Burbank Water and Power - Wildfire Mitigation Plan Page | 1 Burbank Water and Power
WILDFIRE
MITIGATION
PLAN
2022
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TABLE OF CONTENTS
LIST OF ACRONYMS AND ABBREVIATIONS ................................ ................................ ................................ ................................ ......................5 DEFINITIONS ................................ ................................ ................................ ................................ ................................ ................................ ....................6 CHAPTER 1. INTRODUCTION................................ ................................ ................................ ................................ ................................ .....................8
1.1 Policy statement ................................ ................................ ................................ ................................ ................................ ................................ .... 8
1.2 Plan summary ................................ ................................ ................................ ................................ ................................ ................................ ......... 8
1.3 WMP objectives ................................ ................................ ................................ ................................ ................................ ................................ ... 11 CHAPTER 2. BURBANK WATER AND POWER ................................ ................................ ................................ ................................ .................. 11
2.1 BWP profile ................................ ................................ ................................ ................................ ................................ ................................ .......... 11
2.2 Service territory ................................ ................................ ................................ ................................ ................................ ................................ .... 12
2.3 Electric system ................................ ................................ ................................ ................................ ................................ ................................ ..... 12 CHAPTER 3. PREVENTATIVE STRATEGIES AND PROGRAMS OVERVIEW ................................ ................................ ............................... 14 CHAPTER 4. RISK ANALYSIS AND RISK DRIVERS ................................ ................................ ................................ ................................ ............ 16
4.1 Risk analysis methods ................................ ................................ ................................ ................................ ................................ ............................. 16
4.1.1 Hazard vs. risk discussion ................................ ................................ ................................ ................................ ................................ ............. 16
4.2 Wildfire risk bowtie analysis ................................ ................................ ................................ ................................ ................................ ................. 16
4.2.1 Potential risk drivers ................................ ................................ ................................ ................................ ................................ ................. 18
4.2.2 Key risk impacts ................................ ................................ ................................ ................................ ................................ ........................... 19
4.3 Site fire environment assessment of BWP’s electric service territory ................................ ................................ ................................ ........... 20
4.3.1 High fire threat district ................................ ................................ ................................ ................................ ................................ ............. 20
4.3.2 Wildfire-threat area site evaluation................................ ................................ ................................ ................................ ...................... 22
4.3.3 Evaluation of higher fire-threat areas ................................ ................................ ................................ ................................ .................. 24
4.4 Electrical facility assessment ................................ ................................ ................................ ................................ ................................ ................. 24
4.5 Prioritization of wildfire risks ................................ ................................ ................................ ................................ ................................ ................ 29
4.6 Mitigation activities that address risk drivers ................................ ................................ ................................ ................................ ................... 30
4.7 Review of risk drivers and analysis................................ ................................ ................................ ................................ ................................ ....... 30 CHAPTER 5. WILDFIRE PREVENTION STRATEGIES AND PROGRAMS ................................ ................................ ................................ ...... 31 5 . 1 Facility design and construction ................................ ................................ ................................ ................................ ................................ ........... 31
5.1.1 Deteriorated pole replacements ................................ ................................ ................................ ................................ ........................... 31
5.1.2 Pole loading assessments & remediation ................................ ................................ ................................ ................................ ........... 31
5.1.3 Overloaded transformer replacements ................................ ................................ ................................ ................................ ............... 32
5.1.4 Distribution construction standard improvements ................................ ................................ ................................ ....................... 32
5.1.5 Conventional fuse replacements ................................ ................................ ................................ ................................ .......................... 33 5 . 2 Inspection and maintenance ................................ ................................ ................................ ................................ ................................ ................. 34
5.2.1 Annual patrol inspection (GO 165) ................................ ................................ ................................ ................................ ....................... 34
5.2.2 Vegetation management program ................................ ................................ ................................ ................................ ........................ 34
5.2.3 Intrusive pole inspections ................................ ................................ ................................ ................................ ................................ ........ 35 5 . 3 Operational practices ................................ ................................ ................................ ................................ ................................ ............................. 36
5.3.1 Block reclosing and increase relay sensitivity during RFW ................................ ................................ ................................ ......... 36
5.3.2 Line patrol after outage event during RFW ................................ ................................ ................................ ................................ ....... 36
5.3.3 Ignition potential work practices during RFW ................................ ................................ ................................ ................................ . 37 5 . 4 Situational/conditional awareness ................................ ................................ ................................ ................................ ................................ ...... 38
5.4.1 Weather/fire monitoring ................................ ................................ ................................ ................................ ................................ ........... 38
5.4.2 Geographic information system (GIS) applications ................................ ................................ ................................ ........................ 38
5.4.3 Enhanced system monitoring ................................ ................................ ................................ ................................ ................................ . 38 5 . 5 Public safety power shutoff ................................ ................................ ................................ ................................ ................................ ................... 39 CHAPTER 6. EMERGENCY PREPAREDNESS AND RESPONSE ................................ ................................ ................................ ..................... 40 ATTACHMENT 1
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6.1 Emergency management ................................ ................................ ................................ ................................ ................................ .................. 40
6.1.1 BWP Department Operations Center ................................ ................................ ................................ ................................ ..................... 42
6.2 Disaster and emergency response ................................ ................................ ................................ ................................ ................................ .. 42
6.2.1 Fire agency emergency response ................................ ................................ ................................ ................................ .............................. 43
6.3 Customer support during emergencies ................................ ................................ ................................ ................................ .......................... 43
6.4 Restoration of service ................................ ................................ ................................ ................................ ................................ ........................ 43 CHAPTER 7. PERFORMANCE METRICS AND MONITORING ................................ ................................ ................................ ...................... 44
7.1 Accountability of the plan ................................ ................................ ................................ ................................ ................................ ................. 44
7.2 Metrics to evaluate plan performance ................................ ................................ ................................ ................................ ........................... 45
7.2.1 BWP performance metrics ................................ ................................ ................................ ................................ ................................ ...... 45
7.2.2 Annual performance metrics ................................ ................................ ................................ ................................ ................................ .. 47
7.3 Monitoring and auditing the plan ................................ ................................ ................................ ................................ ................................ ... 48
7.3.1 Identifying and correcting deficiencies in the WMP ................................ ................................ ................................ ...................... 48
7.3.2 Monitoring and auditing the effectiveness of inspections ................................ ................................ ................................ ........... 48
7.3.3 Annual internal audit ................................ ................................ ................................ ................................ ................................ ................. 49 CHAPTER 8. PUBLIC COMMENT, PRESENTATION, AND INDEPENDENT EVALUATION ................................ ................................ . 55
8.1 Public comment ................................ ................................ ................................ ................................ ................................ ................................ .. 55
8.2 Presentation to BWP Board and Burbank City Council ................................ ................................ ................................ ............................ 55
8.3 Independent evaluation ................................ ................................ ................................ ................................ ................................ .................... 55
8.4 Wildfire Safety Advisory Board ................................ ................................ ................................ ................................ ................................ ........ 56 CHAPTER 9. REFERENCES ................................ ................................ ................................ ................................ ................................ ......................... 57 EXHIBIT A. CONTEXT-SETTING INFORMATION TABLE ................................ ................................ ................................ ............................... 58 EXHIBIT B. SUMMARY OF KEY CHANGES IN BWP’S 2022 WMP ................................ ................................ ................................ ............... 60 ATTACHMENT 1
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FIGURES
FIGURE 1 - BWP'S ELECTRIC LOAD ................................ ................................ ................................ ................................ ................................ ............................ 12 FIGURE 2 - BWP ELECTRIC DISTRIBUTION SYSTEM ................................ ................................ ................................ ................................ ................................ 13 FIGURE 3 - BWP'S WILDFIRE RISK BOWTIE ................................ ................................ ................................ ................................ ................................ .............. 17 FIGURE 4 - BWP'S TIER 2 HIGH FIRE THREAT DISTRICT ................................ ................................ ................................ ................................ ......................... 21 FIGURE 5 - HISTORICAL FIRES IN BURBANK ................................ ................................ ................................ ................................ ................................ .............. 23 FIGURE 6 - ELECTRICAL FACILITIES WITHIN THE TIER 2 HFTD................................ ................................ ................................ ................................ ............. 25 FIGURE 7 - WILDFIRE RISK PRIORITIZATION WITHIN THE TIER 2 HFTD ................................ ................................ ................................ ............................. 29 FIGURE 8 - BWP EMERGENCY RESPONSE TEAM ORGANIZATION ................................ ................................ ................................ ................................ ....... 41
TABLES
TABLE 1 - PLAN COMPLIANCE WITH PUC 8387(B) ................................ ................................ ................................ ................................ ................................ ... 8 TABLE 2 - OVERVIEW OF MITIGATION ACTIVITIES ................................ ................................ ................................ ................................ ................................ ... 14 TABLE 3 - BREAKDOWN OF BWP'S ELECTRICAL ASSETS WITHIN THE TIER 2 HFTD ................................ ................................ ................................ ....... 24 TABLE 4 - INVENTORY OF BWP ASSETS IN THE TIER 2 HFTD BY CIRCUIT ................................ ................................ ................................ ......................... 26 TABLE 5 - ELECTRICAL EQUIPMENT RISK DRIVERS BASED ON HISTORICAL EVENTS ................................ ................................ ................................ ........... 27 TABLE 6 - MITIGATION ACTIVITIES THAT ADDRESS RISK DRIVERS ................................ ................................ ................................ ................................ ........ 30 TABLE 7 - DISTRIBUTION INSPECTION CYCLES (MAXIMUM INTERVAL IN YEARS) ................................ ................................ ................................ ............... 34 TABLE 8 - VEGETATION CLEARANCES ................................ ................................ ................................ ................................ ................................ ........................ 35 TABLE 9 - PRIORITY LEVEL OF DETERIORATED POLES BASED ON INTRUSIVE INSPECTIONS ................................ ................................ .............................. 35 TABLE 10 – ELECTRIC SERVICES TEAM RESPONSIBILITIES DURING AN EMERGENCY RESPONSE EVENT ................................ ................................ ........ 41 TABLE 11 - ACCOUNTABILITY FOR WMP COMPONENTS ................................ ................................ ................................ ................................ ..................... 44 TABLE 12 - BWP WILDFIRE PREVENTION PERFORMANCE METRICS ................................ ................................ ................................ ................................ .... 46 TABLE 13 - 2021 BWP WILDFIRE PREVENTION PERFORMANCE METRICS ................................ ................................ ................................ ........................ 47 TABLE 14 - 2021 SUMMARY OF RISK DRIVER EVENTS IN THE TIER 2 HFTD ................................ ................................ ................................ ...................... 48 TABLE 15 - SUMMARY OF MITIGATION ACTIVITY ACCOMPLISHMENTS IN 2021 ................................ ................................ ................................ ............... 52
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List of Acronyms and Abbreviations
AMI Advanced Metering Infrastructure
BWP Burbank Water and Power
CAL FIRE California Department of Forestry and Fire Protection CPUC California Public Utilities Commission
CWSAB California Wildfire Safety Advisory Board
DOC Department Operations Center
ECC Energy Control Center
EERP Electric Emergency Response Plan
ERP Emergency Response Plan
EM Emergency Management
GIS Geographic Information System
GO General Order
HFTD High Fire Threat District
IC Incident Command or Incident Commander
ICS Incident Command System
kV Kilovolt
MW Megawatts
NERC North American Electric Reliability Corporation
NIMS National Incident Management System
NWS National Weather Service
OMS Outage Management System
PRC California Public Resources Code
PUC Public Utilities Code
RFW Red Flag Warning
SB Senate Bill
SCADA Supervisory Control and Data Acquisition
SEMS Standardized Emergency Management System
SME Subject Matter Expert
T&D Transmission and Distribution
WMP Wildfire Mitigation Plan
WUI Wildland Urban Interface
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Definitions
1. Energy Control Center (ECC): BWP’s ECC personnel are responsible for directing the safe and reliable operation of BWP’s electric system while operating within current policies and proce dures during normal and emergency situations. The ECC prepares, checks, and administers the execution of safe and reliable switching procedures. The ECC will monitor and maintain equipment-loading levels to prevent damage to equipment. The ECC is also responsible for updating outage information timely and accurately.
