Publication
Governor Newsom Issues Executive Order to Expedite the Rebuilding and Undergrounding of Utilities and Telecommunication Infrastructure in the Wake of the LA Fires
Quick Take
On March 27, 2025, Governor Gavin Newsom issued Executive Order N-24-25 (the Order), suspending certain permitting requirements to help accelerate the rebuilding efforts of Altadena, Malibu, and Pacific Palisades following the fires that devastated these areas in January (the LA Fires).
Background
On January 12, 2025, Governor Newsom issued Executive Order N-4-25, which suspended the California Environmental Quality Act (CEQA) and permitting requirements under the California Coastal Act (CCA) to encourage the rebuilding of properties destroyed or substantially damaged by the LA Fires. While the prior suspension of CEQA and the permitting requirements under the CCA apply to electric, gas, water, sewer, and telecommunication infrastructure, certain projects that relocate, move underground, or upgrade existing infrastructure that was substantially damaged or destroyed by the LA Fires, may not qualify under such suspensions. Thus, with the Order, Governor Newsom has extended the suspension of CEQA and the CCA to apply to such rebuilding efforts of these utilities and infrastructure.
In support of the Order, Governor Newsom declared: “We are determined to rebuild Altadena, Malibu, and Pacific Palisades stronger and more resilient than before. Speeding up the pace that we rebuild our utility systems will help get survivors back home faster and prevent future fires.”
Key Provisions of Executive Order N-24-25
Executive Order N-24-25, issued by Governor Newsom on March 27, 2025, mandates that both CEQA and the permitting requirements under the CCA are suspended as they relate to:
- Projects to rebuild electric and telecommunication infrastructure substantially damaged or destroyed by the LA Fires, including undergrounding, upgrading, and relocation of such infrastructure.
- Projects to demolish, repair, replace, relocate, or upgrade electric or telecommunication infrastructure in areas adjacent to the projects described in paragraph one (above).
- Other underground electric, gas, water, sewer, or telecommunication infrastructure projects that can be undertaken at the same time as, and in the same excavated site as, the projects undertaken under the authority of paragraphs one and two (above).
Subject to the below requirements, the Order also suspends, to the extent necessary, other state statutes, rules, regulations, and requirements that fall within the jurisdiction of boards, departments, and offices within the California Environmental Protection Agency and the California Natural Resources Agency, for the purpose of expediting the projects described in paragraphs one through three (above):
- Individuals or entities who desire to conduct activities under the suspension of such state statutes, rules, regulations, and requirements, must request that the appropriate agency secretary (of either the California Environmental Protection Agency or the California Natural Resources Agency) determine that the proposed activities are eligible to be conducted under the suspension. The secretary must use discretion in applying the Order to ensure that the suspension serves the purpose of accelerating the projects described in paragraphs one through three (above), while at the same time protecting public health and the environment.
- Any activities performed under the suspensions shall be in accordance with the State Environmental Protection Plan or a comparable plan describing how such actions will balance expeditious fire recovery and environmental protection.
The Order serves as an important expansion of prior Executive Orders related to the suspension of CEQA and the permitting requirements under the CCA. By expediting the process for repairing and replacing damaged or destroyed utilities and infrastructure and facilitating the upgrading, undergrounding, and relocation of such utilities and infrastructure, the Order serves as a significant step forward in not only rebuilding the areas devastated by the LA Fires, but also in making these areas more resilient to future devastation.
Snell & Wilmer will continue to monitor Executive Order N-24-25 and will provide updates as new information becomes available.
About Snell & Wilmer
Founded in 1938, Snell & Wilmer is a full-service business law firm with more than 500 attorneys practicing in 17 locations throughout the United States and in Mexico, including Los Angeles, Orange County, Palo Alto and San Diego, California; Phoenix and Tucson, Arizona; Denver, Colorado; Washington, D.C.; Boise, Idaho; Las Vegas and Reno, Nevada; Albuquerque, New Mexico; Portland, Oregon; Dallas, Texas; Salt Lake City, Utah; Seattle, Washington; and Los Cabos, Mexico. The firm represents clients ranging from large, publicly traded corporations to small businesses, individuals and entrepreneurs. For more information, visit swlaw.com.
