Relating to risk mitigation planning and associated liability for providers of electric service; providing an administrative penalty.

Contracts

• Vegetation Management MSAs: Review all Master Service Agreements with tree-trimming vendors immediately. Your statutory liability shield depends on "strict compliance" with your vegetation plan. Contracts must mandate adherence to WMP specifications and include indemnification clauses if vendor negligence voids your liability protection.
• Independent Expert Retainers: You must contract with an "independent expert in fire risk mitigation" to analyze your plan prior to submission. Secure these vendors now; demand will exceed supply in Q3/Q4 2025.
• Pole Attachments: Review attachment agreements. Ensure third-party equipment does not interfere with your ability to execute the WMP, as the statute preserves existing contract rights.

Hiring/Training

• De-Energization Protocols: Control room staff require immediate training on new Public Safety Power Shut-off (PSPS) procedures and recloser disablement protocols.
• Community Liaison: Designate specific personnel responsible for the mandatory community outreach and first-responder coordination required by the WMP.

Reporting & Record-Keeping

• The 10-Point WMP: You must compile a plan containing 10 statutory components, including vegetation management, infrastructure inspections, and restoration procedures.
• Compliance Audits: Establish an internal audit trail. To claim the liability defense in court, you must produce records proving you were in compliance with your plan at the time of ignition.
• Self-Insurance Petitions: If commercial insurance is cost-prohibitive, prepare data to petition the PUC for self-insurance authority under amended Section 36.064.

Fees & Costs

• Consulting Fees: Budget for high-cost independent expert analysis required for the WMP.
• Administrative Penalties: Failure to file or follow the plan triggers Chapter 15 Utilities Code penalties (typically up to $25,000 per violation, per day).
• Operational Increases: Expect significant budget increases for vegetation management to meet the "strict compliance" standard in designated risk areas.