2. General Order 95 (GO 95): GO 95 is a set of rules formulated by the California Public Utilities Commission (CPUC) with the purpose of creating requirements for overhead line design, construction, and maintenance. While the CPUC does not have direct governance over publicly owned utilities, BWP designs, constructs, and maintains all overhead electrical lines to meet or exceed this industry standard.
3. General Order 165 (GO 165): GO 165 is a set of rules formulated by the CPUC with the purpose of creating requirements for the inspection of electric distribution and transmission facilities in order to ensure safe and high-quality electric service. BWP has an inspection program in place that meets or exceeds this industry standard.
4. Hardening: Modifications to electric infrastructure to reduce the likelihood of ignition and improve the survivability of electrical assets.
5. High Fire Threat District (HFTD): In 2017, the CPUC adopted new fire safety regulations to combat the threat of wildfire for areas in Northern and Southern California. High Fire Threat Districts (HFTD) have been classified as High Hazard Zones due to tree mortality (Tier 1), elevated risk for utility - associated wildfires (Tier 2), and extreme risk for utility-associated wildfires (Tier 3).
6. Incident Commander (IC): The IC is the person responsible for all aspects of an emergency response, including quickly developing incident objectives, managing all incident operations, application of resources, as well as responsibility for all persons involved. The IC sets priorities and defines the organization of the incident response teams and the overall incident action plan.
7. Incident Command System (ICS): The ICS “a systematic tool used for the command, control, and coordination of emergency response” according to the state Standardized Emergency Management System and federal National Incident Management System. A more detaile d definition of an ICS according to the United States Center for Excellence in Disaster Management & Humanitarian Assistance is “a set of personnel, policies, procedures, facilities, and equipment, integrated into a common organizational structure designed to improve emergency response operations of all types and complexities.” Responding emergency service providers would establish the ICS and designate an Incident Commander.
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8. Red Flag Warning (RFW): An RFW is a warning issued for a stated period of time by the National Weather Service using pre-determined criteria to identify particularly critical wildfire danger in a particular geographic area. The National Weather Service issues an RFW when “warm temperatures, very low humidity, and stronger winds are expected to combine to produce an increased risk of fire danger.”
9. Senate Bill 901 (SB 901): SB 901 is legislation enacted as of September 21, 20 18 that, among other changes and requirements, amended California Public Utilities Code (CPUC) Section 8387 to provide in subpart (b) that each local publicly owned electric utility and electrical corporative shall annually prepare and present a wildfire mitigation plan (WMP) to its governing board for review and approval, and to specify in subpart (b) (2) the elements that must be included in such WMP. As used herein, SB 901 refers to the requirements of CPUC Section 8387.
10. Wildfire Risk: The risk of a potential wildfire event caused by BWP electrical lines or equipment.
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Chapter 1. Introduction
1.1 Policy statement
As a community owned utility, Burbank Water and Power’s mission is to provide safe, reliable, affordable and sustainable electric service to the residents and businesses of the City of Burbank.
1.2 Plan summary
While the City of Burbank has experienced several wildfires in the Verdugo Mountains throughout its history, no wildfires have ever been caused by BWP electrical facilities. This WMP describes the range of activities that BWP is taking to mitigate the threat of power -line ignited wildfires, including its various programs, policies and procedures. This plan will be reviewed and evaluated by its governing board each year. This plan meets or exceeds the requirements of PUC section 8387 for publicly owned electric utilities to prepare a WMP by January 1, 2020, and annually thereafter . Table 1 below summarizes the plan compliance with the corresponding plan sections referenced.
This plan is available on BWP’s website at BurbankWaterAndPower.com under Electric > Wildfire Mitigation Plan.
For a summary of changes to the 2022 WMP, refer to Exhibit B, Summary of Key Changes in BWP’s 2022 WMP.
Table 1 - Plan compliance with PUC 8387(b)
SB 901
requirement
Description
Plan section number
b (2) (A) An accounting of the responsibilities of the persons responsible for executing the plan. 7.1
b (2) (B) The objectives of the wildfire mitigation plan. 1.3
b (2) (C)
Description of the preventative strategies and programs to be adopted by the publicly owned electric utility or electrical cooperative to minimize the risk of its electrical lines and equipment causing catastrophic wildfires, including consideration of dynamic climate change risks.
3, 5
b (2) (D)
A description of the metrics the local publicly owned electric utility or electrical cooperative plans to use to evaluate the wildfire mitigation plan’s performance and the assumptions made that underlie the use of those metrics.
7.2 b (2) (E)
A discussion of how the application of previously identified metrics to previous wildfire mitigation plan performances has informed the wildfire mitigation plan.
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SB 901
requirement
Description
Plan section number
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
5.3.1, 5.5
b (2) (G)
Appropriate and feasible procedures for notifying a customer who may be impacted by the de-energizing of electric
lines. The procedures shall consider the need to notify, as a priority, critical first responders, health care facilities, and operators of telecommunications infrastructure.
6.3 b (2) (H) Plans for vegetation management. 5.2.2
b (2) (I) Plans for inspections of the local publicly owned electric utility’s or electrical cooperative’s electrical infrastructure. 5.2.1
b (2) (J)
A list that identifies, describes, and prioritizes all wildfire risks, and drivers for those risks, throughout the local publicly owned electric utility’s or electrical cooperative’s service territory. The list shall include, but not be limited to, both of the following:
4.2, 4.5
b (2) (J) (i)
Risks and risk drivers associated with design, construction, operations, and maintenance of the local publicly owned electric utility or electrical cooperative’s equipment and facilities.
4.2.1 b (2) (J) (ii)
Particular risks and risk drivers associated with topographic and climatological risk factors throughout the different parts of the local publicly owned utility’s or electrical cooperative’s service territory.
4.3 b (2) (K)
Identification of any geographic area in the local publicly owned electric utility’s or electrical cooperative’s service territory that is a higher wildfire threat than is currently identified in a commission fire threat map, and identification of where the commission should expand the high fire
threat district based on new information or changes to the environment.
4.3.3 b (2) (L) A methodology for identifying and presenting enterprise- wide safety risk and wildfire-related risk.
4.1 b (2) (M) A statement of how the local publicly owned electric utility will restore service after a wildfire.
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SB 901
requirement
Description
Plan section number
b (2) (N)
A description of the processes and procedures the local publicly owned electric utility or electrical cooperative shall use to do all of the following:
b (2) (N) (i) Monitor and audit the wildfire mitigation plan. 7.3 b (2) (N) (ii) Identify any deficiencies in the wildfire mitigation plan or its implementation, and correct those deficiencies.
7.3.1 b (2) (N) (iii)
Monitor and audit the effectiveness of electrical line and equipment inspections, including inspections performed by contractors that are carried out under the plan, and other applicable statutes, or commission rules.
7.3.2 b (3)
The local publicly owned electric utility or electrical cooperative shall present each wildfire mitigation plan in an appropriately noticed public meeting. The local publicly owned utility or electrical cooperative shall accept comments on its wildfire mitigation plan from the public, other local and state agencies, and interested parties, and shall verify that the wildfire mitigation plan complies with all applicable rules, regulations, and standards as appropriate.
8.2 (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.
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1.3 WMP objectives
The primary objectives of this WMP are to:
1. Reduce the probability that BWP’s electric system may be the contributing source for the ignition of a wildfire; and
2. Harden and maintain BWP’s electric system against a potential wildfire; and
3. Create a WMP that is consistent with state law and objectives.
BWP continually evaluates prudent and cost -effective improvements to its design standards, physical assets, inspection and maintenance programs, operations, and training in order to meet these objectives. This plan documents mitigation activities that will be carried out by BWP. Lastly, this plan will set measures of effectiveness to inform future improvements or modifications to specific programs and strategies.
Chapter 2. Burbank Water and Power
2.1 BWP profile
Burbank Water and Power is a vertically integrated, publicly owned municipal utility that has served Burbank’s electrical needs for more than 100 years. Being vertically integrated means that BWP generates, transmits, and distributes power to Burbank customers. BWP is owned and operated by the City of Burbank and is governed by its Board and the Burbank City Council. BWP is not-for profit, delivering service at cost.
