Anaheim City Council
June 13, 2023

2023 Wildfire Mitigation Plan

2 Table of Contents
Executive Summary - 2023 ...........................................................................................................................4 SECTION 1 - Introduction..............................................................................................................................6 A. Introduction......................................................................................................................................6 B. Overview and Objectives ..................................................................................................................9 SECTION 2 - Enterprise-Wide Safety Risk Assessment................................................................................16 SECTION 3 - Overview of Risks and Risk Drivers Related to Wildfires ........................................................16 SECTION 4 - Dynamic Climate Change........................................................................................................19 SECTION 5 - Assessment of High Fire Threat in APU’s Electric Service Territory........................................20 SECTION 6 - Overview of Preventative Strategies and Programs ...............................................................24 SECTION 7 - Situational Awareness ............................................................................................................25 SECTION 8 – Preventative Strategies for Building Infrastructure Resiliency ..............................................31 A. Vegetation Management................................................................................................................31 B. System Inspection and Maintenance..............................................................................................34 C. Undergrounding Power Lines .........................................................................................................35 D. Overhead Construction Practices ...................................................................................................37 E. Pole Loading and Wire Spacing.......................................................................................................38 SECTION 9 - Operational Strategies to Reduce Risk of Wildfire Ignition ....................................................39 A. System Patrols ................................................................................................................................39 B. Circuit Reclosers .............................................................................................................................39 C. Communication Network................................................................................................................40 D. Power Shutoffs ...............................................................................................................................40 E. Summary of Operational Strategies ...............................................................................................42 SECTION 10 - Community Support in Emergencies ....................................................................................42 A. Community Outreach .....................................................................................................................42 B. Emergency Response......................................................................................................................44 C. Community Support .......................................................................................................................46 D. Post-Event Customer Support ........................................................................................................47 SECTION 11 - Workforce Training...............................................................................................................48 SECTION 12 - Organization and Assignment Responsibilities.....................................................................49 SECTION 13 - Metrics, Monitoring and Reporting ......................................................................................51 SECTION 14 - Monitor and Auditing the Plan .............................................................................................58 3 List of Tables
Table 1: Anaheim Public Utilities Context-Setting Table ............................................................................6 Table 2: Statutory Cross References with SB 901 — Public Utilities Code Section 8387(b) ......................9 Table 3: Elements Consistent with WSAB 2023 Guidance........................................................................13 Table 4: Risk Mitigation for Wildfire Ignition ...........................................................................................17 Table 5: Categorization of APU Potential Wildfire Risk Drivers and Corresponding Preventative Strategy ....................................................................................................................................................................19 Table 6: Tiered Fire Threat Zones in Anaheim ..........................................................................................22 Table 7: Preventative Strategies and Programs ..........................................................................................24 Table 8: Operational Strategies ..................................................................................................................42 Table 9: Roles and Responsibilities for Implementation of the WMP .......................................................50 Table 10: Summary of Performance Metrics..............................................................................................55 Table 11: APU’s Wildfire Mitigation Investments.....................................................................................56 List of Figures
Figure 1 : Anaheim Service Territory and Council District Boundaries.......................................................8 Figure 2: (a) Park Substation (b) Walnut Canyon Reservoir during Canyon Fire 2 .....................................9 Figure 3: Wildfire "Bowtie" Risk Mitigation Chart....................................................................................17 Figure 4: Anaheim Public Utilities Fire Threat Map ..................................................................................21 Figure 5: AlertCalifornia.org Portal............................................................................................................26 Figure 6: High Resolution Camera Installation and Camera Image Overlooking Anaheim.......................26 Figure 7: Anaheim Camera Image of 91/241 Freeway Interchange ...........................................................27 Figure 8: Camera Locations in Service and Planned by APU to View Anaheim FTZs..............................28 Figure 9: APU Power BI Dashboard ..........................................................................................................29 Figure 10: Anaheim Camera Image of Contempo Wildfire on 10-26-2019 ...............................................30 Figure 11: Anaheim Camera Image of Jim Wildfire of 3-2-2022...............................................................30 Figure 12: Tree Inventory Tracking in a GIS Map .....................................................................................32 Figure 13: GSOB 2021 Survey Data ..........................................................................................................33 Figure 14: APU OH Circuits in FTZs.........................................................................................................36 Figure 15: (a) Concealed Lightning Arrester (b) Ductile Iron Pole (c) Comparison of Lightning Arrester Models ........................................................................................................................................................37 Figure 16: (a) Raptor Clamp with LED Light (b) Swan Flight Diverter ....................................................38 Figure 17: APU Emergency Generator.......................................................................................................41 Figure 18: APU Staff During 2022 Community Meetings .........................................................................43 Figure 19: Mobile Neighborhood Utility Center ........................................................................................46 Figure 20: APU Annual Electrical Safety Training for Fire Cadets ..........................................................49 Figure 21: City of Anaheim Organizational Structure................................................................................50 Figure 22: 2023 WMP Incident and Performance Metrics .........................................................................52 4 Executive Summary - 2023
The City of Anaheim (Anaheim) Public Utilities Department (APU) places top priority on the safety and resiliency of the community we serve. The APU Wildfire Mitigation Plan (WMP) serves to establish methods and procedures utilized to construct, maintain, and operate APU’s electrical lines and equipment in a manner that will minimize the risk of APU assets being an original or contributing source of a wildfire. Safety of people and properties is one of the highest priorities in Anaheim, and the City Council and the City Manager’s Office support City departments in the development of integrated strategic plans and their cross-functional implementation. This 2023 WMP was developed in collaboration with the Anaheim Fire & Rescue Department (AF&R) to meet both local safety initiatives, as well to comply with state regulations.

In 2018 and 2019, state legislation was enacted under Senate Bill (SB) 901, which amended Public Utilities Code (PUC) Section 8387, and Assembly Bill (AB) 1054 which amended various PUC sections that further defined requirements to be included in local publicly-owned electric utility WMPs which are updated annually with a comprehensive revision not less than every three (3) years. This legislation also established the Wildfire Safety Advisory Board (WSAB) with the responsibility to review each utility’s WMP beginning in 2020 and provide advisory guidance opinions for improvements and future considerations in subsequent wildfire mitigation plans. APU incorporated these advisory guidance opinions as applicable within the 2023 WMP to build upon its initial foundation.

To increase the level of transparency and information accessibility for public review, the 2023 WMP, including previous year’ WMPs, Independent Evaluation Reports, and supplemental filings, as appropriate, have a prominent location and may be accessed on APU’s main website using the following link: https://anaheim.net/6099/Public-Utilities. This modification was made in response to comments by the WSAB to provide easier access to the WMP and related documents.

In 2022, Anaheim did not experience any wildfires; however, some wildfires occurred within close proximity in the broader Orange County area, including the Jim Fire which burned approximately 2,000 acres, the Coastal Fire which burned approximately 200 acres, and the Emerald Fire which burned approximately 154 acres. The Jim Fire was captured on the four (4) Anaheim regionally networked fire cameras via AlertCalifornia.org to assist both the Orange County Fire Authority (OCFA) and the local Metro Net Fire Dispatch to focus resources and assess risk of the fires moving towards more densely populated areas including Anaheim.

Anaheim installed one additional wildfire camera site with two cameras in 2022, bringing the total number of fire cameras to ten (10) within the Anaheim service territory. This additional camera views a Tier 3 Fire Threat Zone (FTZ) known as the Oak Canyon Nature Preserve, a 58- acre canyon adjacent to residential homes and a critical water treatment facility and reservoir, a key water source used by these two agencies to fight major fires including the Canyon 1 and 2 fires several years ago. The cameras have been instrumental in improving situational awareness and supporting fire response.

APU owns and operates 130.42 circuit miles of electric lines in the geographic locations considered FTZs, which are identified in Figure 4. Within the FTZs, 98% of those lines are underground, which substantially mitigates the potential for wildfires in Anaheim. The 5 remaining 2.63 miles of overhead lines are across 7 segments. APU applied for and received approval for $1.16 million of funding by the Federal Emergency Management Agency (FEMA) for an undergrounding design grant. The detailed design is complete and once easement activities are finalized, the full engineering package will be submitted to FEMA for review and consideration of construction grant approval in May of 2023. The construction phase of the project is planned for 2024 and 2025. In May 2021 APU undergrounded a 2,000-foot overhead circuit in a residential neighborhood within and adjacent to a Tier 3 FTZ named Deer Canyon.

Undergrounding this segment of line eliminated the need for APU to initiate any planned shutoffs for wildfire mitigation.

Climate-related factors contributing to wildfire risk are identified in the 2023 WMP as well as assistance offered to customers to prepare and protect properties using APU rebates, educational workshops, and resiliency programs including service lateral undergrounding. The 2023 WMP includes metrics on customer participation levels.

A transformer replacement program was initiated in 2021, focusing on replacement of overhead transformers over a five (5) year period based upon established criteria. Transformers in the FTZs are prioritized and replaced with FR3 fluid-filled transformers, beginning with the 2,000- foot undergrounding project recently completed in 2021. Eight (8) FR3 transformers were installed in 2021 in the Tier 1 FTZ. Twenty-three (23) FR3 transformers are planned to be installed by 2024/2025, to convert all of the OH facilities to underground within the FTZs. This will complete all remaining non-FR3 OH transformers in the FTZs. In addition to use of FR3 fluid in transformers, APU utilizes CAL FIRE exempt overhead protective devices1 that reduce the potential to start wildfires. These include use of twelve (12) sealed lightning arresters that prevent animals contacting the energized high-voltage section and installation of twelve (12) non-expulsion fuses that prevent any potential hot shards caused by blown fuses from falling on shrubs or grass below and causing fires. Further risk will be mitigated when these protective devices are replaced with pad-mount and subsurface equipment after the remaining overhead lines are converted to underground in 2024/2025.

The availability of proprietary utility equipment required to meet California wildfire mitigation goals can be a challenge for publicly owned utilities (POUs) when sourcing specialized components such as FR3 transformers, underground cable, and other wildfire mitigating equipment. APU is evaluating these supply chain challenges and initiating long lead material requests due to current and future supply chain constraints on the utility industry to strive towards the project completion goals detailed in this WMP.

Vegetation Management is a collaborative effort in Anaheim among APU, AF&R, who serves as the lead agency for Anaheim on wildfire mitigation, the Department of Public Works, who manages public right-of-way tree-trimming and performs vegetation management around electrical infrastructure, and the OCFA, who surveys for Invasive Shot Hole Borer Beetle (ISHB), Gold Spotted Oak Borer (GSOB), and other invasive pests threatening canyon areas.

Additional Vegetation Management measures include controlled burns for managing flammable re-growth and annually uses goats as an ecologically sensitive method for clearing wildgrass in canyon areas not easily accessible by equipment.
1 California Power Line Fire Prevention Field Guide, 2021 Edition, https://osfm.fire.ca.gov/media/3vqj2sft/2021- power-line-fire-prevention-field-guide-ada-final_jf_20210125.pdf 6 For ease of navigating the Anaheim 2023 WMP, Section 1(B) -Table 3- Elements Consistent with WSAB 2023 Guidance provides a summary list of comments from the 2023 WSAB Opinion and Guidance document and maps the location within the Anaheim 2023 WMP where the comment is addressed.

SECTION 1 - Introduction
A. Introduction
APU began providing electric utility services to the City of Anaheim in 1895. Anaheim’s population has grown to approximately 350,000 and there are 20,000 businesses located in the City. Anaheim is the 10th largest city in California and the only municipally-owned electric and water utility in Orange County. APU is governed by the Anaheim City Council who appoints a Public Utilities Board (PUB) that serves as an advisory body consisting of local residents to provide recommendations and reviews APU’s operations, finances, and conducts public hearings.

The following table provides a brief overview of the APU service area and topology.

