injury might be viewed as either minor or serious depending on the utility, and further clarification of each descriptor is needed. As to impact categories (e.g., safety, environmental, reliability, compliance, financial, etc.), there is no agreement on what the categories should be, which is a precursor to effective multiattribute risk analysis. Utilities agree to use similar likelihood descriptors but further exploration may be warranted before likelihood measures are required. In sum, IS and EPUC believe that “these uniform elements identified by the utilities are best treated simply as a baseline, and in the interests of efficiency, the Commission ought to require additional uniformity across the utilities.” IS and EPUC also contend that even though the utilities do not agree on a common risk algorithm, the Commission should provide further guidance in this area. They also do not think that the Commission should defer consideration of a risk reduction per dollar spent in the upcoming RAMP filing because SCE has already demonstrated that it is possible to calculate. MGRA suggests that the Utilities have made good progress in developing areas of commonality. However, they assert the IOUs can likely accomplish more in the areas of specific risk approaches (e.g., wildfire risk) and use of different scoring algorithms. As to wildfire risk, MGRA points out “the wildfire exposure of different electrical utilities depends on specific landscape and weather type and not upon which particular IOU service territory the risk occurs in.” While Ana” wind driven wildfire risk and Northern “Santa California vegetationdriven wildfire risk are distinct, they need not be specifically tied to a utility. To reinforce this point, why should Ana” SCE “Santa
injury might be viewed as either minor or serious depending on the utility, and further clarification of each descriptor is needed. As to impact categories (e.g., safety, environmental, reliability, compliance, financial, etc.), there is no agreement on what the categories should be, which is a precursor to effective multiattribute risk analysis. Utilities agree to use similar likelihood descriptors but further exploration may be warranted before likelihood measures are required. In sum, IS and EPUC believe that “these uniform elements identified by the utilities are best treated simply as a baseline, and in the interests of efficiency, the Commission ought to require additional uniformity across the utilities.” IS and EPUC also contend that even though the utilities do not agree on a common risk algorithm, the Commission should provide further guidance in this area. They also do not think that the Commission should defer consideration of a risk reduction per dollar spent in the upcoming RAMP filing because SCE has already demonstrated that it is possible to calculate. MGRA suggests that the Utilities have made good progress in developing areas of commonality. However, they assert the IOUs can likely accomplish more in the areas of specific risk approaches (e.g., wildfire risk) and use of different scoring algorithms. As to wildfire risk, MGRA points out “the wildfire exposure of different electrical utilities depends on specific landscape and weather type and not upon which particular IOU service territory the risk occurs in.” While “Santa Ana” wind driven wildfire risk and Northern California vegetationdriven wildfire risk are distinct, they need not be specifically tied to a utility. To reinforce this point, why should “Santa Ana” SCE
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