BWP is committed to p roviding reliable, affordable and sustainable electrical service to Burbank. BWP’s reliability is superb, maintaining electrical service to BWP’s customers 99. 999% of the time in 2019. In terms of affordability, BWP’s rates are near the lowest in the regio n, with annual rate increases at or below the long- run rate of inflation for the last decade. BWP’s commitment to sustainability is strong: In 2007, BWP was the first utility to commit to 33% renewables by 2020 and BWP reached 33.3% renewables in fiscal y ear 2016-17.
Consistent with BWP’s 2019 Integrated Resource Plan, by the end of the planning period in 2038, BWP would have renewables equivalent to a 67% renewable portfolio standard, approximately double the current level.
For a summary of information r egarding BWP’s service territory, please refer to Exhibit A, Context -Setting Information Table.
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2.2 Service territory
BWP electric system provides power to approximately 52,907 customers across 17 square miles within the City limits. Burbank is known as the Media Capital of the World and is home to two of the world’s largest studios, Warner Bros. Entertainment and The Walt Disney Company. The city is also home to thousands of sm aller businesses, many of whom moved to Burbank in the early 1990s after the aerospace industry contracted and real estate became more available. These businesses have come to expect cost -effective and reliable electrical service, as well as additional services such as fiber optic networking.
Burbank also has a vibrant residential community, with a housing mix of about 18,750 single-family homes that range from post -World War II bungalows to two story view homes. There are also about 28,850 multifamily homes. In total, BWP currently serves 45,774 residential, 5,403 small commercial, 1,086 medium commercial, 156 large commercial, and 87 extra-large customer accounts.
2.3 Electric system
BWP supplies electrical service to its customers through a distribution network, which includes 13 distribution substations, 2 customer substations, 5 switching stations, 45 miles of 34.5 kilovolt (kV) sub-transmission lines, 33 miles of 69 kV transmission lines, 204 miles of overhead distribution lines, 131 miles of underground distribution lines, 587 miles of overhead secondary lines, 117 miles of underground secondary lines, 10,737 poles, and 5,834 transformers. BWP’s all-time peak demand was 322 MW in 2017 but is forecast to remain flat at about 314 to 322 MW for the next several years.
45,774 5,403 1,086 156 87
Figure 1 - BWP's electric load
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Figure 2 - BWP electric distribution system
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Chapter 3. Preventative strategies and programs
overview
BWP’s strategy for preventing wildfires resulting from its electrical infrastructure includes attention to fire prevention during ongoing operations and maintenance and during planning, design, and construction of new assets.
The overarching goal is to minimize the risk of BWP facilities starting or contributing to the ignition of vegetation fires. The BWP fire prevention strategies and programs encompass four primary fire safety categories. Each of the fire safety categories below have several mitigation measures, many of which have already been implemented. Each of the mitigation measures is discussed in more detail in Section 5 of the WMP. Table 2 is a summary of BWP’s program and strategies that support wildfire prevention and mitigation.
Table 2 - Overview of mitigation activities
Mitigation activities Description Timing*
Design and construction
1 Deteriorated pole
replacements
Replacement of poles that do not pass condition-based assessments to prevent pole failure.
B
2 Pole loading assessments &
remediation
Structural assessment of poles to identify potential loading issues during high wind events. Replacement of poles that do not pass GO 95 wind loading design criteria to minimize the risk of pole failure.
A
3 Overloaded transformer
replacements
Replacement of overhead transformers that do not meet loading criteria to prevent transformer failure.
B
4 Distribution construction
standards improvements
Engineering study of distribution construction standard improvements, which could provide additional risk reduction in the Tier 2 HFTD. Analysis will be ongoing as new technologies come to market and best practices are refined.
B
5 Conventional fuse
replacements
Replacement of conventional fuses with CALFIRE “Exempt” non-expulsive fuses in the Tier 2 HFTD. These fuses do not emit sparks during normal operation and reduce the risk of wildfire ignitions from fuse operations.
A
Inspection and maintenance
6 Annual patrol inspection (GO
165)
Annual system patrol to inspect the condition of electrical assets to avoid faults, which could cause ignitions. A
7 Vegetation management
program
Annual vegetation maintenance and clearance from electrical lines to avoid vegetation contact in Tier 2 HFTD A
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Mitigation activities Description Timing*
8 Intrusive pole inspections
Condition based assessment of remaining pole strength to identify poles at risk of failure A
Operational practices
9 Block reclosing and increase
relay sensitivity during RFW
Block reclosing and increase relay sensitivity on all feeder lines in the Tier 2 HFTD during RFW events A
10 Line patrol after outage event
during RFW
Patrol with physical inspection of
tripped feeder lines in Tier 2 HFTD during RFW before re -energizing circuit A 11 Ignition potential work
practices during RFW
Except during an emergency, disallow work that may potentially produce an ignition source on all feeder lines in the Tier 2 HFTD during RFW events A Situational/conditional awareness
12 Weather/fire monitoring
Conduct weather and fire monitoring via publicly available weather resources to monitor weather forecast and any potential extreme fire conditions
A
13 Geographic information
system (GIS) applications
Implementation of Outage Management System (OMS), which uses GIS data and meter information to help BWP locate outages and decrease response time
A
14 Enhanced system monitoring
Implement a pilot program of pole mounted sensor packages to detect faults and anomalies in real time. See Section 5.4.3. B
*A – Mitigation activity already implemented
B – Ongoing mitigation activity
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Chapter 4. Risk analysis and risk drivers
4.1 Risk analysis methods
During the development of its Wildfire Mitigation Plan in 2019, BWP retained a consultant (Dudek) to perform a fire risk assessment of its electrical system and equipment utilizing the following approaches:
• Risk bowtie analysis. Risk evaluation method to analyze all potential causes of an BWP-caused wildfire as well as the potential impacts of such an event.
• Site fire environment assessment. Assessment of natural and landscape environments around BWP facilities to determine the presence of potential threats or conditions that could become a BWP-caused wildfire threat.
• Electrical equipment assessment. Inventory of all BWP electrical assets within the Tier 2 HFTD and analysis of historical outage information.
4.1.1 Hazard vs. risk discussion
The definition of a BWP risk of catastrophic wildfires (Wildfire Risk) is a wildfire event itself that is caused by BWP electrical facilities. However, it is important to distinguish between hazard (which the hazard maps categorize) and risk (which the hazard maps do not quantify). Hazard is a property of the potential fire environment or wildfire behavior for a given area (such as flame length, crown fire occurrence, and capacity to generate embers). A wildfire risk, however, relates to potential risk drivers (or triggers) that indicate if a risk event could occur, and do not reflect actual conditions or threatened conditions. Thus, even if there is potential high fire hazard in a given area (with expected high flame lengths, and aggressive wildfire), there may be a low risk of ignition from BWP electrical facilities.
4.2 Wildfire risk bowtie analysis
The risk of a vegetation ignition and potential for an uncontrollable wildfire caused by BWP electrical facilities is related to the type of vegetation (fuel bed) within its vicinity, the local/regional weather patterns, and the potential for a failure of BWP’s equipment. For example, areas that include uninterrupted, natural (unmaintained) vegetation present a risk of ignition from ongoing operational activities or equipment failures. When the area also includes weather conditions that result in periodic h igh wind and low humidity, the wildfire risk is significantly enhanced. Both of these weather conditions can occur in BWP’s Tier 2 HFTD area. A bow tie analysis was conducted to identify these risk drivers as well as their potential resulting impacts. Figure 3 provides the risk bow tie diagram, which summarizes the assessment process.
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Figure 3 - BWP's wildfire risk bowtie
Key risk drivers Triggering event Key risk impacts
Electrical equipment failure:
• Conductor
• Crossarm
• Insulator
Prolonged electrical outage for
customers
• Splice/clamp/connector
• Transformer
• Pole
Conventional fuse operation:
• Transformer fuse
• Lateral fuse Ignition from BWP assets
that causes a wildfire
Serious injuries or fatalities Wire contact with foreign object(s):
• Mylar balloons
• Animals
Wire contact with vegetation:
• Tree branch Damage and loss of BWP assets
• Palm frond
Extreme weather conditions:
• Climate change
• High temperatures Claims from damaged property
• Extreme wind
• Low humidity
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4.2.1 Potential risk drivers
Risk drivers are important to identify because they are the primary ways in which BWP electrical facilities could result in a catastrophic wildfire. The center of the bow tie chart is the triggering event, which is an ignition caused by a BWP asset resulting in a catastrophic wildfire. During the wildfire threat assessment, five categories were identified as potential drivers for causing fire ignitions:
1. Electrical equipment failure;
2. Conventional fuse operation;
3. Wire contact with foreign object(s);
4. Wire contact with vegetation; and
5. Extreme weather conditions.
It should be noted that the listed potential risk drivers are just an indication that a risk event could occur from a BWP asset, but actual conditions may differ. This type of analysis helps identify the types of mitigations necessary to minimize the risk of wildfire.
BWP’s risk driver analysis identified and studied the five categories of drivers:
4.2.1.1 Electrical equipment failure
Electrical equipment failure is an inherent risk. Failure can occur for a variety of reasons such as manufacturer defects, loading conditions, or deterioration. Failure of electrical components, such as poles, crossarms, conductor, insulators, splices, connectors, or guy wires can result in a downed conductor (or “wire down”) situation, which could lead to fire ignition. Electrical equipment such as transformers, voltage reg ulators, or capacitor banks can have internal shorts that can potentially be destructive and eject materials which could lead to fire ignition.
4.2.1.2 Conventional fuse operation
Fuses are devices that protect electrical lines and equipment during fault or overload conditions. Historically, BWP, as well as most of the electric industry, standardized on conventional type fuses to protect their system.
During overload or fault conditions, a conventional fuse will operate and can expel hot particles and gases, which could ignite nearby vegetation.
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4.2.1.3 Wire contact with a foreign object(s)
BWP constructs its overhead electrical lines in alignment with industry standards by installing bare wires spanned on top of insulators on wooden poles. These lines are constructed at a certain height above the ground and a certain distance from adjacent objects based on appropriate design criteria to prevent contact and faults. Unfortunately, foreign objects such as animals and mylar balloons can still occasionally come into contact with overhead electrical lines.