Table 1: Anaheim Public Utilities Context-Setting Table Attribute APU
Service Territory Size 50 square miles
Owned Assets
☑ Transmission ☑ Distribution ☑ Generation
202 MW Electric Generation
14 Substations
18,184 Million Gallons (MG) of Water Production
763 miles of Water Distribution
920 MG Open Water Reservoir

35.75 MG Closed Water Reservoir
23 miles of Overhead Fiber Optic
111 miles of Underground Fiber Optic
Number of Customers Served 122,500 electric customer accounts 64,200 water customer accounts
Population Within Service Territory 346,842
Number of Accounts Share of Total Load (MWh)
Customer Class Makeup

83.53% Residential

0.76% Government

0.03% Agricultural

15.46% Small/Medium Business

0.22% Large Commercial/Industrial

26.87% Residential

4.78% Government

0.24% Agricultural

28.42% Small/Medium Business

39.69% Large Commercial /
Industrial
Service Territory
Location/Topography

86.42% Urban

8.96% Shrub

2.50% Herbaceous

1.00% Barren/Other

0.16% Agriculture

0.89% Conifer Forest

0.07% Water
7 Attribute APU
Service Territory
Wildland Urban Interface
(based on total area)

11.9% Wildland Urban Interface

1.7% Wildland Urban Intermix
Percent of Service Territory in
APU FTZs2
(based on total area)
 Includes maps
Tier 1 - Elevated: 7.6%
Tier 2: 0.6%
Tier 3: 13.9%
Prevailing Wind Directions &
Speeds by Season
Wind direction in Anaheim is most often from West for 9.3 and from East for 2.6 months, respectively, with an average wind speed of 2-14 mph Transmission Overhead: 1.23 miles, 18 Poles
Overhead Sub-Transmission: 28.12 miles, 838 Poles
Underground Sub-Transmission: 59.75 miles
Overhead Distribution: 385.74 miles, 16,311 Poles
Underground Distribution: 774.29 miles
Miles per circuit measured from APU GIS
Total APU Miles of Owned Lines
Underground and Overhead
See Section 1 (A) for Description of Assets
Miles of APU Lines in Tier 3 -
Extreme
Transmission Overhead: 0 miles, 0 Poles
Overhead Sub-Transmission: 0 miles, 0 Poles
Underground Sub-Transmission: 1.20 miles
Overhead Distribution: 0.88 miles, 27 Poles
Underground Distribution: 19.81 miles
Miles of APU Lines in Tier 2- Very
High
Transmission Overhead: 0 miles, 0 Poles
Overhead Sub-Transmission: 0 miles, 0 Poles
Underground Sub-Transmission: 59.75 miles
Overhead Distribution: 0.04 miles, 5 Poles
Underground Distribution: 0.85 miles
Miles of APU Lines in Tier 1 -
Elevated
Transmission Overhead: 0 miles, 0 Poles
Overhead Sub-Transmission: 0 miles, 0 Poles
Underground Sub-Transmission: 59.75 miles
Overhead Distribution: 1.71 miles, 65 Poles
Underground Distribution: 107.13 miles
No. of Substations within the FTZs 1 Substation – Tier 1 Customers have ever lost service
due to an IOU PSPS event?
☐ Yes
 No
Customers have ever been notified
of a potential loss of service due to
a forecasted IOU PSPS event?
☐ Yes
 No
Has developed protocols to pre-
emptively shut off electricity in
response to elevated wildfire risks?
 Yes
☐ No
Has previously pre-emptively shut
off electricity in response to
elevated wildfire risk?
☐ Yes
 No
2 See Section 5 for description of APU Fire Threat Zones 8 APU is a Participating Transmission Owner (PTO) with the California Independent System Operator (CAISO), is interconnected to the regional grid at 220 kilovolts (kV) by four Southern California Edison (SCE) owned and operated transmission lines and distributes power from its fourteen (14) substations through its 69kV sub-transmission system. The 12kV distribution system located throughout Anaheim distributes power through approximately 1,000 circuit miles of distribution lines. APU’s historic peak demand is 596 Megawatts (MW).

Anaheim is about 50 square miles and is divided into six Council Districts (see Figure 1). For the purpose of this WMP, the areas considered to be in the FTZs are only in District 6, or the eastern portion of Anaheim.

Figure 1 : Anaheim Service Territory and Council District Boundaries In 1990, the Anaheim City Council authorized an Underground Conversion Program to underground overhead lines along major thoroughfares, and in 2016 amended the program to expand the types of eligible projects that include reliability improvements such as wildfire safety.

To date, 139.2 circuit miles have been undergrounded throughout Anaheim service territory as a result of this program. APU also features the first fully underground substation in the United States that is located in District 6 that provides reliability, physical security, and operational benefits to the community. APU is also a full-service water utility and has its Walnut Canyon Reservoir, a 920 million gallon facility, in the eastern part of Anaheim that has been used extensively by water carrying aircraft during regional fires. As a customer-owned utility, APU emphasizes safety, reliability, and affordability in its daily operations and long-term investments. 9 B. Overview and Objectives
The primary goals of this WMP are to minimize the probability that APU-owned infrastructure is the contributing source of ignition of a fire and to improve resiliency of its electrical grid by incorporating methods and procedures to construct, maintain, and operate APU’s electrical lines and equipment safely. Any references throughout this WMP in regards to wildfire mitigation are efforts to minimize the probability that APU-owned infrastructure is a contributing source towards the ignition of a wildfire. The provisions set forth below outline the preventative strategies and actions for fire prevention and suppression activities and specific operational response during elevated fire and weather conditions to limit potential electric sources of fire ignition in the FTZ within APU’s service territory.

The Anaheim WMP was initially developed to meet the provisions mandated in Senate Bill (SB) 1028 (Hill), which became law in 2016 and requires all public utilities and private utilities and corporations to assess whether portions of the geographical area where the utility’s overhead electrical lines and equipment are located has a significant risk of a catastrophic wildfire resulting from those electrical lines and equipment and if so, present mitigation measures the utility intends to undertake to minimize that risk. In 2018, SB 901 (Dodd) was adopted which outlined the elements to be included when assessing the risks and formulating a wildfire mitigation plan.

Table 2 is a summary of the elements required within a SB 901 plan as compared to the elements included in this WMP.

Table 2: Statutory Cross References with SB 901 — Public Utilities Code Section 8387(b) Requirement Statute and Description Section
Number
Persons
Responsible
PUC § 8387(b)(2)(A): An accounting of the responsibilities of persons responsible for executing the WMP 9(D), 10, 12
Objectives of
the Plan PUC § 8387(b)(2)(B): The objectives of the WMP 1 Figure 2: (a) Park Substation (b) Walnut Canyon Reservoir during Canyon Fire 2 10 Requirement Statute and Description Section
Number
Preventative
Strategies
PUC § 8387(b)(2)(C): A description of the preventive strategies and programs to be adopted by the POU to minimize the risk of its electrical lines and equipment causing catastrophic wildfires, including consideration of dynamic climate change risks. 3, 7, 8, 9, 10
Evaluation
Metrics
PUC § 8387(b)(2)(D): A description of the metrics the POU plans to use to evaluate the plan’s performance and the assumptions that underlie the use of those metrics.
13 Impact of
Metrics
PUC § 8387(b)(2)(E): A discussion of how the application of previously identified metrics to previous wildfire mitigation plan performances has informed this plan.
13 De-Energization
Protocols
PUC § 8387(b)(2)(F): Protocols for disabling reclosers and de- energizing portions of the electrical distribution system that consider the associated impacts on public safety, as well as protocols related to mitigating the public safety impacts of those protocols, including impacts on critical first responders and on health and
communication infrastructure.
9(B), 9(D)
Customer
Notification
Procedures
PUC § 8387(b)(2)(G): Appropriate and feasible procedures for notifying a customer who may be impacted by the de-energizing of electrical lines. The procedures shall direct notification to all public safety offices, critical first responders, health care facilities, and operators of telecommunications infrastructure with premises within the footprint of potential de-energization for a given event. 9(D), 10
Vegetation
Management
PUC § 8387(b)(2)(H): Plans for vegetation management. 8(A) Inspections PUC § 8387(b)(2)(I): Plans for inspections of POU’s electrical infrastructure. 8(B)
Prioritization of
Wildfire Risks
PUC § 8387(b)(2)(J): A list that identifies, describes, and prioritizes all wildfire risks, and drivers for those risks, throughout POU’s service territory. The list shall include, but not be limited to, both the following:
i. Risks and risk drivers associated with design, construction, operation, and maintenance of POU’s equipment and
facilities
ii. Particular Risks and risk drivers associated with topographic and climatological risk factors throughout the different parts of POU’s service territory.
4 11
Requirement Statute and Description Section
Number
CPUC Fire
Threat Map
Adjustments
PUC § 8387(b)(2)(K): Identification of any geographic area in POU service territory that is a higher wildfire threat than is identified in a California Public Utilities Commission (CPUC) fire threat map, and identification of where the CPUC should expand a high fire threat district based on new information or changes to the environment.
5 Enterprise Risk PUC § 8387(b)(2)(L): A methodology for identifying and presenting enterprise-wide safety risk and wildfire-related risk. 2 Restoration of
Service
PUC § 8387(b)(2)(M): A statement of how the POU will restore service after a wildfire. 9(D), 10
Monitor and
Audit
PUC § 8387(b)(2)(N): A description of the processes and procedures the POU shall use to do all of the following:
i. Monitor and audit the implementation of the WMP
ii. Identify any deficiencies in the WMP or its implementation, and correct those deficiencies
iii. Monitor and audit the effectiveness of electrical line and equipment inspections, including inspections performed by contractors, that are carried out under the plan, other applicable statutes, or commission rules.
13, 14
Qualified
Independent
Evaluator
PUC § 8387(c): The local publicly owned electric utility or electrical cooperative shall contract with a qualified independent evaluator with experience in assessing the safe operation of electrical infrastructure to review and assess the comprehensiveness of its wildfire mitigation plan. The independent evaluator shall issue a report that shall be made available on the Internet Web site of the local publicly owned electric utility or electrical cooperative, and shall present the report at a public meeting of the local publicly owned electric utility’s or electrical cooperative’s governing board. 14 As further required by AB 1054 (Holden) enacted in 2019, POUs shall submit annual updates of their wildfire mitigation plans to the WSAB with comprehensive revisions at least once every three (3) years thereafter. After the submission of its WMP, and upon review by the WSAB, who subsequently issues an advisory opinion, APU reviews the recommendations from the WSAB and incorporates them if deemed relevant. All Anaheim WMPs submitted to the WSAB and the Independent Evaluation report are posted on APU’s WMP webpage for public access from the APU homepage: http://www.anaheim.net/5487/Wildfire-Mitigation-Plan.

In November 2022, the WSAB published its Guidance Advisory Opinion for the 2023 Wildfire Mitigation Plans of Electric POUs and Rural Electric Cooperatives. The Guidance included 21 12 recommendations that are summarized in Table 3 - Elements Consistent with WSAB 2023 Guidance and incorporated into APU’s 2023 WMP.

The WSAB also provided a revision template for updating wildfire mitigation plan formats if POUs had not previously developed their own wildfire mitigation plan format. APU reviewed and considered the proposed WSAB revision template and determined that the existing APU WMP format provides information that exceeds the section format in the WSAB revision template, and that it is more advantageous for readers and stakeholders of this WMP to maintain a format that is consistent with previous APU WMPs. However, key elements from the WSAB revision template are incorporated into this WMP as detailed below:
1) Objectives of the WMP;
2) A Fire Threat Assessment including location and weather condition warnings; 3) Identification of utility assets located in FTZs;
4) Identification of key wildfire risks and risk drivers; 5) A description of the preventative strategies and programs adopted to minimize the risk of APU electrical lines and equipment causing catastrophic wildfires including vegetation management, system inspection, operational strategies, and construction standards; 6) A description of the factors used to determine when it may be necessary to de-energize electrical lines and deactivate its reclosers;
7) A description of the metrics used to evaluate annual and historical WMP performance and discussion of how to use performance metrics to enhance ongoing Plans; 8) An accounting of the responsibilities of persons responsible for executing the WMP; 9) Monitoring and audit provisions that support implementation of the WMP, and identifying any deficiencies or areas for improvement;
10) Ongoing monitoring and audit of the effectiveness of electrical line and equipment inspections; and
11) A description of community outreach and education, covering communication about wildfire prevention, utility wildfire mitigation efforts and strategies, and potential de- energization and re-energization practices.

Going forward, it is anticipated that the WSAB will review the updated wildfire mitigation plans annually and provide additional recommendations attributed to all POUs and also include comments specific to each individual POU. APU reviews the WSAB annual Guidance recommendations, incorporates additional information in the APU WMP to address these recommendations as applicable, and compiles Table 3 below to identify the relevant sections within APU’s WMP. This WMP represents the combined effort of the POU industry associations to further the development of a template to respond to the WSAB’s Guidance in future reporting wildfire mitigation plan cycles. APU is an active participant in the California Municipal Utilities Association (CMUA) wildfire working groups and continues to support and work with the CMUA and WSAB to streamline future wildfire mitigation plan requirements for POUs.
13 Table 3: Elements Consistent with WSAB 2023 Guidance Category WSAB Recommendation APU WMP Section
General Comments, Reporting, and Staffing
A. Reporting Based on Threat
Level
The WSAB invites the POU
representative organizations to work
with us and develop an approach to
streamline the WMP requirements for
POUs with low likelihood of
wildfires.
1(B)
POUs with no overhead assets within
or abutting high wildfire threat areas
should consider whether the specific
topics listed in PUC Section
8387(b)(2) are necessary to include in
each annual WMP that they develop
and file with the WSAB.

