Transportation safety impacts

Introduction
I appreciate Xcel Energy’s efforts to improve system reliability; however, it is critical to recognize that Public Safety Power Shutoffs (PSPS) are primarily a liability mitigation strategy—not a comprehensive public safety solution. While the Superior fire was a tragic event, historical data over the past 50+ years shows that such fires are extremely rare when proper maintenance of power distribution infrastructure is performed. The probability of another Superior-type fire remains very low under standard maintenance practices. The December 17 PSPS also started at 5AM, but it didn’t really get high wind gusts in Lakewood until the afternoon. The PSPS power remained out from 17th to the 20th.

Comparative Analysis
Investor-owned utilities like Xcel have implemented PSPS, whereas mountain power cooperatives—facing equal or greater wind risks—did not. These co-ops prioritize service continuity for their customer-owners. If residents had the ability to choose their power provider, it is unlikely they would support widespread outages as a risk mitigation measure.

Public Safety Impacts
True public safety considerations must account for the consequences of outages. Every time power is cut, major traffic signals go dark, creating a high likelihood of crashes. During December 17 PSPS, Lakewood prepared for significant outages along the Alameda corridor by gathering 10 generators from citywide departments. Since the outage area wasn’t predefined with enough accuracy we didn’t pre-deploy generators as most predicted signal outages had battery backup systems. We experienced a broadside crash at Van Gordon & Cedar while deploying generators early in the outage, followed by a secondary collision. This pattern is predictable: commuter routes with dark signals often do not function as four-way stops, even with driver education of the law.

Infrastructure Investment & Cost Implications
Lakewood has invested nearly $1 million in battery backup systems for traffic signals, designed for short-term outages (4-8 hours). These systems cannot sustain the extended durations introduced by PSPS events. We already spend $30,000–$40,000 annually replacing batteries, and these systems will need to drastically change escalating costs under current PSPS practices of multiday outages.

Policy Recommendations
Lakewood’s power distribution is a mix of above-ground and underground systems. Xcel should collaborate with municipalities to prioritize feeders most vulnerable to PSPS and initiate a phased undergrounding strategy from substations outward. This should be a joint investment, leveraging city 1% funding where possible. Prioritization should be based on cost-benefit metrics—e.g., undergrounding a feeder that removes 5,000 customers from PSPS risk should rank higher than one affecting 3,000 customers at similar cost. Critical facilities—hospitals, elder care, sewage plants, police stations, and traffic signals on commuter routes—must be weighted heavily in this matrix.

Conclusion
PSPS, as currently implemented, introduces significant public safety risks and financial burdens without proportionate benefit. A collaborative, data-driven approach focused on infrastructure resilience—not blanket outages—is essential for true public safety.