Animals and mylar balloons are highly conductive and could result in a fault when contact is made with overhead electric lines. Protective devices such as relays, circuit breakers, and fuses are set up to protect and isolate these type of situations. However, there is a time delay between the protective devices sensing the fault and operating to isolate the fault. Although this time delay is nearly instant (within fractions of a second), there is still enough time to cause an emission of sparks, molten metal, or burnt foreign objects, which could lead to a fire ignition. In a worst - case scenario, this could also cause the conductor to fail and land in an energized mode, causing a fire ignition.
Vehicles, that come in contact with an electrical pole or supporting guy wires can damage or break the pole. This could cause energized wires to break and fall to the ground igniting vegetation.
4.2.1.4 Wire contact with vegetation
Vegetation such as tree branches or palm fronds also pose a risk of coming into contact with overhead electrical lines. This contact can cause sparks and arcs, and in some cases can cause the vegetation to ignite into flames and drop to the ground. Vegetation contact could also l ead to conductor failure, which could cause a fire ignition. In addition, trees that are near BWP’s electrical lines could possibly uproot and fall onto an energized conductor, causing pole failures or wire down events that could cause fire ignition.
4.2.1.5 Extreme weather conditions
Climate change along with extreme weather conditions contribute to the risk of wildfires. Higher air temperatures and lower humidity cause trees and vegetation to dry out and create conditions that are ripe for fire ignition and expansion. Additionally, extreme winds can increase tree failures, vegetation contact with overhead electrical lines, and failure of BWP assets such as poles and conductor.
4.2.2 Key risk impacts
If one of the risk drivers listed above were to occ ur, resulting in a wildfire ignition caused by BWP electrical facilities, there could be potential consequences for BWP as presented on Figure 3.
The worst-case scenarios could include:
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• Prolonged electrical outage for customers.
• Serious injuries or fatalities.
• Damage and loss of BWP assets.
• Claims from damaged property.
BWP is fully aware of the impacts that wildfires can have on the publicly owned utility, Burbank’s populace, and local economy. As discussed in Section 5 of the WMP, BWP has established programs and implemented wildfire prevention strategies to create barriers or methods of reducing the likelihood of the risk driver events identified above from occurring and possibly leading to a catastrophic wildfire.
4.3 Site fire environment assessment of BWP’s electric service territory
Due to its weather, topography, and native vegetation, the entire southern California area is at risk from wildland fires. The threat of wildfire exists throughout this region, including BWP’s service territory. This threat is attributable to a variety of factors including extended drought, which has resulted in vulnerable vegetation for longer periods; climate change which may be driving the drought and vegetation drying; and population growth into the fire-prone areas, which results in the potential for increased ignitions and higher threat based on private and public assets that may be exposed to wildfires.
An assessment was made of the surrounding terrain, vegetative fuels, r egional weather patterns, and regional fire history for the HFTD areas within BWP’s service territory. The factors evaluated were:
1. Fire risks: all activity periods (operation, maintenance, new project design, construction, materials and methods);
2. Site and facility ignition sources: equipment, personnel, processes.
3. Fire prevention strategies: design, maintenance, inspections, monitoring.
4. Best management practices for hardening of electrical system.
5. Fire agency coordination: Firefighting and emergency response technical evaluation, training, and coordination.
4.3.1 High fire threat district
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Figure 4 - BWP's Tier 2 high fire threat district
BWP directly participated in the development of the California Public Utilities Commission’ s (CPUC) Fire- Threat Map which designates high-fire threat districts (HFTDs) throughout the State of California. The CPUC Fire - Threat boundary map ranks HFTDs based on the need to increase infrastructure resiliency to mitigate the wildfire threat posed by electric infrastructure. The CPUC Fire -Threat Map is comprised of Tier 2 HFTDs (elevated risk of potential impacts to people and property) and Tier 3 HFTDs (extrem e risk of potential impacts to people and property).
Tier 2 HFTD
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In the map development process, BWP served as a territory lead, and worked with local fire & government officials to identify the areas of BWP’s service territory that are Tier 2 or Tier 3 HFTDs. It was determined through the development process and affirmed by both a peer review and a team of independent nationwide experts led by the California Department of Forestry and Fire Protection (CAL FIRE), that a portion of BWP’s service territory is situated within a Tier 2 HFTD. Additionally, no portion of BWP’s service territory falls within a Tier 3 HFTD.
For a summary of information rega rding BWP’s service territory in the Tier 2 HFTD, please refer to Exhibit A, Context-Setting Information Table.
4.3.2 Wildfire-threat area site evaluation
BWP staff provided Wildfire SME (Dudek) with a guided tour on May 9, 2019, of the electric distribution system within Tier 2 HFTD area. The wildfire experts evaluated existing site conditions (e.g., topography, vegetation, and fuel loading) and whether or not there are the presence of potential risk drivers or conditions that could become a BWP-caused wildfire threat. Based on Dudek’s field assessment and BWP staff interviews, the following observations were recorded for the distribution system in the Tier 2 HFTD area.
Fire environment observations
1. Most of the Tier 2 HFTD Areas are hilly or mountainous and steeper slopes exacerbate fire spreading, which also impedes fire suppression efforts. In worst -case scenarios, fires on the steep slopes of the Verdugo Mountains could burn well into the heavily developed areas of Burbank.
2. Wildland fires are relatively common in the Verdugo Mountains and have historically burned into the wildland-urban interface or Tier 2 HFTD areas of Burbank. The most recent fire, La Tuna fire (2017), consumed large portions of the south face of the Verdugo range within the City limits. The La Tuna fire significantly changed the fuel beds from chaparral-shrubby species to non-native grasses and other weedy species, especially north to northwest of overhead feeder line T-14.
3. Fuels in Sunset Canyon, off of Country Club Drive, remain dense and pose a threat to the residents.
Defensible space has been provided around some of the residences along Country Club Drive.
4. The level of fire hazard in wildfire-threat Tier 2 HFTD areas prone to wildland fires is also greatly increased during periods when weather conditions of high temperatures, low humidity, and high winds (e.g., RFW days) would accelerate the spread of a wildland fire and make containment difficult. “90% of the land area burned in California occurs during wildfires that ignite on the 10% of days that meet Red Flag Warning conditions while 10% of the land area burns occurs during the 90% of fires that occur during typical weather conditions.”
5. BWP’s Tier 2 HFTD area includes brush and grass-covered areas of significant topographic relief in the Verdugo Mountain range that is susceptible to wildland fires. The most recent wildfire (La Tuna fire) in BWP’s service territory occurred in September 2017.
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neighborhoods that have been developed in the canyons, and at the base or edge of the hillsides, within the Tier 2 HFTD area. In these areas, the wildfire hazard is of significant concern. This is especially true for those older residential areas in the canyons that were built in the 1960’s to 1980’s before current ignition resistant fire and building codes.
7. Some of the older residential areas are typically reached by narrow roads that do not meet the current fire safety standards for access and egress of fire apparatus. Many roads in the canyons are also dead-end roads that are too long, do not have appropriate turnarounds at their end, and have no secondary access. Of the roads not meeting dead -end road standards, Count ry Club Drive poses by far the most serious concern regarding accessibility, as this is the only way out during a wildfire for the residents on this street.
Figure 5 - Historical fires in Burbank
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4.3.3 Evaluation of higher fire-threat areas
A component of this WMP is the evaluation of the area’s fire threat to determine whether it is accurately classified.
Based on wildfire threat analysis conducted, there was no justification for increasing the Tier fire threat level beyond its current Tier 2 designation. BWP will continue to evaluate changes to the Tier 2 HFTD in future WMPs based upon new information that is obtained during the implementation and evaluation of BWP’s WMP.
4.4 Electrical facility assessment
Figure 6 presents the portion of BWP’s service territory (e.g., feeder lines and equipment) within CPUC fire- threat areas. As illustrated in Figure 6, BWP’s electrical system is located within both Tier 2 HFTDs, and areas not considered within the HFTD (referred to as outside HFTD in this WMP). Table 3 includes the breakdown of BWP’s electric system that falls within the Tier 2 HFTD.
Table 3 - Breakdown of BWP's electrical assets within the Tier 2 HFTD BWP asset Total assets in entire system Total assets within Tier 2 HFTD Percent of total Overhead wire 204 miles 11 miles 5.4%
Underground lines 131 miles 14 miles 10.7%
Poles 10,737 643 6.0%
Overhead
transformers 4,698 184 3.9%
Overhead conventional
transformer fuses 4,698 184 3.9%
Overhead conventional
lateral fuses 2,060 45 2.2%
As shown in Table 3, approximately five percent of BWP’s total 204 miles of overhead wires are located within the Tier 2 HFTD area. In comparison, approximately 11 percent of the total underground lines occur within the Tier 2 HFTD area.
Table 3 does not include a fuse count reduction for the non-expulsive fuses expected to be installed by June 2022 (work in progress), an updated count will be provided in the 2023 WMP.
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Table 4 provides a detailed inventory of BWP assets within Tier 2 HFTD area organized by distribution feeder circuit. As indicated, there is a total of approximately 25 miles of distribution lines in Tier 2 HFTD, with 14 miles underground lines and 11 mile s overhead wire. The overhead wire and related components are the focus of this WMP as they represent the primary source of potential wildfire ignitions. Approximately 56 percent of BWP - owned electrical lines in the Tier 2 HFTD area are currently undergro und, which significantly reduces the threat of fire ignition.
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Table 4 - Inventory of BWP assets in the Tier 2 HFTD by circuit Electric
"feeder"1
Voltage
(kV)
No. of
miles
UG lines
No. of
miles
OH lines
No. of
poles
No. of
OH
transformers
No. of
OH
conventional
transformer
fuses
No. of
conventional
lateral fuses
M-5 4.16 3.9 0.4 18 11 11 0
M-8 4.16 0.0 1.23 80 20 20 8
M-11 4.16 1.83 0.45 41 9 9 7
M-13 4.16 4.58 0.8 48 11 11 4
M-15 4.16 0.0 0.46 25 8 8 0
T-10 4.16 1.2 2.3 167 48 48 12
T-14 4.16 1.54 1.53 83 24 24 3
T-19 4.16 1.0 2.91 134 38 38 9
T-21 4.16 0.0 0.08 14 2 2 1
W-11 4.16 0.0 0.9 33 13 13 1
Total 14.05 11.06 643 184 184 45
—
1 Feeder lines are identified by the substation within their circuit. W= Winona Substation; M=McCambridge Substation; and T= Town Substation.