N/A
POUs with no overhead assets within
or abutting high wildfire threat areas
should consider whether hiring an
Independent Evaluator is necessary
for the annual updates between
comprehensive revision WMPs and
when hiring an Independent
Evaluator is reasonable, such as when
the utility’s wildfire circumstances
substantively change.

N/A
B. Comprehensive Revision
and Revision Template
POUs should consider using the
WSAB proposed comprehensive
revision template described herein for
their 2023 WMPs.
1(B)
POUs that have not used the previous
CMUA template because they have
developed their own comprehensive
WMP formats may continue that
practice, while including the context-
setting template and statutory cross-
reference table.
1(B), Table 1, Table
2 Refer back to the 2022
recommendations along with those
for 2023 provided below for
preparation of next year’s WMPs.
1(B)
C. Metric Development and
Evaluation
Adopt thoughtful, relevant metrics
that appropriately reflect the
significant variation in circumstances
among POUs, including size,
location, and asset situation or type.
13 14
Category WSAB Recommendation APU WMP Section
D. Independent Evaluations Procure IE for a review of the 2023 comprehensive revision WMPs and
the IE to provide an analysis that
goes beyond simply documenting
compliance with the statute to
recommend wildfire mitigation
changes or improvements that will
improve the wildfire risk profile of
the utility.
14 Documentation of IE
recommendations, WMP changes,
and IE acceptance of those changes
as adequate for the current WMP.
14 Grid Assets, Operations and Inspection
Evaluate asset management
programs, including examining
legacy equipment issues.
3 Describe grid design and system
hardening programs.
6, 8, 9
Identify and assess those assets that
would not be directly subject to the
protocols of the CPUC’s GO 95 due
to their construction prior to the GO
first being adopted.
8(E)
The WSAB recommends POUs
consider the pre-staging of utility
personnel at clearing points during
de-energization event.
10(B)
Risk Assessment and Climate Mapping
Identify cost-effective risk
assessment tools to help focus
wildfire mitigation activities.
2, 3
Understand and incorporate climate
change data in risk assessments and
wildfire mitigation decision making
and prepare for these changes
proactively rather than reacting to
them as they happen.
3, 4
Vegetation Management
Explore the risks of widespread
invasive annual grasses that extend
across the State.
8(A)
Investigate mitigation methods to
avoid the development of potentially
risky grasses in cleared areas.
8(A)
15 Category WSAB Recommendation APU WMP Section
Focus on ecologically relevant
replanting and avoid the short-run
simple practice of relying on greater
clearances.
8(A)
Community Communication and Outreach
Include information in WMPs about
how POUs and their customers and
community minimize wildfire
impacts through backup power
resources.
9(D)
WSAB Advisory Guidance Specific to Anaheim Public Utilities 2022 WMP Submittal WSAB encourages development of a
more easily found track to the WMP
information from the main Anaheim
web page.
1(B)
Clarify in the future what is meant by
the term “brush” – some brush such
as chaparral when abated can be
replaced by more flammable invasive
grasses.
5 The WSAB would like to understand
the source of information about the
approximately 10 species of trees
responsible for 75% of fire ignitions
in California.
8(A)
To implement the APU 2023 WMP, a matrix identifying persons responsible for executing the WMP, resources utilized to assess field conditions when elevated fire and weather indicators reach certain thresholds, and education and training for field personnel, stakeholders, and the public is located in Section 13. Finally, metrics using historical and incident driven data measure the effectiveness of the mitigation efforts and drive future enhancements. 16 SECTION 2 - Enterprise-Wide Safety Risk Assessment
There are various methods to evaluate risk, and APU follows the Committee of Sponsoring Organizations of the Treadway Commission (COSO) Enterprise Risk Management - Integrated Framework. Similar to the risk management standards established by the International Organization of Standardization (ISO) 31000, the purpose is to identify and manage potential enterprise and safety risks, including those associated with electrical infrastructure igniting or contributing to a wildfire, that could threaten the community, interrupt core business functions, and threaten business continuity or impact recovery.

APU’s enterprise risk management framework begins with an organizational structure ranging from Elected and Appointed Officials, Executive Management, Division Managers, and Subject Matter Experts (Risk Owners) who identify credible and foreseeable threats utilizing industry experience, and accounting for APU’s unique characteristics and safety assessments. Similar to the “bowtie” method (see Figure 3) for identifying where new or enhanced controls may be worthwhile, a repository of identified risks (see Table 4) are prioritized based on consequence to the business enterprise and frequency of occurrence. For each risk, mitigation plans are established, with a Risk Owner identified to oversee implementation and progression of the mitigation measures, and a member of the senior management team who is held responsible and accountable for the risk.

Ongoing efforts of reviewing and revising the risks as new threats evolve keep this process dynamic. APU measures and monitors the effectiveness of the mitigation efforts through various means including the agency-level Utilities Success Indicator report. Examples of safety and wildfire risks include loss of electric service to critical infrastructure, loss of communication connectivity, impacted roadways limiting access to FTZ areas and facilities, and regional grid emergency shut-off events.

Risk drivers related to wildfire potential for electric utilities commonly focus on operational and/or electrical infrastructure, vegetation, resource coordination, and the resulting loss of power to critical facilities. These internal factors are addressed with strategies to mitigate the risk within the APU 2023 WMP. Other risk drivers, including natural elements such as climate change and weather conditions are global and require a dynamic approach using forecasting tools to manage the risk.

SECTION 3 - Overview of Risks and Risk Drivers Related to Wildfires As previously mentioned, a repository of wildfire-related risks from utility operations and/or equipment sparking a wildfire were identified and prioritized based on the threat to the community, core business impact, consequences, and risk mitigation path. The “bowtie” method in Figure 3 illustrates this process.
17 Figure 3: Wildfire "Bowtie" Risk Mitigation Chart
Wildfires
involving APU
Equipment
Potential
Consequences
Im
pa
ct
s
Key Risk
Drivers/Triggers
Ca
us
es
Table 4 summarizes the analysis conducted to identify APU’s exposure and impacts from a wildfire and to identify current controls and mitigations to reduce the significant risk of a wildfire occurring. It is important to note that the below listed potential risk drivers/triggers are an indication that a risk event could occur, but do not necessarily reflect actual conditions or threatened conditions.

Table 4: Risk Mitigation for Wildfire Ignition
Risk- APU Equipment including Third Party Attachment Igniting a Wildfire Potential Drivers Description of Driver Mitigation Measures and Programs Topology Wildland areas and steep
terrain with exposure to
overhead power lines.
• Vegetation Management
• Construction Standards
• Water infrastructure reliability
improvements to help protect homes near
wildland areas
• Ensure availability of water in Walnut
Canyon Reservoir for water aircraft
support
• Patrols of utility equipment and
structures
Elevated wildfire
conditions
High winds and other weather
conditions plus topology more
conducive to the spread of
wildfire.
• Construction Standards
• Disable Reclosers
• Wildfire Cameras
• Weather Stations
• Pole Loading
• Threat Level Communications and Public
Outreach
Climate Change Expanding FTZs and more
extreme weather conditions
caused by extended drought
seasons and lack of early fall
rains.
• Inventory Assessment in the FTZs
• Vegetation Management
Contact by a
foreign object
Vegetation, metallic balloons,
avian, vehicle accidents, for
• System Inspection
• System Patrols
18 Risk- APU Equipment including Third Party Attachment Igniting a Wildfire Potential Drivers Description of Driver Mitigation Measures and Programs example, coming into contact
with APU overhead electric
facilities.
• Vegetation Management
• Construction Standards
• Avian Deterrents
• Conductor Spacing
• Undergrounding
Failure of
Equipment
Electrical equipment
containing flammable
material or potential for
arcing when operated in a
FTZ.
• System Inspection
• System Patrols
• Transformer replacement
Downed
Conductors
including Third
Party attachments
Energized electrical wires
falling and coming into
contact with wild grass, brush,
and other vegetation below.
• System Inspection
• System Patrols
• Reclosers Blocking
• Vegetation Management
• De-Energize Equipment
• Undergrounding
Energized lines
coming into
contact with each
other
Multiple energized lines in
contact with each other
creating arcing and sparking
in dry conditions.
• Construction Standards
• Conductor Spacing
• De-energize Equipment
• Undergrounding
Operational
Procedures
Automatic operations to re-
energize a line after an
interruption or programmable
settings that de-energize
during specific conditions.
• Disable Reclosers
• De-Energize Lines for Wildfire
Mitigation
• Notification to AF&R emergency
operations to determine necessity of
activation of local Emergency Operations
Center (EOC) and establishment of
incident command
• Evacuation Assessment
• Initiate citywide communications and
public outreach
• Staffing of 311 Call Center to assist with
customer inquiries
Lack of
Coordinated
Response
When ignition is identified, a
well-coordinated response to
suppression and de-energizing
lines to limit progression of
the fire.
• Customer Support and Emergency
Response coordination with local and
regional first responders
• Coordination with SCE
• Staffing of EOC and inter-departmental
collaboration on traffic, emergency
management, and communications
19 The potential consequences if the risk drivers listed above were to occur and resulted in an incident, in a “worse-case-scenario”, could include:
 Personal injury or fatalities to the public, employees, and contractors  Damage to real and personal property
 Damage and loss of City of Anaheim owned assets and facilities  Reliability impacts
 Reputational damage
 Claims and litigation.

As an overview of the 2023 WMP, the preventative strategies discussed further in this WMP are mapped to these potential risk drivers in Table 5 and placed in one or more of the following categories: (1) Situational Awareness, (2) Design and Construction, (3) Inspection and Maintenance, (4) Operational Practices, and (5) Response and Recovery.

Table 5: Categorization of APU Potential Wildfire Risk Drivers and Corresponding Preventative Strategy
Risk Driver Categorization Assessment/ Preventative
Strategy Sections
Topology Situational Awareness 5, 6
Elevated Wildfire Condition Situational Awareness 5, 6, 7 Climate Change Situational Awareness 4
Contact by Foreign Object Design & Construction 8(E)
Equipment Failure Design & Construction /
Inspection & Maintenance
8(B-D), 9(A)
Downed Conductors including
Third Party attachments
Design & Construction /
Inspection & Maintenance
8(B-D), 9(A)
Energized lines contact together Design & Construction / Inspection & Maintenance
8(C-D)
Operational Procedures Operational Practices 9(A-E)
Lack of Coordinated Response Response & Recovery 10, 11, 12 SECTION 4 - Dynamic Climate Change
According to the U.S. Environmental Protection Agency (EPA), the United States average temperature has risen by 0.5 degrees Fahrenheit over the past century and is projected to rise another 3 to 12 degrees Fahrenheit over the next one hundred (100) years3. Although these increases are seemingly small changes to the climate, this increase in temperature could result in potentially dangerous shifts in climate and weather. Recorded impacts of the changing climate to the Earth’s atmosphere include rain and snowfall patterns that are shifting and changing with 3 United States Environmental Protection Agency, https://climatechange.chicago.gov/climate-change-science/future- climate-change
20 more extreme weather patterns starting to become more frequent, resulting in increased floods, droughts, or intense rain, as well as more frequent and severe heat waves. Data from National Oceanic and Atmospheric Administration (NOAA) shows increases in observed sea level rise around the United States and globally. The impacts of climate change can be categorized as economic, environmental, or social.

Economic impacts could result when residences and businesses in the FTZ lose their ability to afford rising fire insurance premiums or cancellation of policies, which in Anaheim includes approximately 6,439 structures with heightened exposure to wildfires. The cost for resilient infrastructure, increased labor and maintenance within the FTZ could increase operation and maintenance expenditures for utilities.

Wildfires may impact the local environment, including increased potential for flooding from the loss of trees and vegetation to stabilize hillsides. Prolonged periods of drought will likely result in a prolonged fire season, potentially year-round. Climate change impacts may result in FTZ area expansion from the higher into lower elevation wildlands and canyons. The majority of wildland and canyons in Anaheim have been designated as Tier 3 FTZ (see Figure 4: Anaheim Public Utilities Fire Threat Map) and overhead electrical infrastructure within the FTZs have been identified in this WMP along with mitigation strategies.

