch is responsible for representing ratepayer interests in energy proceedings involving general rate cases, cost of capital, securitization, sales of utility assets, Catastrophic Event Memorandum Account (CEMA) recovery, Wildfire Mitigation Reasonableness Reviews, utility financing, electrification cost recovery, and nuclear decommissioning. The Branch also focuses on natural gas procurement and policy, gas cost incentive mechanisms, purchased gas costs, natural gas system planning, natural gas transmission and storage infrastructure, and natural gas cost allocation and rate design.
The Energy Cost of Service and Natural Gas Branch is organized into four sections:
- Natural Gas Section
- Operational Costs Section
- Regulatory Cost Analysis Section
- Revenue Requirement Section
The Energy Infrastructure Branch focuses on distribution and transmission electric infrastructure, including distribution and transmission planning and policy. The branch reviews programs, such as the interconnection of resources, electric vehicles programs, microgrids policies and guidelines, distributed resource planning, and transmission planning and permitting processes in California and the western region. The branch's two sections evaluate energy infrastructure project proposals, such as power lines, to ensure they efficiently advance the state's affordability, energy and climate change goals.
- The Distribution Planning & Policy Section focuses on the interaction between distributed energy resources (such as solar panels, electric vehicles and battery storage) and the electricity distribution grid to which they are connected. The section recommends and supports accurate forecasting in order for the distribution grid infrastructure to be built out in a cost-effective and equitable manner. Key areas of work include utility planning processes, microgrids, transportation electrification and distribution interconnection.
- The Transmission Planning and Policy Section provides technical expertise, research, and recommendations on areas of the bulk electric system, including transmission interconnection, California Independent System Operator (CAISO) and western region transmission planning process, and infrastructure permitting at the CPUC.
The Safety Branch focuses on the safety of electric and natural gas infrastructure. The branch develops policy and technical recommendations to achieve the state’s safety, reliability, and cost-effectiveness goals to make a safety California. The branch's four sections utilize a variety of tools, from working to enhance safety culture all the way to mapping utility infrastructure against risk, to promote safety as effectively, efficiently, as quickly as possible. The Safety Branch represents ratepayers and ratepayer interests in safety matters such as wildfire hardening and protection (undergrounding, covered conductor, tree trimming, Public Safety Power Shutoffs), safety culture, and risk modeling. The branch also actively participates in safety proceedings after infrastructure disasters, such as the 2007 San Diego firestorms, 2010 PG&E transmission pipeline explosion in San Bruno, 2015 Southern California Gas Company Aliso Canyon Natural Gas Storage blowout, 2017 PG&E North Bay Wildfires, 2018 PG&E Camp Fire, and the failure to properly implement Public Safety Power Shutoffs in 2019.
- The Financial Impacts Section's analysts and engineers analyze and recommend improvements to utility safety and risk management programs. The team advocates in multiple proceedings at the CPUC to optimize ratepayer funds to maximize safety benefits, mitigate risks, close safety gaps, and avoid the enormous costs from catastrophic events. These proceedings include CPUC rulemakings, Risk and Mitigation Phase proceedings (RAMPs) and GRCs. We have recommended that the CPUC require electric utilities to conduct a thorough risk analysis of Public Safety Power Shutoff (PSPS) events. We also recommended that the CPUC require that utilities report an expanded suite of safety performance metrics. We also recommended that the CPUC require utilities to submit action plans to timely complete necessary, ratepayer funded, safety and reliability work, that remains incomplete. We recommended that the CPUC establish an ongoing process to oversee this action plan. In past CPUC investigations, incomplete safety and reliability work has been identified as one of the root causes of costly catastrophic events.
- The Safety Analysis Section advocates for the safe and efficient implementation and operation of both natural gas and hydrogen infrastructure. As the nascent hydrogen economy begins to develop the analysis team is responsible for ensuring that existing regulations keep pace with the development of infrastructure dedicated to the transportation of hydrogen as a fuel. In this role, we are active in the early scoping and development of feasibility studies for projects such as the Angeles Link proposed by SoCalGas. The section is also responsible for the development, maintenance, and utilization of Geographical Information System analysis across all aspects of the safety branch’s portfolio. We also represent ratepayers during investigations into underground gas infrastructure catastrophic failures.
- The Safety Policy Section focuses on developing and implementing policy solutions to improve utility safety outcomes. Our major focus is on assessing and improving electric and gas utility safety culture, which we define as the collective set of values, principles, beliefs, and norms that an organization’s leaders, employees, and contractors share concerning safety. We review safety culture assessments and advocate on guidelines for conducting future assessments at both the CPUC and the Office of Energy Infrastructure Safety. In addition, our team advocates in other areas where policy can impact safety outcomes such as utility executive compensation and de-energization policy.
- The Wildfire Safety Section works to prevent utility-caused wildfires and to promote effective safety improvements in general. We advocate for effective, risk-focused programs to mitigate wildfire risks. We scrutinize electric utilities’ management practices, and their implementation of safety programs, to ensure that the utilities manage their grids competently and effectively – and when the results fall short of expectations, we demand changes and accountability. Electric utilities have caused several of the worst wildfires in California history. Electric utilities now submit Wildfire Mitigation Plans (WMPs) or updates annually. These plans entail billions of dollars in annual spending to prevent future wildfires. It is therefore vital to prioritize risks and select cost-effective mitigation measures to decrease risk. The Wildfire Safety Section carefully analyzes and critiques the utilities’ Wildfire Mitigation Plans and recommends improvements.
The Communications and Water Policy Branch on proceedings that involve the nine (9) small telephone company general rate cases, all public purpose programs (LifeLine, Deaf & Disabled, California Advanced Services Fund, California Teleconnect Fund, High Cost Fund A, and High Cost Fund B), and policy rulemakings related to access to utility poles and conduit, service quality (including safety and reliability), competition and customer choice, the continuing transition to Internet Protocol networks, the retirement of copper facilities, and privacy and customer protections.
- The Cross-Industry Policy and Spatial Analysis Section manages activities related to the Public Advocates Office Geographic Information Systems (GIS) data strategy, including but not limited to, operation and maintenance of the Division's GIS platform, internal procedures, data governance, data management, and data products in support of the Division's analysis of cross-industry utility GIS data including energy, communications, and water. The Section also works on cross-industry affordability proceedings with a focus on communications and water affordability.
- The Customer Programs Section advocates for policies to bridge the digital divide, achieve universal access to broadband services in California, advance customer protections for communication services, hold companies accountable for delivering reliable and affordable communication services, work on General Rate Cases, and conduct quantitative and qualitative research on communications policy issues that impact Californians every day, including customers in disadvantaged communities, low-income households, people with disabilities, and people who are incarcerated.
- The Policy Section advocates for broadband digital equity including universal access to high-quality and affordable broadband services, safe and reliable voice, wireless, and Voice over Internet Protocol (VoIP) service, conducts and qualitative research on communications policy issues that impact Californians every day.