BWP analyzed outage records for energized circuits within wildfire-threat areas. The analysis focused on recent outage data between January 2005 and December 2021 that was obtained from BWP. These records provide documentation about the frequency and cause of outages and represent the most accurate depiction of how often potential ignitions may occur within BWP’s Tier 2 HFTD . The electrical equipment risk assessment examined five categories: equipment failure, foreign object contact, vegetation contact, wire down events, and other or unspecified events. Table 5 presents the results of the analysis.
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Table 5 - Electrical equipment risk drivers based on historical events Wildfire risk
event
Number of occurrences (by circuit)
M-5 M-8 M-11 M-13 M-15 T-10 T-14 T-19 T-21 W-11 Count Percent Equipment failure
Transformer failure 1 1 1 3 5%
Conductor failure
(wires down)
3 2 8 1
14 22%
Total 17 27%
Conventional fuse operation
Transformer fuse 1 3 1 1 4 3 1 3 17 27%
Lateral fuse 2 1 3 3 9 14%
Total 26 41%
Wire contact with foreign object(s)
Wire contact -
mylar balloons
1 4 1
6 9%
Total 6 9%
Wire contact with vegetation
Wire contact -
vegetation 1
2 1 2 4
10 16%
Total 10 16%
Other
Other 1 1 1 1 1 5 8%
Total 5 8%
Total events per
feeder line
7 6 2 4 6 7 5 21 2 4 64
—
Source: BWP outage data between 1/1/2005 and 12/31/2021
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The risk event frequency for the Tier 2 HFTD area was determined to be 64 events over 17 years for 25 circuit miles of distribution line, with a driver frequency as follows:
• Equipment failure (27%, 17 potential ignitions). Failure of transformers and overhead copper conductor wire down events that could have resulted in fire ignition. • Conventional fuse operation (41%, 26 potential ignitions). Operation of a transformer or lateral fuse for a faulted condition that resulted in sparks that could have led to fire ignition. • Wire contact with foreign object(s) (9%, 6 potential ignitions): Mylar balloons or vehicles that could contact with conductors, resulting in ignition.
• Wire contact with vegetation (16%, 10 potential ignitions): Tree, tree limb, palm fronds or other vegetation contact with conductors that could result in ignition. • Other (8%, 5 potential ignition): Situations where BWP was unable to determine the cause and location of the outage . These outages are included because it is unknown whether these outages occurred on a portion of the circuit in the Tier 2 HFTD BWP has verified that these outages were not caused by an overload condition and suspects that t hese outages are likely caused by a temporary or instantaneous wire contact with a foreign object or vegetation that has vaporized or was not discovered during a patrol of the overhead distribution line after the outage.
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4.5 Prioritization of wildfire risks
Based on the findings of this risk assessment, Sunset Canyon (the upper road segment of Country Club Drive) poses the greatest risk of wildfire within Burbank’s Tier 2 HFTD. This is due to the continuity of vegetation within the canyon and density of tree canopies surrounding the residential homes.
Prioritization of the Tier 2 HFTD mitigation efforts is broken down into three sub-categories as follows:
Priority level 2.1 – Tier 2 HFTD with dense vegetation adjacent to overhead electrical facilities Priority level 2.2 – Tier 2 HFTD with low density vegetation underneath overhead electrical facilities
Priority level 2.3 – Tier 2 HFTD with no overhead electrical facilities
Priority 2.1
Priority 2.2
Priority 2.3
Figure 7 - Wildfire risk prioritization within the Tier 2 HFTD ATTACHMENT 1
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4.6 Mitigation activities that address risk drivers
Table 6 below summarizes each mitigation activity along with risk driver that it addresses. Section 5 goes into more detail for each mitigation activity.
Table 6 - Mitigation activities that address risk drivers
Mitigation activity
Risk driver addressed
Electrical
equipment failure
Conventional
fuse operation
Wire contact with
foreign object
Wire contact
with vegetation
1 Deteriorated pole replacements X X X
2 Pole loading assessments &
remediation
X
X X
3 Overloaded transformer
replacements
X X
4 Distribution construction
standards improvements
X X X
5 Conventional fuse replacements
X
6 Annual patrol inspection (GO 165) X X X
7 Vegetation management program X X
8 Intrusive pole inspections X X X
9 Block reclosing and increase relay
sensitivity during RFW
X X X
10 Line patrol after outage event
during RFW
X X X X
11 Ignition potential work practices
during RFW
X X X
4.7 Review of risk drivers and analysis
BWP works with POU associations to discuss unidentified wildfire risk drivers and mitigation measures that could address these risks . BWP participates in ongoing industry discussions regarding wildfire risks and responses to evaluate potential opportunities for improvement. BWP also continuously works with industry suppliers to identify and review new solutions to improve grid hardening and monitoring, new solutions that may improve BWP’s system and monitoring are piloted as discussed in section 5.1.
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Chapter 5. Wildfire prevention strategies and
programs
This section describes the strategies and programs BWP has implemented to mitigate the threat of electrical infrastructure-related wildfires within Tier 2 HFTD area of its service territory. As previously mentioned, the prevention strategies and programs are developed to address four primary fire safety categories:
1. Facility design and construction
2. Inspection and maintenance
3. Operational practices
4. Situational/condition awareness
5.1 Facility design and construction
5.1.1 Deteriorated pole replacements
Because pole failure could result in a wires down event and potential fire ignition, it is imperative to replace any poles that do not pass condition-based assessments. BWP prioritizes and schedules the replacement of deteriorated poles based on data obtained from intrusive pole inspections. Each year, all priority 1 and 2.1 poles are replaced per the timelines in Table 9 of Section 5.2.3.
Since 2018, BWP has replaced 50 deteriorated poles in our Tier 2 HFTD area, which is about 8% of the poles in our Tier 2 HFTD. In 2021, BWP replaced all poles that were identified as priority 1 or 2.1. A total of 5 deteriorated poles were replaced including 5 priority level 2.1 poles. All poles installed in the Tier 2 HFTD in 2021 were composite poles.
As described further in Section 5.1.4 , BWP will continue replacing additional poles with composite poles in the Priority 2.1 area of its Tier 2 HFTD where the benefits of a composite pole (I.e., increased strength, fire resistance, and ease of installation in difficult terrain) are deemed appropriate by BWP.
5.1.2 Pole loading assessments & remediation
Wind Loading is also an important factor in the prevention of pole failure. BWP designs poles to meet or exceed the wind loading criteria set in General Order 95 (GO 95) in order to minimize the chance of pole failure during heavy winds. BWP will perform this loading analysis on all of the poles located within the Tier 2 HFTD. Any poles that do not pass the wind loading criteria are scheduled for replacement. In some cases, poles may only require additional guying reinforcement to meet wind loading criteria.
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By the end of 2020, BWP completed pole loading analysis of all poles inside BWP’s Priority 2.1 Zone (see Figure 7) having dense vegetation near overhead facilities.
In 2021, pole loading analysis was performed on 5 poles within the Tier 2 HFTD. This included an analysis of the 5 deteriorated poles that were replaced.
5.1.3 Overloaded transformer replacements
Distribution transformers are another identified risk because failure could lead to the expulsion of sparks or material that could cause a fire ignition. Ensuring that transformers are not excessively loaded past their capacity can help mitigate failures due to internal faults. Each year BWP uses advanced data analytics to measure the loading levels of every transformer in the electric system. Any transformers that exceed the loading criteria of 175% are scheduled for replacement.
Excessive transformer loading can also lead to transformer fuse operations to occur during high heat days. If the transformer is fused with a conventional fuse, fuse operation could expel sparks that could lead to fire ignition. As discussed in section 5.1.5, all conventional transformer fuses will be replaced with CALFIRE “Exempt” fuses by June 2024. While this will eliminate potential ignition events from conventional transformer fuse operations, excessive transformer loading will still have an igniti on risk from transformer equipment failure. Therefore, in the Tier 2 HFTD, BWP uses a more conservative loading criteria of 150% as a threshold for proactive transformer replacement.
In 2021, BWP replaced 3 transformers in the Tier 2 HFTD that exceeded the 150% loading threshold. As a result, there were no transformer failures in the Tier 2 HFTD.
5.1.4 Distribution construction standard improvements
As an ongoing fire prevention strategy BWP will continuously evaluate distribution construction standard improvements that could reduce the risk of ignitions and harden its electric system in the Tier 2 HFTD. This will include components of the electric system such as fuses, overhead conductor, and detection & isolation technology.
Each electrical facility location within the Tier 2 HFTD will be analyzed to determine where material upgrades or the installation of new technology would be appropriate, as some locations may not have vegetation present. Ongoing evaluation is necessary to study and implement new technologies and new developments in industry best practices.
BWP has completed some preliminary efforts towards its engineering study of distribution construction standard improvements including the following:
• Field reclosers: BWP completed an initial evaluation of field recloser technology in fiscal year 2021/2022.
This evaluation analyzed the use of field reclosers in conjunction with falling conductor detection to allow for added isolation, reduced customer impact, and increased sensitivity settings. BWP determined that other mitigation activities could have a hig her risk reduction -to-cost ratio. The final determination of whether BWP will invest in this technology will be made once the falling conductor detection engineering study is completed in fiscal year 2022/2023.
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• Falling conductor detection: In order to focus on other mitigation activities having a higher risk reduction- to-cost ratio, BWP has moved its review of falling conductor protection for one or two radial circuits in BWP’s Tier 2 HFTD to fiscal year 2022/2023.
• Composite poles: BWP installed two modular composite poles in the Tier 2 HFTD as a pilot project in 2019.