Social impacts involve public safety and the potential devastation from lives or homes being lost during extreme wildfires. The Canyon Fire 2 in October 2017 did not result in any fatalities; however, there were 14 homes destroyed, 44 homes damaged, thousands of people evacuated, and over 9,000 acres burned from the wind-driven event that was initiated by remaining embers from a previous brush fire. As a result, the Anaheim City Council supported certain fee waivers and accelerated permitting to assist homeowners with restoring their lives.

APU is actively evaluating the impacts of climate change on its service territory and probability of wildfire ignition. APU includes a Tier 1 – Elevated FTZ, detailed in Section 5, as a monitored area for wildfire activity to continually evaluate any conditions that may affect the likelihood of wildfires. Operational procedures are in place to maintain water levels in the Walnut Canyon Reservoir to accommodate fire-fighting aircraft. APU and AF&R evaluate environmental and climate conditions annually and on as-needed basis to review impacts to APU territory and to propose modifications to future APU WMPs and operational practices.

SECTION 5 - Assessment of High Fire Threat in APU’s Electric Service Territory
A statewide fire threat map was developed to delineate the boundaries to identify, evaluate, and adopt stricter fire-safety regulations that apply only to overhead power lines, electric equipment, and communications lines located within those boundaries. The map was developed by a peer group of utility personnel and fire safety professionals known as the Peer Development Panel (PDP) with the oversight by an Independent Review Team (IRT) appointed by the California Department of Forestry and Fire Protection (CAL FIRE) and the California Public Utilities Commission (CPUC).
21 The 2018 CPUC High Fire-Threat District (HFTD) map designates Tier 2 and Tier 3 high fire- threat areas, and the 2022 Cal-Fire Fire and Resource Assessment Program (FRAP) map designates Very High Fire Hazard Severity Zones (VHFHSZ). The APU Fire Threat Map identifies Tier 2 – Very High and Tier 3 - Extreme FTZs that aligns with the CPUC HFTD Tier 2 and Tier 3 boundaries. The APU Fire Threat Map additionally includes a Tier 1 – Elevated designation that aligns with the CAL FIRE VHFHSZ boundary. Tier 1 – Elevated is not identified by the CPUC HFTD map. Due to the proximity to the Tier 2 and Tier 3 FTZs, Tier 1 – Elevated is included in the APU Fire Threat Map as a monitored area for wildfire activity to continually evaluate any conditions that may affect the likelihood of wildfires.

APU and AF&R, with outreach to SCE and the OCFA, developed the Anaheim FTZ boundaries identified in Figure 4 - Anaheim Public Utilities Fire Threat Map. APU and AF&R review the map annually and on an as-needed basis to address any changes to the FTZs. The map was established based on criteria for FTZ tiers listed in Table 6.

Figure 4: Anaheim Public Utilities Fire Threat Map

22 Table 6: Tiered Fire Threat Zones in Anaheim
Zone Description
Tier 3 - Extreme Areas where there is an extreme risk, including likelihood and potential impacts on people and property, from utility related wildfires, typically wildland areas where topography, historical wind speeds, the availability of water resources, and emergency responder circulation routes affect response times to combat wildland fires.

Tier 2 – Very High Areas where there is a very high risk, including likelihood and potential impacts on people and property, from utility related wildfires due to vegetation.

Tier 1 - Elevated Areas where there is an elevated risk, including likelihood and potential impacts on people and property, from utility related wildfires. Areas are well developed and have access to fire hydrants, with roadways that are accessible to fire and utility personnel.

Topography has a considerable effect on wildland fire behavior and on the ability of fire fighters and their equipment to take action to suppress wildland fires. Due to topography, a fire starting at the bottom of a canyon may expand quickly to the ridge top before initial fire responders can arrive. Rough topography greatly limits road construction, road standards, and accessibility by ground equipment.

A relatively large portion of East Anaheim is covered by natural vegetation. Of these different vegetation types, coastal sage shrubs, chaparral, and grasslands reach some degree of flammability during the dry summer months and, under certain conditions, during the winter months. For example, as chaparral gets older, twigs and branches within the plants die and are held in place. A stand of brush 10 to 20 years of age, such as shrubs, vegetation or prunings where the diameter is not greater than three inches at the widest point, usually has enough dead material to produce fire spread rates about the same as in grass fires when the fuels have dried out. In severe drought years, additional plant material may die, contributing to the fuel load.

There will normally be enough dead fuel that has accumulated in 20- to 30-year-old brush for fire spread rates to be about twice as fast as in a grass fire. Under moderate weather conditions that produces a fire spread rate of one-half foot per second in grass, a 20- to 30-year old stand of chaparral may have a fire spread rate of about one foot per second. Fire spread rates in old brush (40 years or older) has been measured at eight times as fast as grass, at about four feet per second. Under extreme weather conditions, the fastest fire spread rate in grass is 12 feet per second or about eight miles per hour. Anaheim is relatively flat with the exception of the eastern portion of Anaheim where the Wildland Urban Interface (WUI) presents greater risk of wildfire.

To manage surface fuel in the FTZs, AF&R manages the Brush Abatement Program, which is detailed in Section 8 (A) Vegetation Management.

Within Anaheim’s boundaries there are four Tier 3 FTZ areas; these areas are exposed, generally steep north facing slopes with coastal sage shrubs and mixed chaparral. Tier 3 contains one (1) normally-deenergized 12 kV overhead segment totaling approximately 0.88 miles. There are also seven (7) segments of 12 kV overhead line in Tier 1 - Elevated and adjacent to Tier 2 FTZs 23 totaling approximately 1.75 miles. These remaining overhead segments in FTZs are planned for undergrounding in 2024 and 2025, see Section 8 (C) Undergrounding Power Lines for additional information regarding planned underground project scope.

Also located within the FTZs are SCE’s high voltage overhead 500 kV transmission lines which serve as one of several interconnection paths for Anaheim to the regional power grid. SCE is subject to regulatory oversight by the Office of Energy Infrastructure Safety (OEIS) and California Public Utility Commission (CPUC), who review and approve SCE’s wildfire mitigation plan respectively to address its transmission assets, including the areas that pass- through Anaheim. APU coordinates with SCE on situational awareness of fire conditions, as well as operational activities that may include SCE de-energizing the high voltage transmission lines.

The impact to APU is mitigated since there are multiple transmission lines that serve Anaheim. 24 SECTION 6 - Overview of Preventative Strategies and Programs Table 7: Preventative Strategies and Programs
Situational/Conditional Awareness
Collaboration with AF&R, Fire Safe Councils and OCFA in preparation for RFW and SAWTI events Fire cameras installed in Anaheim’s FTZs and connected to the regional network AlertWildfire.org Weather monitoring stations installed in FTZ and network access for local weather station data Training for AF&R Dispatch Center and APU Operators in fire camera view and operations Daily monitoring and reporting of elevated fire weather conditions including RFW and SAWTI On-site visual inspection by APU troubleshooter and CERTS during elevated conditions Training for APU Operations on Disabling Reclosers
Training for APU Operations on De-energize/Restore protocols and communications Design and Construction
Modified Construction Standards for FTZ
Wood to Ductile Iron pole replacement
Concealed lightning arrester replacement
Insulated covers on equipment mounting brackets
Increase overhead wire spacing
Increased wind loading for pole strength and integrity
Installation of avian diversion equipment
Expulsion-proof fusing
Undergrounding electric lines in FTZ
Inspection and Maintenance
Vegetation Management- Line Clearance
Surface fuel management
Vegetation tracking and recording
Detailed distribution overhead and underground lines and infrared thermography inspections Distribution wood pole intrusive testing
Visual inspection and infrared thermography of distribution substations Substation equipment oil sampling
Operational Practices
Overhead Distribution line patrols
Disable reclosing during RFW and SAWTI Extreme conditions Independent fiber-optic communication network
Response and Recovery
Wildfire Mitigation Response Procedures - Operation and communication protocols including emergency shut- off
Communication strategy for de-energize/restore response Emergency Response planning for Stakeholder support during an outage Field Operations recovery procedures
Post event customer support and protection services
Modifications to policies, practices, and procedures
Waiver of electric and water service connection fees
Waiver of electric and water design/engineering, plan checks, and inspection fees Impacted customer payment extensions, payment plans
Irrigation controllers provided at no cost to extend longevity of landscaping 25 SECTION 7 - Situational Awareness
In Southern California, the period for active fire conditions can exist year-round; however, conditions contributing to a higher risk of a fire igniting and spreading is attributed to the amount of dry fuel sources, high winds, low relative humidity, and dry lightning conditions. APU collaborates with multiple stakeholders including, but not limited to: AF&R; APU’s Water Division; the National Weather Service (NWS); and adjacent electric utilities including SCE and San Diego Gas and Electric (SDG&E) to leverage situational awareness. Additionally, APU utilizes the camera networks, web-based real-time monitoring data from local weather stations, and fire condition warning systems that gauge fire threat conditions so that APU can mobilize personnel and take specific actions to mitigate a higher fire threat.

AF&R provides daily assessment of conditions classified as Normal, Elevated, Extreme, and Red Flag Warning conditions for mountainous (East Anaheim) areas. Additionally, APU’s in-basin generation report is issued daily to operators, which includes the AF&R conditions classifications for heightened awareness of all APU staff. A Red Flag Warning (RFW) is issued by the NWS for weather events which may result in extreme fire behavior that will occur within 24 hours. A RFW is typically issued when relative humidity is at or below fifteen percent (15%) and sustained winds are expected to reach twenty-five (25) miles per hour (mph) or higher and/or wind gusts exceed thirty-five (35) mph for six (6) or more hours. Also, lightning under dry conditions may trigger a RFW. Anaheim is located within the CAZ554 region and monitors RFW events for the Orange/Inland Empire. At the onset of a RFW for the mountainous areas, AF&R notifies APU and AF&R deploys fire watchers for on-site assessment of conditions.

In conjunction with the RFW, another early warning system is the Santa Ana Wildfire Threat Index (SAWTI), which was developed through collaboration with Cal-Fire, UCLA, the United States Forest Services (USFS), NWS, SDG&E, and the Desert Research Institute. The SAWTI classifies fire threat potential from No Rating, Marginal, Moderate, High, and Extreme based on the likelihood of a catastrophic wildfire fueled by high winds. High winds contribute to increased dry fuel source, but also can cause power lines to come into contact with each other and produce a spark which potentially can cause a fire ignition. APU monitors and reports the SAWTI for Zone 2 - Orange/Inland Empire on a daily basis to key personnel.

Weather forecasts and weather indexes are early-warning tools to proactively prepare for critical fire weather conditions; however, real-time monitors track the changing dynamics of these conditions and can inform key decisions impacting response times. High-resolution cameras and weather stations are utilized in Anaheim for this purpose. AF&R and APU jointly evaluated a regional network of fire cameras that is being deployed in the FTZ to provide high-resolution video, near-infrared capabilities, and the ability to zoom into areas to identify ignition points more quickly. Because wildfires can spread rapidly in windy and dry conditions, the ability to recognize and respond expeditiously can make a significant difference in saving lives and properties.

AF&R and APU joined with University of California San Diego-Scripps (UCSD) to become part of this regional network of fire cameras and to include locations in Anaheim through an agreement approved by the Anaheim City Council on May 14, 2019. This allows access to the larger regional system that spans the state of California. This regional network is owned and managed by UCSD-Scripps, with network partnerships including SDG&E, SCE, OCFA, and 26 CAL FIRE. This network provides AF&R Dispatchers and APU Operators with the ability to view camera images and provides additional capabilities to AF&R to remotely control the cameras and more quickly verify an ignition while environmental conditions are being monitored in real time. AF&R can more quickly validate 911 calls reporting a fire by first using the cameras and then deploy the necessary resources based on the visual information. These cameras are now part of the Alertwildfire.org regional public access network of high-resolution cameras used by fire agencies as a topographical visual tool for scouting fires.

The link for public access of regional network of fire cameras is: AlertCalifornia.org.

Figure 5: AlertCalifornia.org Portal
Figure 6: High Resolution Camera Installation and Camera Image Overlooking Anaheim

27 Figure 7: Anaheim Camera Image of 91/241 Freeway Interchange Anaheim has strategically placed one of its Pan-Tilt-Zoom (PTZ) cameras to capture real-time situational awareness in Gypsum Canyon, the originating location of the 2017 Canyon Fire 2.

