Overstory Testifies at FERC’s Wildfire Conference

On October 20th, 2025, Overstory was invited to speak at the Federal Energy Regulatory Commission’s (FERC) Wildfire Risk Mitigation Technical Conference. The meeting convened regulators and industry leaders to examine how technology can improve wildfire mitigation outcomes. Overstory was honored to contribute, sharing the insights we’ve gleaned from dozens of utilities using remote sensing data to reduce wildfire risk across their networks. In the following article, we’ll break down why this topic has garnered so much attention and the three key observations our experts shared with the Commission.

Photo by Anthony Feliciotti on Unsplash

The cost of wildfire risk

Wildfire is no longer a peripheral issue for utilities. Across North America, it continues to spread its geographic influence, driving both risk and costs sharply upward.

In recent reports from organizations such as Lawrence Berkeley National Laboratory and the Public Advocate’s office in California, researchers have analyzed how wildfire mitigation investments can impact utility costs. They note that wildfire-related investments (covering mitigation, insurance, grid hardening, and settlements) are the single largest factor driving increases in revenue requirements at California utilities. 

By 2024, these wildfire-related costs accounted for roughly 17% of total allowed utility revenues, ten times their share just five years earlier. This rapid escalation highlights the scale of the challenge and underscores the need for prudent, data-driven investment to ensure that every mitigation dollar delivers measurable reductions in wildfire risk.

For regulators and utilities alike, the question is no longer whether to invest in wildfire mitigation, but how to do so in a manner that effectively reduces risk with minimal ratepayer impacts.

Drawing on our experience with utilities across North America, we’ve seen how technology can help make wildfire mitigation more effective, efficient, and measurable. 

Our testimony highlights three main points, described below. 

1. Satellite technology is already used widely and effectively

In recent years, remote sensing has emerged as an essential tool for wildfire mitigation. With the capacity to deliver a recent and objective view of conditions on the ground across an entire network, remote sensing offers a cost effective and actionable approach to mitigate wildfire risk. 

Thanks to advancements in both machine learning models and the quality of commercially available satellite imagery, utilities can now monitor vegetation conditions, fuels, and encroachment across their entire systems. These insights enable utilities to adopt a far more precise approach, directing field resources where they can achieve the greatest risk reductions.

Combining this technology with innovations like high-resolution detection cameras or fire-spread modeling tools, utilities can now obtain a continuous view of system risk that connects long-term prevention with real-time awareness and response. 

This practical, cost-effective and continuous monitoring is now leveraged across hundreds of thousands of line miles per year by Overstory alone, with other wildfire technologies following suit. 

2. Satellite analysis is a practical, cost-effective path to mitigation 

Satellite analytics scale with utility size, wildfire risk exposure and organizational maturity, delivering an adaptable, repeatable baseline to assess vegetation and fuel conditions, pinpoint highest-risk spans, and track progress over time while balancing cost. 

For utilities beginning to develop an approach, satellites provide a turnkey, system-wide view without standing up large internal teams, enabling rapid prioritization or targeted patrols. For more advanced or risk-prone electricity providers, satellite analysis serves as a foundational layer that integrates with LiDAR, sensors, and field programs to determine where deeper investments should go. 

As wildfire costs grow, scalable tools like satellite analytics are both the prudent starting point and the enduring backbone for mitigation planning at utilities of various sizes and levels of wildfire investment maturity, focusing spend where impact is greatest and building long-term resilience.

3. Regulation hasn’t kept pace with technological maturity

While satellite technology has matured and utility adoption has accelerated, policy frameworks have not all followed suit. Under NERC’s FAC-003 standard, which governs vegetation management for transmission lines, many utilities remain uncertain whether satellite-based inspections qualify as required vegetation inspections on their own.

As a result, they are often caught between spending on prohibitively costly full-system LiDAR scans and filling in the gaps with notoriously risky or subjective inspections from aerial flights, foot patrols, drive bys or citizen call-ins. To consider the costs and risks of aerial flights alone, utilities have shared that while these inspections meet NERC’s requirements, they are often plagued by difficult viewing angles, inconsistent aircraft speed, inspector fatigue and other factors resulting in approximately 50% false detections and unknown numbers of misses. 

In many cases, satellite scans can serve as a prudent complementary technology, producing results that complement more infrequent LiDAR scans and can be more accurate than helicopter patrols. As evidence of satellite analysis’s technological maturity, Overstory presents some sample findings across diverse territories, including:

• An analysis of tens of thousands of spans at a West Coast utility comparing Overstory’s results to on-the-ground field inspections determined more than 99% agreement on spans in high fire risk areas needing no work (marked “clear” by the technology).

• Certified utility foresters at a Western utility found 90 percent agreement that “high-risk” spans identified by Overstory required work, and 96 percent agreement that “minor-risk” spans did not. 

• A Midwestern Investor-Owned Utility measured a 95 percent correlation between Overstory’s encroachment indices and contractor work hours. 

These results demonstrate that satellite-based inspections meet the technical rigor and intent of FAC-003 in most cases, supporting the case for regulatory clarity that recognizes satellite remote sensing as an acceptable compliance method.

The existing uncertainty can create cost inefficiencies for consumers: utilities that use satellites for proactive risk management often still conduct parallel aerial or LiDAR patrols within the same year to satisfy regulatory requirements. 

Moving forward, clarifying the full list of remote sensing types that meet the intent of annual inspection standards would reduce redundancy, accelerate innovation, and allow utilities to reinvest savings directly into mitigation and fuel management work without compromising reliability or oversight.

Looking ahead

FERC’s engagement this year reflects a welcome advancement, aligning technology, policy, and economics in wildfire mitigation. As we continue to confront the growing costs and risks of a changing climate, technology should be evaluated not just for its novelty, but for its ability to achieve demonstrable, cost-effective reductions in ignition risk.

Overstory’s perspective is simple: technology is a means to act earlier, learn faster, and invest smarter. By building clarity around how various wildfire mitigation tools fit into both operational practice and regulatory frameworks, we can strengthen grid reliability, improve public safety, and make wildfire mitigation more sustainable for utilities and communities alike.