These poles, which are manufactured by Highland Composites, are constructed in 3 modular sections, which allow the field crews to assemble the pole in place. Many poles in th e Tier 2 HFTD are very difficult to access during replacement due to the existing hillside terrain. This modularity allows for a significant gain in crew efficiency and safety during construction. Additional benefits of composite poles include increased st rength, greater fire resistance, greater longevity, and a reduction in maintenance and inspection costs. The pilot was successful; however, Highland Composite ceased composite pole production. Later in fiscal year 2021/2022, BWP complete d an additional pilot of 5 composite pole installations in fiscal year 2021/2022 using a different manufacturer – RS Poles. After this pilot, BWP has made a final determination to continue replacing poles with composite poles in the Priority 2.1 area of its Tier 2 HFTD where the benefits of a composite pole (I.e., increased strength , fire resistance, and ease of installation in difficult terrain) are deemed appropriate by BWP. • Replacement of #6 bare copper conductor in the Tier 2 HFTD: After an analysis of outage events in the Tier 2 HFTD, BWP has found that #6 bare copper conductor has been present in all “wires down” events. For new construction, BWP uses #2 aluminum conductor steel reinforced (ACSR) as a standard for local circuit segments that branch off from a main backbone. The increased strength gained from this steel reinforcement help reduce “wires down” events in the Tier 2 HFTD . BWP also evaluated the use of ACSR covered conductor as a replacement option. Covered conductor has a layer of insulation around the main high strength ACSR conductor. This insulation would prevent outages (and risk driver events) from wire - to-wire contact and wire contact with foreign objects or vegetation. BWP will complete a full analysis by June 2022.
• Non-oil filled pole mounted transformers: BWP will pilot the installation of non -oil filled pole mounted transformers as a fire risk reduction strategy . Once the pilot is complete a decision on the use of non-oil filled transformers in the Tier 2 HFTD will be made.
• Pole mounted sensor packages: BWP will pilot installation of pole mounted sensor packages on 50 poles on T-14 circuit in the Tier 2 HFTD to detect distribution grid faults and continuously monitor equipment degradation or anomalies. Once the pilot is complete a decision on the use of sensor packages on all poles in the Tier 2 HFTD will be made.
5.1.5 Conventional fuse replacements
Conventional fuses are used in the electric system to protect transformers and wires from damage during faul t conditions. These conventional fuses are expulsive in nature and may generate electrical arcs, sparks or hot material during normal operation. Conventional fuse operations account for 47% of BWP’s risk driver events. To further reduce the risk of wildfir e, BWP has created a program to replace all conventional fuses in the Tier 2 HFTD with CALFIRE “Exempt” fuses as determined in the “California Power Line Fire Prevention Field Guide.” These “Exempt” fuses clear faults faster and reduce the fault energy. Th is minimizes electrical arcs and sparks during fault events and minimizes the impact of a fault on electrical equipment along the circuit.
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By June 2022, BWP will replace all conventional fuses with CALFIRE “Exempt” fuses in the Priority 2.1 zone of the Tier 2 HFTD. The Priority 2.1 zone contains 36 transformer fuses and 7 lateral fuses. By June 2024, BWP will replace the remaining 148 transformer fuses and 38 lateral fuses in the Tier 2 HFTD.
5.2 Inspection and maintenance
5.2.1 Annual patrol inspection (GO 165)
In general, BWP performs electrical infrastructure patrol inspections to inspect each component of the electrical system to check that no obvious abnormalities exist to the extent possible. BWP performs these inspections on a cycle that meets or exceeds the timeframes given in General Order 165 (GO 165). During these inspections, problems are identified, prioritized and corrected. Table 7 below summarizes the inspection cycles.
Table 7 - Distribution inspection cycles (maximum interval in years)
Component Patrol Inspection Detailed Inspection Intrusive Inspection Overhead Component Inspection 1 8
Padmounted Transformer 1 5
Padmounted Switch 1 5
Padmounted Regulator/Capacitor 1 5
Component Patrol Inspection Detailed Inspection Intrusive Inspection Wood Poles over 15 years old which have
not been subject to intrusive inspection
1 10*
Wood Poles less than 15 years old 1
Wood poles which have passed intrusive
inspection
1 20
—
*Within 10 years or prior to 25 years of age
As noted in Table 13 of its Performance Metrics, BWP completed 100% of its annual patrol inspections for pole s within the Tier 2 HFTD in 2021.
5.2.2 Vegetation management program
BWP meets or exceeds the minimum industry standard vegetation management practices. For all electrical facilities, BWP meets: (1) Public Resources Code section 4292; (2) Public Resources Code section 4293; (3) GO 95 Rule 35; and (4) the GO 95 Appendix E Guidelines to Rule 35. These standards require significantly increased clearances in the High Fire Threat District. The recommended time-of-trim guidelines do not establish a ATTACHMENT 1
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mandatory standard, but instead provide useful guidance to utilities. BWP will use specific knowledge of growi ng conditions and tree species to determine the appropriate time of trim clearance in each circumstance. Table 8 below summarizes BWP’s vegetation clearances.
Table 8 - Vegetation clearances
Outside Tier 2 HFTD Within Tier 2 HFTD
Minimum clearance at all times between 4kV overhead
lines and vegetation 18 inches 4 feet
At time of trim, minimum trimming clearance between
4kV overhead lines and vegetation
4 feet 12 feet
BWP performs routine vegetation management, such as pruning and removal, on an annual basis in the Tier 2 HFTD.
Each year, field patrols are performed to inspect tree and conductor clearances and to identify any hazard trees.
Areas for vegetation pruning and removal are targeted based on the results of these patrols. BWP hires contracted line clearance tree trimming crews to trim vegetation near its electrical lines. The tree crews will trim a minimum of 12 feet of clearance. BWP’s tree trimming contractors are specialists, supervised by a certified arborist . The tree crews are knowledgeable about work near energized electric lines and about trees, growth rates, and pruning methods that maintain tree health.
As noted in Table 13 of its performance metrics, BWP completed 100% of its vegetation management inspections and trimming for poles within the Tier 2 HFTD in 2021. Over the past year, BWP and its tree-trimming contractor performed an extensive line clearance work as part of its vegetation management program by trimming 213 trees and removing 1 “problem” tree, which would have created a potential fire hazard.
5.2.3 Intrusive pole inspections
BWP performs intrusive inspections on all poles in the electric system according to the cycle intervals in Table 7.
The inspections provide information on the amount of rot and decay inside each pole to measure the amount of remaining strength left in the pole before replacement is necessary. Each pole is given a rating that determines the priority and schedule of replacement. Table 9 summarizes the priority system.
Table 9 - Priority level of deteriorated poles based on intrusive inspections
Priority level Recommended action
1 Immediate replacement
2.1 Replace within 1 year
2.2 Replace within 3 years
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Priority level Recommended action
2.3 Replace within 5 years
3 Replace when practical
All intrusive pole inspections were completed for the Tier 2 HFTD by the 2nd quarter of 2019 and prioritized within the time frames noted above. Of the 5 deteriorated poles replaced in 2021, there were zero priority level 1 poles, 5 priority level 2.1 poles, and zero priority level 2.2 poles.
5.3 Operational practices
5.3.1 Block reclosing and increase relay sensitivity during RFW
BWP has reclosing capabilities on all substation circuit breakers in the electrical system. Under normal operation, once a fault is detected the circuit will first open and will attempt to reclose the circuit to test if the fault condition still exists. The circuit will make two total attempts to reclose the circuit and will remain open and locked out if unsuccessful. In the Tier 2 HFTD, each attempt to reclose the circuit could cause a spark if fault conditions are still present. This could potentially lead to an ignition of vegetation. For this reason, BWP enacted an operating procedure to block reclosing capabilities on all circuits in the Tier 2 HFTD during RFW conditions to prevent any potential for vegetation ignitions. Additionally, more sensitive, quicker acting relay settings are employed during RFW conditions to increase the chance of detecting and isolating a fault.
In 2021, BWP blocked reclosing and enabled more sensitive relay settings on RFW alert days for all circuits that extend into the Tier 2 HFTD. In 2021 there were 4 RFW events totaling 11 days.
5.3.2 Line patrol after outage event during RFW
If a circuit within a Tier 2 HFTD sees a fault during RFW condi tions, field crews will perform a patrol of the entire circuit to locate the cause of the fault. The ECC dispatcher will wait for confirmation of the patrol inspection to ensure no fire ignition risks are present when the circuit is re-energized.
The following is a summary of the outages that occurred on Tier 2 HFTD circuits during RFW days:
• 11/24/2021 – Outage on M-13 circuit occurred during a RFW condition. A line patrol was performed prior to re-energizing the circuit and the cause was found to be cont act with vegetation. Tree branches were removed from the overhead lines and the circuit was re-energized. • 11/24/2021 – Outage on T-19 circuit occurred during a RFW condition. A line patrol was performed prior to re-energizing the circuit and the cause was found to be contact with vegetation. After the vegetation was cleared and the lines were rebuilt, the circuit was re-energized. • 11/24/2021 – On T -19 circuit the outage management system reported loss of power during a RFW condition. A line patrol was performed, and the cause was found to be a fuse operation and a downed line.
After the line was repaired the fuse was replaced and service was restored.
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5.3.3 Ignition potential work practices during RFW
BWP enhanced the safety of its work practices associated with Ignition Potential Work (IPW) within the Tier 2 HFTD during RFW conditions. IPW is any work having the potential to produce an ignition source to areas adjacent to the work location. BWP’s ECC has issued a procedure to notify BWP construction and maintenance crews when an RFW condition exists.
During the RFW, IPW within the Tier 2 HFTD shall not be performed except in response to an emergency. In addition, emergency IPW in the Tier 2 HFTD shall be performed with strict adherence to all required safety precautions including the following:
• A pre-job briefing to review the pre-job briefing form, work plan, and fire safety measures. • Removal, covering, or wetting of all combustible fuels below or adj acent to the work area as much as practical.
• Readily accessible fire extinguisher with a minimum rating of 3-A-40 BC, a 5-gallon bucket of water, sand or clean dirt, and a round point shovel.
• FR rated clothing worn by all involved personnel.
Any ignitions will be immediately extinguished (as possible) by site personnel and shall be monitored and verified as out and cool by crew supervisor or their designee, prior to leaving the area. BWP will also notify the Burbank Fire Department of any fire, even if extinguished. For record keeping purposes, the ECC shall be informed of all ignitions.