This camera was recently used by AF&R Dispatch to visually capture movement of the 2021 Blue Ridge Fire. A second camera was installed at a substation to provide a different easterly vantage point. Cameras at two (2) additional locations facing south were installed and visually captured progress of the Orange County 2021 Silverado Fire.

In 2022, APU installed temporary facilities for an additional site with two cameras to overlook Oak Canyon, a FTZ within a residential area. Permanent facilities to house the camera and networking equipment was completed in November 2022.

In 2023, cameras at two (2) locations will be installed overlooking the Gypsum and Weir Canyon areas, both within a Tier 3 FTZ. These sites will require the installation of camera infrastructure and over ten thousand (10,000) feet of fiber optics extension and networking equipment to connect camera control and video through the AlertCalifornia - Home system and with coordination through UCSD Scripps Institute.

There are five (5) locations where ten (10) cameras are installed, with two (2) additional planned locations for four (4) more cameras. The fourteen (14) total installed and planned camera locations are depicted under Figure 8 below.
28 Figure 8: Camera Locations in Service and Planned by APU to View Anaheim FTZs Weather stations that measure 10-minute intervals that can include temperature, wind speed, wind conditions, and humidity levels are located at APU’s Clair, Lewis, and Fairmont Substations, Lenain Water Treatment facility, Oak Canyon, and the Linda Vista pumping station in East Anaheim. The data is used by AF&R and APU to direct resources and make operational decisions based on the measured peak wind gust, as detailed in Section 10 (D) and 10 (E). In addition to the fire camera network, a network of local weather station data is publicly available through the NWS, NOAA Weather, and Hazards Data Viewer. Within Anaheim, there are six (6) weather stations through partnerships with SCE, the California Air Resources Board (CARB), and the Citizen Weather Observer Program (CWOP). Weather station data for each APU site is accessed online using Microsoft’s Power BI software, shown in Figure 9, including access to trending and historical data.
29 Figure 9: APU Power BI Dashboard
The AlertCalifornia – Home network cameras and weather stations are monitored by the AF&R Dispatchers and utilized as another real-time data source for monitoring fire threat conditions, and where appropriate, warrant APU operational actions that are discussed in this WMP. The fire cameras proved to be very useful to AF&R in October 2019 during the Contempo Fire that ignited in the FTZ in East Anaheim, south of the 91 freeway near Coal Canyon. The cameras were used to help verify ignition, direct aircraft, and position ground crews to keep the wildfire from spreading and was contained to only 5 acres. Figure 10 below depicts the image captured by AF&R Dispatch of that wildfire from the cameras. More recently, the cameras allowed the tracking of the 500-acre Jim Wildfire on March 2, 2022 in the Cleveland National Forest in eastern Orange County, with the camera image captured under Figure 11 below. 30 Figure 10: Anaheim Camera Image of Contempo Wildfire on 10-26-2019

Figure 11: Anaheim Camera Image of Jim Wildfire of 3-2-2022

31 SECTION 8 – Preventative Strategies for Building Infrastructure Resiliency The goal of a wildfire mitigation plan is to minimize the risk of electric infrastructure being a contributing factor to the ignition of a wildfire. A prudent approach is taken to consider and, where appropriate, implement changes and improvements to physical infrastructure that are practical preventative measures in construction and maintenance practices to meet that goal.

APU utilizes established guidelines and industry best practices for safe design and construction of its electric system, using resources such as the CPUC General Orders (GOs). GOs outline safe clearances, integrity of construction, and maintenance requirements to achieve a level of infrastructure resiliency to withstand elevated to extreme environmental conditions.

A. Vegetation Management
For the safety and reliability of service where overhead conductors traverse trees and vegetation, APU performs vegetation management activities consistent with the guidelines outlined in GO 95 – Rules for Overhead Electric Line Construction, Section III – Minimum Allowable Clearances – Case Number 14 Extreme and Very High Fire Threat Zones in Southern California, to establish necessary and reasonable clearances between the vegetation and the energized conductors in FTZs. GOs are technical requirements established by the CPUC for investor- owned utilities and are utilized by APU as best industry practice for utility operation and construction.

Dead or rotten trees and brush at risk of falling into energized conductors are inspected, identified, and removed as recommended by the Certified Arborist and Certified Power Line Clearance Tree Trimming Supervisor on staff with Anaheim, who oversees the vegetation management contractors. Tree health is assessed as a part of inspections and include a 360- degree, ground-based visual inspection of the tree crown, trunk, trunk flare, above ground roots and branch and stem defects, drilling evaluation of target risk, increment boring, probing, sounding, sub-surface root and soil assessment, root collar excavation, and site conditions around the tree in relation to targets. All work is performed in accordance American National Standards Institute (ANSI) A300 (Part 9) – 2017 Tree Risk Assessment Tree Failure and the companion publication Best Management Practices: Tree Risk Assessment 2nd edition, as well as the Utility Best Management practices tree risk assessment and abatement for fire prone states and provinces in the western region of North America, as adopted by the Utility Arborist Association. Property owners are informed of any tree clearing activities prior to the commencement of work. APU contractors perform power line clearance tree trimming for approximately 13,000 trees annually across the City, with approximately 5% of those trees within the FTZ. Trees within the FTZs are prioritized for trimming to be completed prior to summer before extreme temperatures begin to elevate wildfire risk.

PG&E notes on page 80 of their 2019 WMP that there are ten (10) species of trees that have been responsible for 75% of the past fire ignitions in California4. The susceptibility of a tree species to wildfire depends on various factors such as its flammability, moisture content, growth habit, and location. These species of trees make up approximately 12% of trees within APU FTZs and approximately 40% of overall tree species in APU service territory. 4 Black Oak, Gray Pine, Tanoak, Coast Live Oak, Live Oak, Ponderosa Pine, Eucalyptus/Blue Gum, Douglas Fir, Valley Oak and Monterey Pine
32 Anaheim tracks the location, species, condition, and trimming schedule for trees near power lines in the FTZs to maintain a defensible space. Clearances are increased around overhead power lines within FTZs where the combination of high wind potential and dry vegetation may increase the risk of fire ignition. The attributes of the tree and Global Positioning System (GPS) coordinates are archived in Geographic Information System (GIS) mapping, and annual inspections and trimming appropriate for the growth pattern of that species is recorded. Figure 12 depicts the attributes recorded for each tree within the FTZs.

Figure 12: Tree Inventory Tracking in a GIS Map

In certain years, heavy rains contribute to increase growth of wild grass in Southern California and as the season transitions, the hot weather dries out the grass attributing to increase surface fuel and higher risk of ignition. As mentioned earlier, surface fuels are managed by removing the vegetation within the FTZs under the Brush Abatement Program managed by AF&R using a combination of goats to remove grass, mechanical tools to remove brush, and replanting native plants to reestablish a natural fire break and is divided into three phases:
 Phase I Natural Brush Abatement – The use of goats to remove flash and invasive fire fuels.  Phase II Mechanical Brush Abatement – The use of machinery and tools to trim existing trees and brush 10’ from the ground and remove dead and invasive trees and shrub.  Phase III – To replant with native plants and shrubs to reestablish nature’s natural fire break. 33 APU performs vegetation clearing around the base of power poles in accordance with PRC § 4292 where CAL FIRE non-exempt switching equipment is located or animal contacting energized electric lines is most prominent. Surface fuel clearing is performed after rains have subsided and ambient temperatures begin to rise.

As part of an Orange County grant program in coordination with OCFA, a survey of trees, initially observed by the Anaheim Community Services Department staff to be infested with an Invasive Shot Hole Borer Beetle (ISHB) and Gold Spotted Oak Borer (GSOB), was conducted by scientific experts in biology and entomology from the University of California Cooperative Extension (UCCE) in the Oak Canyon Nature Preserve and Deer Canyon. The survey determined to either treat or remove invested trees. Through 2022, the program has removed 50-60 trees and treated approximated 400 infected trees. Figure 13 below shows the results of the 2021 GSOB survey. Additional surveys will be performed in FTZs for ISHB and GSOB infestations and treated trees will be evaluated for treatment effectiveness. As a part of the program, approximately 55, fifteen-gallon coast live oak trees were planted at the Oaks Canyon Nature Center to repopulate native trees in the area.

Figure 13: GSOB 2021 Survey Data

34 B. System Inspection and Maintenance
APU conducts routine inspections of distribution and substation equipment to assess condition and prioritize maintenance or replacement. The prioritization method follows industry practice, which aligns with CPUC guidelines as delineated in GO 95 Rule 18, GO 165 – Inspection Requirements for Electric Distribution and Transmission Facilities, and GO 174 Section III- Rules for Electric Utility Substations – Inspection Programs. A visual inspection of over 8,700 underground substructures and above surface equipment was completed in 2022. Inspection of the overhead system, which included intrusive pole testing of over 17,000 poles, including sub- transmission, distribution wood poles, wood streetlight poles, and associated overhead conductors and equipment was completed in 2018 with the next inspection cycle scheduled to start in 2023. Underground distribution equipment is on a 3-year inspection cycle. Surface- mounted and overhead equipment is inspected on a 5-year cycle, consistent with GO 165 guidelines and patrolled annually or prior to a RFW or SAWTI weather event. Qualified substation personnel inspect each of the fourteen (14) substations visually and with infrared scans monthly for anomalies that may include hot spots, rusting, leakage, or visible signs that maintenance or replacement is warranted. Oil samples of substation transformers are tested annually for anomalies such as rising gases or moisture contaminants that could lead to pre- mature failure of the equipment.

APU utilizes ArcGIS Survey123 and ArcGIS Collector to record and collect all inspection data points and photos of electrical assets in the field. The data is loaded directly into the GIS Inspection website and linked to specific asset tags. All assets are captured within GIS and assigned a condition level, which is used to identify and prioritize maintenance measures of the assets, which in turn improves system reliability. There are three maintenance condition levels.

They are prioritized based on probable impact on safety or reliability, taking into account several factors. These factors include facility or equipment type and condition, loading, location, accessibility, and direct or potential impact on safety or reliability. The three conditions and their priority levels are:

Condition Level “1”: Maintenance required. Repair or replace within 90 days. If there is an imminent safety or reliability problem, including equipment within the FTZs, the inspector should contact Electric Operations for confirmation with field personnel and to identify and schedule immediate mitigation procedures.

Condition Level “2”: Maintenance needed but deferrable to next scheduled inspection, no immediate safety or reliability concern.

Condition Level “3”: Minor aging, fully serviceable, no safety or reliability concern.

Appropriate for next scheduled inspection.

Those maintenance items that pose the greatest public safety or system reliability risks will either: (a) be repaired immediately or (b) if the repair proves too complex to complete immediately or requires materials that are unavailable, a temporary repair will be made to address the risks, and the item will be reprioritized for repairs to be completed at a later date.

For infrastructure located within the FTZs, equipment identified as needing maintenance during an inspection cycle will be prioritized for immediate mitigation procedures if there is an imminent safety or reliability problem.
35 The inspection cycle for subsurface and pad-mounted equipment began in 2021 and was completed in December 2022. The next inspection cycle of overhead facilities will begin during the second half of 2023 and will be completed over a 2-year period for all 17,000+ wood poles, including prioritizing those located in FTZs.

C. Undergrounding Power Lines
APU is actively engaged in undergrounding circuits to mitigate wildfire threat. To date, 98% of the 130.42 circuit miles of APU-owned power lines in the FTZs are currently underground, which significantly reduces the overall risk of wildfire to the community. The remaining overhead APU-owned power lines in the FTZs are planned to be undergrounded by late 2025.

The undergrounding of overhead lines and the operational strategies of the APU system eliminates the need for APU to initiate a planned power shutoff for wildfire mitigation in the service territory.

In 2019, APU assets included a 2,000-foot long overhead line that traversed through a residential area adjacent to Deer Canyon, a Tier 3 FTZ. The pole-line was along a narrow, private roadway that that made it difficult for emergency vehicles to access. APU and various telecommunication companies had overhead facilities co-located on utility poles. APU evaluated the use of insulated conductors for this segment; however, it required replacing poles, additional guying support and easements and thus, decided undergrounding the line was more prudent. On July 30, 2019, the City Council approved APU’s Underground Conversion Program Five-Year Plan, which included the undergrounding of this overhead line. Underground design began in 2019 and construction was completed in May 2021 prior to the 2021 fire season. APU works with all telecommunication companies who underground their lines at their cost with the exception AT&T, citing that this roadway did not meet the definition of an eligible project as currently defined in its Rule 32A. APU continues to implement future underground projects and coordinate with telecom providers to include joint use trenching to improve accessibility for emergency vehicles and recommends that the state obligate all telecommunication companies to modify their regulatory authority to underground in FTZs. This project also eliminated the need to subject this segment and the customers it serves to a planned power shutoff for wildfire mitigation purposes.

