Wildfire Mitigation Under California SB 254 and Renewable Developers

Senate Bill 254 was passed on September 19, 2025, during California’s ongoing wildfire season. Enacted as an urgency statute [Section 75 of S.B. 254], SB 254 immediately impacts how utilities plan and justify wildfire-risk investments. For renewable project developers, these changes will influence timelines, mitigation costs, and reimbursements.

Longer Planning Cycles, Tighter Coordination

Under SB 254, electrical corporations must now file comprehensive wildfire mitigation plans at least once every four years, replacing the previous three-year cycle [Section 53 of S.B. 254]. Beginning January 1, 2027, each utility must also submit a preliminary mitigation plan by the earlier of one year before its general rate case application or concurrently with its Risk Assessment Mitigation filing [Section 53 of S.B. 254].  As a result, developers should anticipate longer intervals between plan updates, and plan project schedules around those filing windows.

Cost-Per-Ignition

Additionally, SB 254 requires that wildfire mitigation plans estimate the “cost-per-avoided ignition,” or explain why such a value cannot reasonably be assigned [Section 53(c)(12)(D) of S.B. 254]. In other words, utilities must demonstrate that each dollar of mitigation delivers quantifiable ignition-risk reduction. 

California Wildfire Safety Advisory Board 

SB 254 also created the California Wildfire Safety Advisory Board, which will be responsible for reviewing and providing comments and “advisory opinions to local publicly owned electric utilities and electrical cooperatives regarding the content and sufficiency of their wildfire mitigation plans and recommendations on how to mitigate wildfire risk” as well as providing “other advice and recommendations related to wildfire safety as requested by the Office of Energy Infrastructure Safety” [Section 31 of S.B. 254].

Impact 

Wildfire mitigation is a factor that can shape the feasibility and timing of clean-energy projects. For developers, this means that project timelines must account for longer utility planning cycles and potential delays tied to wildfire mitigation reviews. As California’s climate and energy systems grow more intertwined, SB 254 signals a clear expectation that wildfire risk must be treated with the same rigor as any other infrastructure cost. Moreover, SB 254 underscores that successful renewable development in California now depends on proactive wildfire resilience planning being integrated from the beginning.