11 RFW days occurred in 2021. No ignition potential work was performed within the Tier 2 HFTD on any RFW days.
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5.4 Situational/conditional awareness
5.4.1 Weather/fire monitoring
The National Weather Service may issue RFWs at any time when humidity and wind conditions meet pre - determined thresholds that would promote fire ignition and spread. BWP’s electrical system is located within an area of Los Angeles County that is actively monitored for fire weather conditions. The N ational Weather Service monitors humidity, wind, and temperatures and will declare RFWs and watches (https://www.weather.gov/sgx/), signaling that fire weather is anticipated. BWP’s ECC monitors National Weather Service warnings and watches and coordinates with other agencies and third parties in the area.
Additionally, the ECC will use the fire-monitoring camera stationed in the peak of the Verdugo Mountains to enhance situational awareness of wildfires on an as -needed basis. This camera is owned and operated by Southern California Edison. The camera offer s a 360-degree view of the Verdugo Mountains, including BWP’s Tier 2 HFTD.
The live feed is publicly available and can be viewed at the link below:
Verdugo Peak 2 camera:
http://www.alertwildfire.org/orangecoca/index.html?camera=Axis-VerdugoPeak2&v=7a7f1c3
BWP’s ECC monitored National Weather Service warnings and issued alerts to BWP staff for each of the 11 RFW alert days that occurred in 2021.
5.4.2 Geographic information system (GIS) applications
BWP has implemented a GIS system as well as GIS –based applications to improve situational awareness of the electrical system. Using a fully implemented advanced metering infrastructure (AMI) network, BWP’s smart meters will detect an outage and send out a fault message, which is picked up by the Outage Management System (OMS). The OMS helps ECC operators pinpoint the geographic location of the outage as well as the potential electrical component involved. This allows BWP crews to respond faster to the outage location.
BWP’s GIS and OMS applications were continually up dated throughout 2021, allowing BWP crews to respond faster to outage locations.
5.4.3 Enhanced system monitoring
As discussed in Section 5.1.4, BWP is pursuing a pilot project to test new system monitoring devices on 50 poles on T-14 circuit within the Tier 2 HFTD. These devices are equipped with several optical, environmental, and mechanical sensors that have the potential to provide high visibility at every pole and span location. When processed, the data collected could provide continuous asset health information, improve fault location and response time, rapidly detect fire ignitions, and provide more granular weather monitoring. The pilot proj ect will be completed in fiscal year 2022/2023. Results of the pilot project will be shared in future WMP updates.
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5.5 Public safety power shutoff
A public safety power shutoff (PSPS) is a mitigation method used among several electrical utilities throughout California. This mitigation method employs pre -emptive de -energization of electrical lines when predicted extreme weather conditions would create too great of a risk of a wildfire being ignited by electrical facilities. BWP has evaluated this approach and has determined that a PSPS is not a necessary mitigation activity due to several reasons:
• BWP’s compact, urban service territory and accessibility allows for rapid response times from the Burbank Fire Department and BWP electrical field personnel.
• BWP’s situational awareness of its electrical system allows for rapid, targeted response to outage event locations. This allows personnel to identify whether any risk driver events led to any ignitions, which allows the Burbank Fire Department to respond quickly and limit any further potential spread. • BWP’s mitigation activities as described in Section 5 of the WMP further reduce the risk of its facilities igniting a wildfire in the Tier 2 HFTD
While BWP does not plan to implement a PSPS i n its service territory, BWP’s ECC personnel have the authority to de -energize portions of the electrical system for safety, reliability, or during emergency conditions when requested by the Burbank Fire Department, Burbank Police Department, CALFIRE, or o ther emergency responding agencies. As the WMP is updated each year, BWP will continue to consider if a PSPS strategy is an appropriate mitigation activity for its electrical system.
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Chapter 6. Emergency preparedness and response
6.1 Emergency management
BWP responds to emergencies in accordance with its Emergency Response Plan and in alignment with the State Standardized Emergency Management System (SEMS) and federal National Incident Management System (NIMS). In responding to all -hazard emergencies, BWP staff would be organized based on SEMS and NIMS as outlined in BWP’s Emergency Response Plan. The BWP Emergency Response Plan is comprised of separate plans for Electric, Power Supply, Telecommunication, and Water System. Each plan calls for convening a gr oup of experts, or Emergency Response Teams, to respond and coordinate efforts pertaining to any situation where communication and control of an incident would be needed. Once assembled, these Emergency Response Teams will assess a situation and make a rec ommendation to the General Manager whether to declare a department system emergency and activate the BWP Emergency Response Plan. The declaration of a department system emergency shall be by the General Manager, by which the Emergency Response Plan would be activated.
BWP’s Emergency Response Team is comprised of four teams: Operational Technology, Electric Services, Power Supply, and Water. The collective work of these teams consists of preparing for, responding to, and recovering from incidents that may affect BWP operations.
To respond and recover effectively from all hazards and threats, such as wildfires, the Electric Services Team follows guidelines that are detailed in the Electric Emergency Response Plan (EERP).
The EERP may be activated whenever any of the following conditions exist:
• Natural disaster
• Predicted load shedding
• Loss of distribution, one-third or more of the distribution system, or generation facility where load is not transferrable
• Emergency curtailment
• Major civil disturbance
The Electric Services Response Team is comprised of four response teams: Damage Assessment, Planning/ Intelligence, Construction, and Logistics as presented in Figure 7. The responsibilities of each response team are described in Table 10 below.
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Figure 8 - BWP Emergency Response Team organization
Emergency Operations
Center
Department Operations
Center
Communications
Operational
Technology
Electric Services
Power Supply
Water
Damage Assessment
Planning/Intelligence
Construction
Logistics
—
Source: BWP Emergency Response Plan
Table 10 – Electric Services Team responsibilities during an emergency response event Team Responsibilities
Damage Assessment
• Visit affected areas to identify safety issues and determine extent of damage • Estimate labor, material, and equipment needed for restoration • Submit information to Restoration Team
Planning/Intelligence
• Prioritize and coordinate restoration according to the Restoration Philosophy • Maintain system integrity
• Ensure continued operation
Construction
• Assign and manage construction crews
• Coordinate with mutual aid crews
Logistics
• Obtain, manage, and control materials and equipment to support Operations and Construction teams
• Maintain communication and technology systems to support all teams —
Source: BWP Emergency Response Plan
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6.1.1 BWP Department Operations Center
BWP’s is responsible for coordinating BWP’s emergency management activities and activation of the Department Operations Center (DOC). The activation of the DOC assembles the internal subject matter experts for the Electric Services Response Team to assess and provide situational awareness to internal and external stakeholders/Assistant General Managers and providing incident planning objectives and subsequent response.
6.2 Disaster and emergency response
BWP EERP is consistent with BWP’s system wide response approach. The BWP EERP is customized to provide a framework by which BWP can respond effectively to wildfire threats and other hazards. BWP recognizes its essential role in both restoring normalcy after an incident and the importance of the utility sector to the daily lives of customers and stakeholders and the region’s economic well -being and security. The WMP reflects these considerations and is intended to be a framework for BWP’s engagement with external entities and the citizens of Burbank.
In the event of a disaster, BWP expects to utilize experienced electric staff and affiliate support to perform incident response and management. Roles and responsibilities are divided by functional areas and the emergency response is led by an area commander or an incident commander (IC), depending on incident scope or complexity.
BWP will use the Incident Command System (ICS) as the foundation for its incident response organization. ICS is a standardized, on-scene, all-hazard incident management concept, which provides responders with an integrated organizational structure to match the complexities and demands of single or multiple incidents. Through the use of span of control manageme nt and a top -down organizational structure, ICS helps ensure full utilization of all incident resources, decreases confusion, and improves communication. As a system, ICS both provides an organizational structure for incident management, and guides the pro cess for planning, building, and adapting that structure.
When an incident affects multiple entities and/or jurisdictions, a Unified Command structure may be established.
The Unified Command organization consists of the ICs from the various jurisdictions or agencies, who form a single command structure and work together to make joint decisions. Institutions and responding agencies blend into an integrated, unified team.
A unified approach results in:
• A shared understanding of priorities and restrictions. • A single set of incident objectives.
• Collaborative strategies.
• Improved internal and external information flow.
• Less duplication of efforts.
• Better resource utilization.
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By utilizing this emergency response framework, BWP will maintain a coordinated and standardized approach for activating and establishing the emergency response organization. The emergency response framework, along with all associated plans, serves to safeguard BWP’s ability to meet its essential missions and functions und er wildfire threats and hazards, with or without warning, in preparation for or during any incident, regardless of its expected duration.
6.2.1 Fire agency emergency response
In addition to its internal emergency preparedness procedures, emergencies including active fire within BWP’s Tier 2 HFTD would be responded to by a robust City fire-fighting system. BWP distribution lines are located within the Burbank Fire Department responsibility area. Emergency response for BWP distribution lines would be provid ed by the Burbank Fire Department along with Los Angeles County Fire and other agencies, as needed, under existing mutual and automatic aid agreements. The available firefighting resources are considered sufficient to respond to wildfires in BWP’s Tier 2 HFTD.
6.3 Customer support during emergencies
Customer support is applicable in emergency situations given the BWP’s service area and customer base. BWP includes a communications protocol for communication and coordination with its primary stakeholders, which include Burbank Fire Department, City Manager, other utilities, elected officials, fire agencies and first responders, and BWP’s emergency response support team. Communication with customers impacted by the de- energizing of electrical lines during an emer gency would be initiated using BWP’s standard communication protocols.
6.4 Restoration of service
Restoration of the electric system would occur in accordance with the BWP Emergency Response Plan. After a wildfire, BWP’s Department Operations Center (DOC) will coordinate restoration of service in alignment with direction from the City of Burbank’s Emergency Operations Center (EOC).
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Chapter 7. Performance metrics and monitoring
7.1 Accountability of the plan
BWP’s General Manager has overal l responsibility for the WMP. Other members of the management team are responsible for executing the various components of the WMP. Table 11 below lists each component of the WMP along with the corresponding owner.