Existing APU assets within Tier 3 include one (1) 12 kV overhead segment totaling approximately 0.88 miles that is de-energized under normal operating conditions, as this portion of the line does not serve customers. The line is used only as a tie-point between two circuits for redundancy and is patrolled and maintained as if it is energized. The line traverses through a nature park and has varying elevations of terrain that would be disruptive to the natural setting if underground excavation and equipment were installed along the existing overhead route. To reduce wildfire risk, the line was hardened in 2019 with twenty-seven (27) ductile iron poles with larger fiberglass crossarms to replace the existing wood poles to reduce the near-term threat of wildfire risk. There is a protocol for visual inspection of this line prior to re-energization, and to use the line for reliability purposes including emergency power restoration when environmental conditions warrant. To preserve the natural habitat of the woodpecker birds in this area, some wood poles were left standing as perches with all electric conductors and equipment removed.
36 Existing APU assets within Tier 1 and Tier 2 FTZs include seven (7) segments of 12 kV overhead line, totaling approximately 1.75 miles. APU partnered with AF&R to apply for grant funding to help offset the cost and accelerate the undergrounding of the existing APU 12 kV overhead lines within all FTZs, including the removal of the 0.88 mile previously-hardened overhead line in Tier 3. Figure 14 shows the remaining APU overhead lines identified for undergrounding or removal as a part of the program. In February 2021, APU received approval for $1.16 million of Hazard Mitigation Grant Program (HMGP) funds from the Federal Emergency Management Agency (FEMA). The detailed design for the program was complete in 2023 and is currently in the easement acquisition phase. The full engineering package will be submitted to FEMA for review in May 2023 for additional grant funding approval consideration to construct the project. The estimated construction cost of the project to underground or remove all 2.63 miles of overhead lines is $20 million and will be implemented as a restructured project, divided into phases, if full funding is not obtained.

Figure 14: APU OH Circuits in FTZs
To incorporate further wildfire risk reduction into APU’s completed and planned undergrounding work in the FTZs, FR3 transformers have been integrated into underground projects. APU has elected to replace overhead transformers with new FR3 subsurface transformers due to the fluid possessing a higher heat tolerance to withstand greater temperatures before burning when compared to current standard mineral-oil. In the past three (3) years, twelve (12) overhead transformers have been replaced with eight (8) subsurface FR3 transformers, with the remaining twenty-three (23) transformers in the FTZs to be replaced by 2025 by undergrounding.
*References: CalFire’s FRAP Map
and CPUC’s High Fire Threat District
37 D. Overhead Construction Practices
While APU anticipates that the remaining 2.63 miles of overhead distribution assets in the FTZs will be removed or replaced with underground facilities by 2025, current overhead design and equipment standards will remain in place until all the undergrounding work is complete. If equipment is identified as potential for imminent failure in Tier 2 or Tier 3 FTZs, equipment may be replaced prior to undergrounding on an as-needed basis. All newly installed equipment will be from the CAL FIRE non-exempt equipment list. These standards are in place to reduce the risk of possible wildfire ignition from foreign objects or environmental forces acting upon the remaining overhead infrastructure.

Lightning arresters are installed on poles with overhead to underground transitions and at customer terminations. When lightning strikes a conductor, there is a high voltage spike along the conductor and the arresters limit the potential for a flashover near a grounded pole. During normal conditions, animals may perch on the cross-arm or the bracket the arrester is mounted to and have been observed to store a food source in the opening of the arrester where the energized high voltage conductor enters. These arresters have been replaced with a concealed version eliminating the entry point to an energized part as shown in Figure 15. In addition, the grounded bracket supporting the arrester is also wrapped to further the distance between the conductor and grounded equipment.

Non-expulsion fuses or current-limiting fuses incorporate a self-contained design that eliminates potential expulsive material associated with expulsion fuse operation, making them suitable for use in areas where a high-fire hazard exists. APU has replaced twelve (12) fuses with non- expulsion type fuses in the FTZs in order to minimize the risk of ignition from an electrical fault and will continue its fuse replacement if undergrounding the remaining overhead line is delayed.

Animals can come into contact with energized overhead power lines, fall to the ground, and ignite brush beneath the power lines or at the base of poles. APU has installed avian protection devices on the conductors to deter bird collisions along their flight path (see Figure 16 below).

Figure 15: (a) Concealed Lightning Arrester (b) Ductile Iron Pole (c) Comparison of Lightning Arrester Models
38 These devices work in two ways, one that allows the bird to “bounce” away from the conductor rather than becoming entangled and/or making phase to phase contact with high voltage power lines. The other method utilizes a device hung on the conductor itself with a flashing light to alert birds during their night flights that an obstruction is ahead. APU has installed avian protection devices on two (2) powerline segments in the vicinity of groundwater charging lakes frequented by migratory birds and will continue to install the devices where bird strikes and bird strike risks are detected.

Figure 16: (a) Raptor Clamp with LED Light (b) Swan Flight Diverter E. Pole Loading and Wire Spacing
APU is primarily the owner of the power poles throughout Anaheim and is a participant in the Southern California Joint Pole Committee that allows members to mutually allocate space on the pole among agencies to attach equipment to provide service, including electric, telecommunications, and cable companies. APU allows for a total maximum weight attached onto the pole using standard guidelines established in GO 95, Section IV. Wind parameters for calculating pole loading were increased from 8 lbs. to 12 lbs., exceeding the GO 95 standard, and has been assessed for all poles within or adjacent to the FTZ.

To establish a measured peak wind gust, APU utilizes historic data collected from the weather stations at Linda Vista Reservoir, Oak Canyon and Fairmont Substation located closer to the Tier 3 FTZ and near the applicable overhead electric infrastructure. APU construction standards for overhead infrastructure including poles, conductors, switches, connectors, and grounding in the Tier 3 FTZ have been modified to incorporate design and construction to sustain the highest measured 3-second wind gust. For example, 27 wood poles have been replaced with ductile iron poles in and through the Oak Canyon Nature Preserve, and pole loading and clearance between lines have been improved in this location. The pole line within the Tier 3 FTZ that traverses the Oak Canyon Nature Preserve does not have telecommunication attachments and does not serve customers. These poles were replaced with ductile iron poles able to withstand even higher wind parameters.

APU substituted standard 8’ wood crossarms with 10’ fiberglass crossarms on all new ductile iron pole installations to increase spacing between wires for energized overhead lines located in or adjacent to the Tier 3 FTZ. The increased clearance reduces the potential for wires to contact each other during high wind conditions.
39 SECTION 9 - Operational Strategies to Reduce Risk of Wildfire Ignition Construction methods for fire-hardening infrastructure, proactive equipment replacements, system inspections, and preventative maintenance are essential components of a resilient electric distribution system, but there are additional strategies to mitigate the risk of operating an electric system within areas where high fire threat exists. As forecasted ambient temperatures rise, humidity levels drop and/or Santa Ana wind conditions are prevalent, these operational strategies will take effect to further reduce the potential for wildfires within the FTZs.

A. System Patrols
A patrol is a visual inspection of applicable utility equipment and structures that is designed to identify obvious structural problems and hazards. System patrols occur on an annual basis to ensure that immediate issues are detected and addressed as quickly as possible. Patrols differ from detailed inspections which are performed for more of a diagnostic and proactive evaluation of equipment conditions.

During forecasted elevated ambient temperatures or RFW and Extreme SAWTI events, utility staff is dispatched to patrol the overhead infrastructure in the FTZs as a precautionary measure or utilize AF&R Community Emergency Response Teams (CERTS) already out on patrols for multiple purposes to provide visibility on electric infrastructure. For circuits in the FTZs that experience a planned or unplanned outage during a RFW and/or Extreme SAWTI event, the length of the circuit must be patrolled prior to re-energizing to ensure the line and supporting structures are intact, and vegetation is not in contact with the lines.

System-wide annual patrols of applicable utility equipment and structures in urban areas are conducted by APU. The entire system is patrolled annually by electric troubleshooters to identify where wood poles, cross arms, or other equipment are in need of repair or replacement, and equipment or lines in need of clearance from vegetation.

B. Circuit Reclosers
Microprocessor-based protective relays are used within substations to detect faults on the electric lines and signal to the substation circuit breaker to open, disrupting power on a circuit before damage occurs to major equipment. Once the circuit breaker has opened and disrupted power, the Supervisory Control And Data Acquisition controlled protective relay is programmed to signal the circuit breaker to “reclose and test”, before re-energizing the circuit. If the fault is cleared, or if it was momentary when, for example, a broken tree branch falls and clears the lines, the circuit is successfully re-energized, and power is restored to the affected area. If the fault is still present, the protective relay will detect it again and signal the circuit breaker to open and the reclose function is automatically disabled. The circuit breaker will remain open with power disrupted until crews make repairs and return the system to normal condition. The reclose and test method allows for a shorter outage duration and less impact to service when the fault is momentary. During extreme fire weather conditions when the area is in RFW and/or an Extreme SAWTI event is initiated, APU operators will disable the automatic reclosing capability of the protective relays for lines located within the FTZs as a precautionary measure, consistent with industry practices in California.
40 Four overhead distribution circuits in FTZs have been identified as subject to disabling the reclosing function during these elevated fire and weather conditions. In addition, if these identified circuits should experience a fault and relay, they will not be re-energized until a visual inspection has been performed. The recloser operations will be reevaluated in 2025 when the remaining overhead circuits are converted to underground.

C. Communication Network
APU operates and maintains critical software applications on computer servers with higher capacity and resiliency for remote operation and protection systems like circuit reclosers. The communication network used to support these systems is an independent fiber-optic network owned and maintained by APU. The fiber-optic system is a point-to-point network with redundancy for added flexibility to re-route the communication path in the event of damage, significantly increasing the reliability for remote communication critical to the automated protection systems. The fiber system is underground in the Anaheim FTZ.

APU is working with wireless carriers to install small cellular sites on its streetlight pole tops throughout Anaheim, including FTZs. The cell sites will improve cellular service coverage and support APU and customer communication during RFW and other emergency events. There are currently ten (10) active small cell sites serving the customers in FTZs, and fourteen (14) additional planned within FTZs.

D. Power Shutoffs
APU is actively engaged in undergrounding circuits to mitigate wildfire threat. 98% of the 130.42 circuit miles of APU-owned power lines in the FTZs are currently underground, which significantly reduces the overall risk of wildfire caused by APU equipment. The underground conversion of overhead lines and APU operational practices eliminates the need for APU to initiate a planned power shutoff for wildfire mitigation in their service territory. APU still maintains protocols to initiate immediate power shutoffs in FTZs.

Operational and communication protocols for immediate power shutoffs impacting customers are documented in APU’s wildfire mitigation response procedures. Customers affected by shutoffs will be contacted in person and/or by phone, text, or electronic mail by APU staff. APU offers portable back-up generators and batteries to residents and small commercial customers in situations when power is expected to be unavailable over eight (8) hours or customers who need additional equipment for medical life-support devices. Additionally, APU has established resiliency rebate programs for Uninterruptible Power Supplies (UPS) and portable battery-based generators to qualifying residents who may need assistance with medical or other essential devices.
41 Figure 17: APU Emergency Generator
Coordination between APU and AF&R occurs on a routine basis for structure fires whether or not there is an elevated wildfire risk. Proper precautions are taken to ensure the safety of the public, AF&R fire crews, and utility personnel when fighting any fire where structures are at risk. A Citywide safety committee includes relevant departments including City Safety, AF&R, Anaheim Police, Public Works, and APU to collaborate on safety matters on a quarterly basis. In situations where AF&R or other public safety first responders initiate an evacuation of an area, APU will coordinate with the City Public Information Office to keep the media and general public informed if power has been de-energized. Operational and communication protocols are also in place to restore power after an outage.

SCE has 500 kV high voltage transmission lines passing through the East Anaheim FTZ. APU customers are not impacted by an SCE Public Safety Power Shutoff (PSPS); however, Anaheim is reliant on regional transmission service via SCE. APU and SCE meet annually to review and discuss SCE operation and communications in the event SCE lines are de-energized and power is re-routed through SCE redundant transmission paths. These redundant paths do not traverse through a FTZ therefore are deemed a very low risk of losing transmission service for Anaheim. 42 E. Summary of Operational Strategies
Table 8 is a summary of operational strategies to be implemented during elevated weather conditions.

