SoCalGas and San Diego Gas & Electric Risk Assessment Mitigation Phase (RAMP)


In November 2016, SoCalGas and San Diego Gas & Electric filed their Risk Assessment Mitigation Phase (RAMP) filing with the CPUC. SCG/SDG&E’s RAMP filing was the first of its kind, as RAMP filings will now precede all large utility General Rate Cases in California.

SCG/SDG&E’s RAMP outlined 28 of the utilities’ top risks (11 for SCG and 17 for SDG&E), as well as providing testimony on the utilities’ general risk management approach, data collection methods, and other information.


Public Advocates Office (the Office) Position

The Office reviewed the utilities’ RAMP filing and provided the following general comments:

  1. Generally, the utilities’ analyses and background were lacking in quantitative analysis and data. In addition, the utilities used inconsistent models for assessing various risks and risk mitigations.
  2. The utilities workpaper (documents supporting written testimony) were inaccessible or not transparent.
  3. At times, there was significant overlap between risks and risk drivers. While Public Advocates Office recognizes that risk assessment does not always allow for a clear distinction, the Public Advocates Office recommended additional future distinction of risks and risk drivers where possible.

The Office also assessed all 28 top utility risks individually and provided comments on specific components of each risk.

The Office recommends changes to the way SCG/SDG&E assess and present risk, risk drivers, and risk mitigations, but acknowledges that the RAMP process is one of ongoing development and learning for all parties and that the process will likely take multiple iterations to reach a common and agreed-upon level of understanding and usefulness.

See Public Advocates Office’s comments on SCG/SDG&E’s filing.

On April 26, the Commission approved Decision 18-04-016 closing the RAMP proceeding and transferring any outstanding issues to SCG/SDG&E’s General Rate Cases.


Proceeding Docket

See the CPUC proceeding docket. Here you can read all parties’ comments on SCG/SDG&E’s RAMP and subscribe to regular proceeding updates.