Table 8: Operational Strategies
Operating Strategies
Red Flag
Warning
(RFW)
Santa Ana Wildfire
Threat Index
(SAWTI) Extreme
Monitor Warnings X X
Patrols X X
Disable Reclosers X X
De-Energize Tier 3 FTZ Overhead
Line
X
SECTION 10 - Community Support in Emergencies
A. Community Outreach
Educating the community on what to expect during elevated fire weather conditions, and the subsequent response to those conditions that could impact the residents and businesses in Anaheim is a priority. Anaheim has held several community outreach events to inform residents of future plans to underground power lines within FTZs. As the construction phase for additional undergrounding in the FTZs approaches in 2024-2025, on-site community outreach will be conducted to inform residents of the impacts and schedules of the project.

During two community meetings in April and October 2022 in East Anaheim, APU staff responded to wildfire-related questions including maintaining sufficient water for fire-fighting helicopters taking water from an open water reservoir, SCE’s wildfire mitigation role regarding their high-voltage transmission towers and lines traversing FTZs in Anaheim, and APU- sponsored rebate programs on attic insulation and vents to harden their homes against wildfire threats.
43 Figure 18: APU Staff During 2022 Community Meetings
A major cause of power outages utility-wide are the result of metallic balloons contacting electrical lines when released. Senate Bill 1990 (1990) and Assembly Bill 2450 (2018) passed mandates to weigh down the metallic balloon and labeling of the supply chain; however, metallic balloon contact with power lines continues to be a potential wildfire risk. APU educates customers through social media, public service announcements, and promotes proper disposal of metallic balloons to reduce wildfire risk. As an example, a contest was held with high school students who first were educated on the impacts of metallic balloons causing power outages and then prepared creative videos to promote safety and proper disposal of balloons; those videos were then shared on APU’s social media sites.

Rebate Programs
In 2020, APU established a fire-safety program encouraging customers to take advantage of rebates on fire-resistant measures, planting approved fire-resistant shade trees, and following AF&R recommendations to improve safety in wildfire zones by clearing brush and maintaining clearances. The fire-resistant measures include rebates up to $750 on fire-resistant attic insulation that reduces the risk of fires starting in the attic while at the same time decreases the energy demands of heating and cooling systems. APU also offers a $250 rebate for fire-resistant vents designed to block embers and fire from entering the home through the attic during extreme situations such as wildfires or local vegetation fires. Eighty (80) APU customers have received over $52,000 in rebates to install over 150,000 square feet of fire-resistant insulation.

The TreePower program informs residents of the appropriate fire-resistant trees to plant at safe distances from combustible structures in FTZs. APU provides up to six (6) trees per resident, which can be selected from the APU Tree Selection catalogue. The program is intended to 44 reduce the need for power line clearance tree trimming and eliminate the opportunity for a vertical “fire-ladder” near a home or other combustible structure.

Information on City Website and Social Media
Other customer outreach includes the use of social media and APU’s webpages listed below which are dedicated to wildfire safety and awareness:
 APU Facebook updates on potential for wildfires:
https://www.facebook.com/page/187233877728/search/?q=wildfire  APU Workshop Protect Your Home from Wildfire Damage
 AF&R Wildfire Workshops (Wildfire tips every Wednesday on AF&R’s Facebook page; 10/23/21 & 3/5/22: Emergency Preparedness Symposium; and 3/31/22: Disaster Preparedness Program (8-hour workshop that includes Wildfire education – 23 residents received certificates.)
 AF&R’s Brush Clearance and other programs: http://anaheim.net/5629/Preparing-for- Wildfire
 APU Wildfire Mitigation Plans Webpage: http://www.anaheim.net/5487/Wildfire- Mitigation-Plan
 APU’s Wildfire Safety Webpage: http://www.anaheim.net/5418/Fire-Safety Also, the City posted notifications in late March 2022 on Anaheim Hills Buzz and NextDoor, two social media platforms commonly used by the area residents, of the impending installation of new wildfire cameras that overlook the Oak Canyon.

B. Emergency Response
APU wildfire mitigation response procedures outline the protocols to ensure appropriate operational procedures are implemented during RFW and/or SAWTI Extreme conditions, identified in Section 8, and appropriate procedures are in place for notifying all stakeholders impacted when de-energizing and re-energizing electrical lines including customers, the APU’s Public Information Officer (PIO), AF&R Emergency Management and Preparedness, Anaheim Police Dispatch Center, APU Water Division and Customer Service Management, and external agencies associated with APU operational support. The APU System Operations Center acts as a hub for system operations and emergency response during RFW events, wildfires, and other emergencies and provides 24/7 customer support when the Customer Service Center is outside of working hours.

One of the benefits of having a municipally owned electric and water utility is the close coordination with Anaheim’s first responders, working collaboratively as emergencies such as wildfires arise. In case of emergencies including unplanned outages, APU has a supporting role with the AF&R in emergency protocols for public support services as delineated in the City of Anaheim Emergency Operations Plan. These services include care, shelter-in-place, animal control, disability assistance, vehicle access, and functional needs. The preparations and response for an emergency power shut-off are included with those used for major events such as flooding and earthquakes. APU also adds a standby crew during non-working hours to improve response 45 time during emergency events, including a fully operational construction crew and an additional troubleshooter. APU will follow the emergency protocols outlined in the City of Anaheim Emergency Operations Plan, where the City adheres to the policy summarized below. In addition, considerations for special needs populations are built into the responsibilities of each member of the Emergency Operations Center organization and are also addressed in supporting procedures and checklists:
 Customers with access and functional needs will be accommodated for access to services or facilities provided by Anaheim.
 Anaheim will work to accommodate special needs populations and those with disabilities to address their circumstances and needs.
 During emergency situations, Anaheim will make reasonable modifications to policies, practices, and procedures to assist residents with disabilities.  Priority will be given to house special needs populations and those with disabilities to keep families, friends, and/or neighbors in close proximity to each other when in mass care emergency shelters.
 Eligibility for mass care shelters will not be dependent on a personal care attendant.  During preparedness and mitigation activities, Anaheim will conduct outreach activities to residents with special needs to ensure they are prepared in times of crisis.

Outlined in the City of Anaheim Emergency Response Plan - Public Notification and Alerts, methods of warning the public of specific emergency conditions are described below. These systems may also be primary means of how state and local governments become aware of emergency information. Public communications such as emergency information, warnings, and actions for an event will be broadcasted to the public by any one of the following methods:
 Emergency Alert System (EAS)
 Wireless Emergency Alert (WEA)
 Integrated Public Alert and Warning System (IPAWS)
 Route alerting - Detour and evacuation routes posted by AF&R  AlertOC – Mass notification via phone or text message initiated by Orange County  Anaheim Alert – Mass notification via phone or text message initiated by the City of Anaheim
 Social Media
 Media-releases – through the City PIO
 Telephone emergency hotline – established during Canyon Fire 2.

APU maintains a Public Utilities Department - Emergency Response Plan (ERP), in accordance with California Government Code, Article 9, Section 8607, to ensure a safe, timely, effective, and well-organized response to major disruptions of services provided by APU including 46 Electric, Water, Customer, and Finance services. The ERP incorporates knowledge gained from emergency situations and includes industry best practices developed as a result of major regional storms and outages affecting other organizations over the last several years. Also included is mutual aid and other information obtained from the California Utilities Emergency Association and the American Public Power Association, as well as standards contained in the CPUC’s GO166-Standards for Operation, Reliability, and Safety During Emergencies and Disasters, which APU has utilized as a guideline for emergency planning.

C. Community Support
When needed, a Mobile Neighborhood Utility Center will be established in close proximity to areas impacted by major water or electric incidents to provide timely and meaningful system status to customers as well as to provide real-time customer feedback to utility staff.

Figure 19: Mobile Neighborhood Utility Center
The Mobile Neighborhood Utility Center is deployed to specific service areas for which the estimated restoration time is anticipated to be more than 24 hours. The precipitating event may be equipment failure, earthquakes, floods, storms, fire, or any combination of these events. It may also be coincident with a local or state-wide emergency not directly associated with APU but which may impact Anaheim’s water and energy resources. Activation may also be preemptive.

The Mobile Neighborhood Utility Center(s) will be located at strategic public gathering areas based upon the type of emergency event and may be relocated or closed as conditions and priorities change.

The priorities of the Mobile Neighborhood Utility Center are to:
47 1. Gather electric and/or water system information and intelligence relative to an incident or outage.

2. Provide timely information to the APU and City Emergency Operations Center - Utility Branch.

3. Provide restoration timelines to the public in coordination with APU and City PIO, and help to reduce call volume to the Call Center by dealing directly with the public.

4. Provide personalized attention to members of the public who may need special assistance that is not of an emergency nature.

5. Maintain system and resource status awareness.

6. Provide mobile back-up power generation to designated Community Centers.

The Mobile Neighborhood Utility Center is facilitated by one or more Mobile Neighborhood Utility Liaisons (Liaisons). The Liaison assignment is typically filled by members of APU staff that are not performing duties respective to emergency operations centers or in direct support of water or electric system restoration. The Liaisons are responsible for collecting, assessing, evaluating, and disseminating information pertaining to the incident. They directly interface with the public throughout the incident and continue to maintain contact with the public until substantial recovery is achieved.

D. Post-Event Customer Support
Post-event customer support and protections are in place to facilitate recovery from the damages incurred and provide multiple options for billing adjustments. Anaheim City Council approved a rule modification that, upon declared emergencies, APU may waive certain charges or portions related to a) Customer service charges, b) Temporary Service, c) service connection plan checks, design/engineering, and inspection, and/or d) related administrative charges related to both electric and water services. Such fees were waived during the Canyon Fire 2 for customers with damaged properties.

The associated fees for the abandonment of existing service connections, installation of new service connections and meters, and inspection of new backflow prevention assemblies are considered Service Connection Fees. Depending on the extent of damages and new construction at each property, Service Connection Fees will vary. For minor service improvements, a Service Connection Fee would not be applicable; however, for a structure requiring a complete rebuild and a fire sprinkler system, Service Connection Fees could be significant. Waived charges apply to the existing property owner for one year from the date the emergency or local emergency is proclaimed or declared, unless the Anaheim City Council declares otherwise.

APU also assists customers with damaged homes who seek to keep their landscaping alive during the rebuilding process. Irrigation controllers were provided, at no charge, during the Canyon Fire 2 upon confirmation that water service can be safely restored, allowing customers to avoid having to replace their existing landscaping that was not damaged by the fire. 48 SECTION 11 - Workforce Training
Emergency Response training is conducted annually to prepare for multiple types of natural disasters that require activation of the City Emergency Operations Center (EOC) and the APU Electric Department Operations Center (DOC). Specific wildfire emergency training scenarios are conducted annually, either as part of the larger Department-wide training or through table-top exercises with key personnel responsible for electric operations.

Training for operation of the wildfire cameras by the AF&R Dispatchers is conducted using a train-the-trainer method. In July 2019, representatives from UCSD-Scripps and SCE, along with supervisory personnel from AF&R conducted fire camera training. The wildfire cameras operations transitioned in 2022 from the AlertWildfire.org to a new more user-friendly platform under AlertCalifornia.org. As such, new training materials for AlertCalifornia.org were provided as a refresher and for new personnel in the division.

As previously mentioned in Section 10(A) - System Patrols, the AF&R CERTS are utilized in the field during RFW, SAWTI Extreme, and wildfire conditions to provide additional visibility of electrical infrastructure and report back to APU System Operations. APU conducts an annual training with the AF&R CERTS as part of a larger AF&R safety training program to review relevant electrical infrastructure including the pole tag numbers, switches, conductors and connections, transformers, and other equipment. This training helps AF&R identify and report equipment anomalies to APU operators to pinpoint the location of the anomaly and help APU operators make appropriate operational decisions. The training also reviews hazards associated with energized electrical equipment and fire suppression methods that cannot be used near the equipment.

Additional training includes interactions within city departments. One example includes APU electric crews providing training on high voltage electrical equipment to fire cadets. The training was conducted with padmount equipment that are installed within the FTZs. Additional training includes fire personnel collaborating with APU water crews on confined space rescues in water storage facilities located within FTZs. Since water pressure is critical for fire mitigation, collaboration and joint training provided the opportunity to improve coordination and ensure employees are familiar with each other’s roles and responsibilities. 49 Figure 20: APU Electrical Safety Training for Fire Cadets SECTION 12 - Organization and Assignment Responsibilities This section describes the roles and responsibilities required to accomplish the objectives of this WMP. Various stakeholders play a role in preventative and operational mitigation strategies, emergency response, and communications. An organizational chart in Figure 20 below gives context to the organizational structure of the City of Anaheim and from there, specific groups responsible for implementing the measures and programs within the WMP. 50 Figure 21: City of Anaheim Organizational Structure
The following Table 9 identifies the roles and responsibilities of City of Anaheim stakeholders.

Table 9: Roles and Responsibilities for Implementation of the WMP Action Organization
Advisory Warning Watch and Notification AF&R EMP/APU Operations Fire Threat Zone area assessment AF&R Fire Prevention/APU Operations Fire Monitoring Cameras and Weather Stations APU Operations/AF&R Fire Prevention On-Site Visual Inspections during RFW and
SAWTI Extreme events
APU Electric Trouble/AF&R CERTS
Disabled Reclosers Procedure APU Operations
Infrastructure Integrity Assessment APU Electric Trouble/T&D Engineering Construction Standards APU T&D Engineering
Vegetation Management APU Electric T&D Field/Public Works Equipment Evaluation and Replacement APU Standards/Electric Operations Distribution System Inspection APU Standards/T&D Engineering Substation Inspection/Maintenance APU Substation Test and Maintenance Reporting APU Administration and Compliance
WMP Review and Approval Public Utilities Board/City Council Budgetary approval for WMP mitigation Public Utilities Board/City Council 51 SECTION 13 - Metrics, Monitoring and Reporting
Metrics are used to evaluate the WMP’s performance consistent with GO 95 and GO 165 requirements, and utilizing the guidelines suggested in SBs 901 and 1028. There are two categories of metrics: 1) specific metrics of fire incidents and 2) the WMP’s performance metrics. As industry risk metric standards continue to develop, APU will identify additional metrics to measure the reduction of wildfire risk in future WMPs. Incident metrics include RFW and SAWTI Extreme initiated in the Orange County area, reclosers functions disabled in the FTZ, planned power shut-off for wildfire mitigations, and reportable ignitions in a FTZ associated with electric overhead conductors. These metrics are used to track progression and to measure the effectiveness of these preventative and operational mitigation strategies to further strengthen fire preparedness and safety.

Other scenarios exist where power lines have the potential to cause fire ignition, for example a vehicle hitting a power pole or power lines in contact with each other during a high wind storm.

A reportable ignition associated with electric overhead power lines in APU’s Tier 2 and Tier 3 FTZ is the number of power lines involved in fire incidents annually that occurred within APU’s Tier 2 or 3 FTZ. Generally, a reportable ignition includes all of the following: a) Ignition is associated with APU’s power lines, b) something other than APU’s facilities burned, and c) the resulting fire traveled more than one meter from the ignition point.

Performance metrics tracking progress in preventative strategies and programs include a target goal to establish the benchmark comparison to actual completion. Sample performance metrics include vegetation clearance, inspections completed, and training performed which are used to inform the performance of each preventive strategy and program.

Performance metrics were first introduced within the 2018 WMP and at that time relatively limited data was available to form comparisons. New metrics have been included starting with the 2020 WMP where there may not have been a metric input applicable in the 2018 year. The following Figure 21 is a summary of the incident and performance metrics associated with the 2023 WMP.
52 Figure 22: 2023 WMP Incident and Performance Metrics

53 54

55 Metrics added or updated starting with the 2020 WMP were the result of actual events that occurred and therefore informed this 2023 WMP. Tracking these metrics will provide insight into the effectiveness of APU wildfire mitigation measures and assist in formulating enhanced measures in future WMPs if warranted. A summary of the metrics tracked from the previous 3- year cycle of WMPs included in this comprehensive analysis.

Table 10: Summary of Performance Metrics
Metric 2021 WMP 2022 WMP 2023 WMP

ANNUAL NUMBER OF EVENTS
Red Flag Warning 7 4 1
SAWTI Elevated in Orange County 0 3 3
Planned Outages for Wildfire Mitigation 0 N/A N/A
Reportable Fire Ignitions in FTZs from Power Lines 0 0 0 Reportable Fire Ignitions in FTZs from Equipment 0 0 0
Disabled Recloser Events 7 4 1
Downed Power Lines 0 0 0
CUMMULATIVE ASSETS INSTALLED FROM 2020-2022
% of Power Lines Underground in FTZs 98% 98% 98%
Weather Monitoring Stations in FTZs 4 5 5
Fire Cameras Installed in FTZ 8 8 10
Asset Replacements for Wood to Ductile Iron Poles 27 27 27 Asset Replacements for Concealed Lighting Arresters 6 12 12 Asset Replacements for Non-Expulsion Fuse
Disconnects
6 12 12
Asset Replacements for FR3 Transformers N/A N/A 8

TRAINING, INSPECTION AND TESTING PERFORMED ANNUALLY
Fire Camera View & Operations Training Complete Complete Complete De-Energize/Restore Procedures Training Complete Complete Complete Disabling Recloser Training Complete Complete Complete
AF&R Electrical Safety Complete
% of Tier 3 FTZ Power Lines Cleared of Vegetation 100% 100% 100% Inspections & Patrols for All Overhead Distribution
Lines Complete Complete Complete
Inspections & Patrols for All Underground
Distribution Lines Complete Complete Complete
Inspections & Patrols for Substation & Yard
Equipment Complete Complete Complete
Sampling & Testing for Strength of Wood Poles Complete Complete Complete Substation Sampling & Testing for Contaminates in
Insulating Oil Complete Complete Complete
The metrics and the wildfire mitigation improvements they represent are a result of substantial investments by APU for completed and planned projects and programs in various areas including engineered upgrades, maintenance and operations improvements, and public education and benefits programs. These investments are listed under Table 11, below. 56 Table 11: APU’s Wildfire Mitigation Investments
APU’s Wildfire Mitigation Investments
Completed Planned
Item Project
Description
Scope Cost
($000)
Scope Year Cost ($000)
1 Wildfire
Undergrounding
- (all FTZ areas)
Placed 2000' of overhead high voltage
and communication lines underground on
Eucalyptus Drive. $2,600
Underground
conversion or
removal of 2.63
miles of
overhead and
communication
lines across 7
segments.
2024-2025 $20,000
2 Transformer
Replacements
in FTZS
Replaced 12 overhead with 8
underground fire-resistant FR3
transformers.
$250
Replace 23
overhead with
FR3
underground and
surface-mounted
transformers
2024-2025 $900
3 Wildfire
Camera
Installation
Installed 2 new wildfire camera sites
overlooking the wildlands at Oak Canyon,
integrated with the AlertCalifornia
camera system.
$300
Install 4
additional
cameras at two
sites to overlook
the Weir and
Gypsum Canyon
wildlands.
2023-2024 $400
4 AF&R
Vegetation
Management in
FTZ’s
Goat herding contractor costs. $198 Goat herding
contractor costs
On-going $200
5 Residential
Structure
hardening -
Attic and Vents
APU provided rebates for 150,000 sq ft of
fire-resistant attic insulation installed by
80 customers. Rebates are also available
for customers taking advantage of Fire-
Resistant fireplace vents.
$52
Continue with
rebates for fire-
resistant attic
insulation and
fireplace vents
On-going $30
6 Residential
Structure
Hardening –
Building Code
Upgrades
Plans for new construction in fire-prone
areas to comply with Building Code
Chapter 7A - Materials and Construction
Methods for Exterior Wildfire Exposure.

N/A
Continued
reviews for
compliance with
Building Code
Chapter 7A
On-going N/A
7 Tree trimming
in FTZs
Powerline Clearing of approximately 840
trees per year. $100
Continued until
all overhead
lines are
undergrounded
in FTZs by 2025
2023-2025 $100
8 Avian
Protection pilot
Install avian protection devices on two
powerline segments in vicinity of
groundwater charging lakes frequented by
migratory birds.
$80
Additional
installations will
be considered if
bird strike risk is
identified
2023-24 $80
57 APU’s Wildfire Mitigation Investments
Completed Planned
Item Project
Description
Scope Cost
($000)
Scope Year Cost ($000)
9 Equipment
upgrades
(sealed surge
arresters, non-
expulsive and
electronic self-
contained fuses)
In FTZs, installed 6 each self-contained
electronic and non-expulsive fuses that
prevent hard shards from fuse activation
to fall on dry grass below, and 12 new
lightning arresters with sealed caps to
avoid critter contact.
$100
Sealed Lightning
arresters will be
installed on an
as-needed basis
On-going $15
10 Reduce animal-
caused outages
at open air
substations
Install bushing covers for High Voltage
Circuit Breakers $45
Other two
substations
serving
customers in fire
threat zones are
in fully-enclosed
structures, not
subject to
animal-induced
outages.

Complete $0
11 Wildfire-
resistant plants
APU’s TreePower program includes
wildfire resistant plant species:
https://www.anaheim.net/763/Residential-
TreePower. 710 trees provided with 403
participants.
$510
Continued
wildfire-resistant
plants
On-going $350
12 Mylar Balloon
Safety
Mylar balloons educational video posted
on City website and YouTube:
https://www.anaheim.net/4752/Mylar-
Balloons.
$5
Continued Mylar
Balloons
educational
program
On-going $5
13 Backup
generators for
customers
Purchased two (2) 70kVA trailer-mounted
emergency generator to restore power and
contract for additional rented emergency
generators.
$75 ea.
$150
Total
Continue trailer
mounted
emergency
generators
contract
2023-2024 $3 annual
maint. cost
14 Ductile iron
poles/fiberglass
crossarms in
Oak Canyon/
Walnut Canyon
Rd. area
Replaced 36 deteriorated wood poles in
HFTZ with ductile iron poles. Topped
wood poles left to support natural habitat
for birds.
$1,000
With future
undergrounding
planned,
additional
ductile iron poles
in fire threat
zones are not
being considered
at this time.
$0
Total $4,390 $22,083
58 SECTION 14 - Monitor and Auditing the Plan
APU reviews its WMP and updates performance metrics annually to align with Anaheim’s planning and budgeting process. Its WMP is presented to the Anaheim Public Utilities Board (PUB) annually on or before July 1st of each year, and upon final approval of the WFM, APU submits its WMP to the California Wildfire Safety Advisory Board (WSAB). The WSAB reviews and provide comments and advisory opinions regarding the content and sufficiency of the APU WMP. APU considers comments and opinions received by the WSAB in future WMPs.

In addition to annual updates to the WMP, a comprehensive review of APU’s WMP is performed every three (3) years to review metrics, garner feedback, and ensure that the wildfire mitigation plan adequately addresses them, and provide an assessment of the WMP programs combined with analysis of performance metrics to develop changes to design, construction, or maintenance standards and practices to inform activities for future wildfire mitigation plans.

This three-year-cycle comprehensive assessment and update to APU’s WMP will be reviewed by a Qualified Independent Evaluator (QIE), as required by AB 1054. The QIE will assess and audit the comprehensiveness of APU’s WMP prior to consideration for recommendation by the Anaheim PUB for consideration and approval by the Anaheim City Council. The WMP is posted on the APU website for public review and comment, and is added as an agenda item to the PUB meeting annually so it is available for public comment.

In March 2020, Guidehouse, Inc. was retained by APU to perform the initial independent audit following a competitive solicitation that followed Anaheim’s Council Policy 4.1 – Selection of Professional Consultants. The APU WMPs and the QIE results are posted to the APU website for public view at http://www.anaheim.net/5487/Wildfire-Mitigation-Plan. The focus of the first QIE review of the APU 2020 WMP was to ascertain whether the WMP meets the statutory requirements, which included an audit of all documentation that support the claims made by APU in the WMP. The QIE determined the 2020 WMP and all supporting documentation was comprehensive. Going forward, APU will select a QIE with expertise in industry-wide strategies to evaluate and develop recommendations for increased grid resiliency and options for reducing impacts of wildfires on utility customers.

In 2023, APU retained NV5, Inc. to assist with the comprehensive update of the 2023 WMP and GridSME, as the QIE, to perform the independent evaluation of the 2023 WMP. The GridSME report, available on APU’s public webpage https://www.anaheim.net/5487/Wildfire-Mitigation- Plan, concluded that the WMP is comprehensive and meets the requirements of the Public Utilities Code Section 8387.