Table 11 - Accountability for WMP components
Mitigation activities Activity owner
Design and construction
1 Deteriorated pole replacements Manager, T&D Engineering 2 Pole loading assessments & remediation Manager, T&D Engineering 3 Overloaded transformer replacements Manager, T&D Engineering 4 Distribution construction standards improvements Manager, T&D Engineering 5 Conventional fuse replacements Manager, T&D Engineering Inspection and maintenance
6 Annual patrol inspection (GO 165) Manager, Electrical Distribution 7 Vegetation management program Manager, Electrical Distribution 8 Intrusive Pole Inspections Manager, T&D Engineering
Operational practices
9 Block reclosing during RFW Manager, Energy Control Center 10 Line patrol after outage event during RFW Manager, Electrical Distribution 11 Ignition potential work practices during RFW Manager, Electrical Distribution Situational/conditional awareness
12 Weather/fire monitoring Manager, Energy Control Center 13 Geographic information system (GIS) applications Manager, T&D Engineering 14 Enhanced system monitoring Manager, T&D Engineering
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7.2 Metrics to evaluate plan performance
BWP’s performance metrics are focused on the success of fire prevention strategies at lowering the risk of catastrophic wildfires. The metrics process would evaluate the effectiveness of a fire prevention strategy in reducing the risk of wildfire ignition and spread. This p erformance metric tracking approach will utilize a format that offers the ability to track compliance trends over time, correct issues as they occur, and adapt metrics as conditions mandate.
These metrics will be measured by BWP personnel at timeframes in dicated, and as needed to ensure adequate goal achievement tracking. As with this WMP, overall performance metrics will be managed according to an adaptive management approach, which will facilitate changes in the measures and metric goals, as well as the measurement timeframes, if determined necessary. However, BWP recognizes that there may be unforeseen circumstances that result in the inability to meet a specific metric goal for a given timeframe. This does not necessarily indicate a failure in the proce ss that requires immediate action. The overall metric goal achievement trend will be the focus of this performance measurement process, with a primary focus on maintaining upward trending performance.
7.2.1 BWP performance metrics
Performance metrics are derived from and address program measures by fire safety category. Table 12 provides the performance metrics developed to directly address the identified primary wildfire risk drivers.
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Table 12 - BWP wildfire prevention performance metrics
Category Metric Responsible Frequency
Equipment failure
Number of wire down events caused by conductor failure in Tier 2 HFTD
T&D Engineering
Manager
Annually
Number of pole failures in Tier 2 HFTD
Number of transformer failures in the Tier 2 HFTD
Conventional fuse
operations
Number of conventional transformer fuse operation
events in Tier 2 HFTD
T&D Engineering
Manager Annually
Number of conventional lateral fuse operation events in Tier 2 HFTD
Number of non-expulsive “Exempt” transformer fuse
operation events in Tier 2 HFTD
Number of non-expulsive “Exempt” lateral fuse operation events in Tier 2 HFTD
Wire contact with
foreign object(s)
Number of outage events caused by wire contact with an
animal in Tier 2 HFTD
T&D Engineering
Manager
Annually Number of outage events caused by wire contact with mylar balloons in Tier 2 HFTD
Number of pole failures caused by vehicle contact in the Tier 2 HFTD
Wire contact with
vegetation
Number of outage events caused by wire contact with
vegetation in Tier 2 HFTD
T&D Engineering
Manager Annually
Intrusive pole
inspections
100% of intrusive pole inspections in the Tier 2 HFTD
completed T&D Engineering
Manager Annually
Summary of pole replacements based on priority level
determined by intrusive inspections in Tier 2 HFTD
Inspection and
maintenance
Number of trees trimmed in the Tier 2 HFTD
Manager Electric
Distribution Annually
Number of recurring “problem” trees removed in Tier 2
HFTD
100% of vegetation management inspections in the Tier
2 HFTD completed on time
100% of patrol inspections of overhead facilities in the Tier 2 HFTD completed
Operations
Number of outages on circuits in Tier 2 HFTD
ECC Manager Annually
Number of outages on circuits in Tier 2 HFTD during
RFW days
Number of ignitions caused by BWP electrical infrastructure in Tier 2 HFTD
Extreme weather
conditions Number of RFW days ECC Manager Annually
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7.2.2 Annual performance metrics
Table 13 - 2021 BWP wildfire prevention performance metrics Category Metric
Equipment failure
Number of wire down events caused by conductor failure in Tier 2 HFTD 3 Number of pole failures in Tier 2 HFTD 0
Number of transformer failures in the Tier 2 HFTD 0
Conventional fuse
operations
Number of conventional transformer fuse operation events in Tier 2 HFTD 0 Number of conventional lateral fuse operation events in Tier 2 HFTD 2
Wire contact with
foreign object(s)
Number of outage events caused by wire contact with an animal in Tier 2 HFTD 0
Number of outage events caused by wire contact with mylar balloons in Tier 2 HFTD 1
Number of pole failures caused by vehicle contact in the Tier 2 HFTD 0
Wire Contact with
Vegetation
Number of outage events caused by wire contact with vegetation in Tier 2 HFTD 3
Number of trees trimmed in the Tier 2 HFTD 213
Number of recurring “problem” trees removed in Tier 2 HFTD 1
Inspection and
Maintenance
Percentage of vegetation management inspections in the Tier 2 HFTD completed on time 100%
Percentage of patrol inspections of overhead facilities in the Tier 2 HFTD completed
100%
Percentage of intrusive pole inspections in the Tier 2 HFTD completed 100% Poles replaced based on priority level
determined by intrusive inspections
in Tier 2 HFTD
Priority 1 N/A
Priority 2.1 5
Priority 2.2 N/A
Operations
Number of outages on circuits in Tier 2 H F T D 10
Number of outages on circuits in Tier 2 HFTD during RFW days 3 Number of ignitions caused by BWP electrical infrastructure in Tier 2 HFTD 1 Extreme Weather
Conditions
Number of RFW days 11
A summary of the risk driver events that occurred in 2021 is shown in Table 14 below. For reference, a broader, multi-year period of historical outage information was previously highlighted in Table 5 of Section 4.4.
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Table 14 - 2021 summary of risk driver events in the Tier 2 HFTD Date of
outage
Voltage
(kV)
Circuit
no.
Cause of
outage
Risk driver events
During RFW
alert?
3/20/2021 4.16 T-19 Mylar balloons
-Equipment failure – conductor
failure (wires down)
-Wire contact with foreign
object – mylar balloons
N
3/24/2021 4.16 T-19 Vegetation contact
-Equipment failure – conductor
failure (wires down)
-Conventional fuse operation –
lateral fuse
-Wire contact with vegetation
N
7/23/2021 4.16 W-11 Other Wire contact – unknown N
11/24/2021 4.16 M-13 Vegetation contact -Wire contact with vegetation Y 11/24/2021 4.16 T-19 Vegetation contact
-Equipment failure – conductor
failure (wires down)
-Conventional fuse operation –
lateral fuse
-Wire contact with vegetation
Y
An assessment of the above performance metrics above is provided in Section 7.3.3 as part of the annual internal audit.
7.3 Monitoring and auditing the plan
BWP will perform an internal audit of the WMP annually to monitor the effectiveness of the plan. This internal audit will align with BWP’s planning and budgeting process. This review will include an assessment of the previous plan metrics as well as the effectiveness of the WMP mitigation acti vities. After the completion of the annual internal audit, the WMP will be updated accordingly. As part of the 2022 annual WMP update, BWP performed an internal audit to monitor the effectiveness of the plan as discussed in Section 7.3.3.
7.3.1 Identifying and correcting deficiencies in the WMP
At any point in time when deficiencies are identified, they should be corrected through BWP Management.
BWP has monitored and audited the implementation of its WMP in 2021. No deficiencies in the WMP or i ts implementation were found.
7.3.2 Monitoring and auditing the effectiveness of inspections
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findings are examined to identify trends and recurring problems. These findings will be combined with analysis of performance metrics to develop changes to design, construction or maintenance standards and practices to that the overall performance of the electric system, including safety and reliability, is improved.
BWP has monitored and audited the effectiveness of electrical equipment inspections in 2021, including inspections performed by its vegetation management contractor. As indicated in the WMP performance metrics in Table 13, all inspection, maintenance, and operation activities associated with this plan were completed in the Tier 2 HFTD in 2021 and no wildfires were caused by BWP’s electrical equipment.
7.3.3 Annual internal audit
BWP performed an internal audit to measure the effectiveness of its WMP in 2021 using the following methods:
• Assessment of performance metrics
• Consideration of recommendations in the Independent Evaluation Report dated May 15, 2020, by BWP’s independent evaluator, Guidehouse.
• Review of mitigation activity accomplishments
Assessment of performance metrics
The following assessment was made regarding the 2021 WMP Performance Metrics listed in Table 13, Section 7.2.2:
• On March 20, 2021, an ignition was caused by BWP’s electrical equipment. The cause of the ignition was due to a mylar balloon coming into contact with overhead wires, which subsequently failed and fell to the ground.
This “wires down” event ignited ground level vegetation but did not spread into a wildfire. BWP field crews responded quickly to the event and were able to isolate the circuit to allow for the Burbank Fire Department to extinguish the ignition. This is the first known ignition caused by BWP’s electrical equipment. While this event did not result in a wildfire, BWP recognizes the importance of continuing to find ways to further reduce the risk of any ignitions in the Tier 2 HFTD by implementing the many mitigation measures found in this WMP. • In 2021, 10 risk driver events occurred in the Tier 2 HFTD. Two events (20%) were attributed to conventional fuse operations for laterals and transformers. Conventional fuse operation is a risk driver accounting for the largest percentage of outages, both this year, and historically in the Tier 2 HFTD. BWP has created a program to replace all conventional fuses in the Tier 2 HFTD with CALFIRE “Exempt” fuses as discussed in Section 5.1.5. • Seven risk driver events (70%) involved wire contact with foreign objects or vegetation and “wires down” events. All of these events involved #6 bare copper conductor. BWP has identified this type of wire as an opportunity to implement constru ction standard improvements in the Tier 2 HFTD in order to reduce the likelihood and frequency of these type of events. BWP is on track to complete the analysis of this study by June 2022 and will provide a summary of the findings in the 2023 WMP update. • There was one outage (33%) with an unknown cause and location that occurred on July 23, 2021. This event is not included in the Table 13 performance metrics but was included in the list of risk driver events in Table 14 to provide an accurate number of potential risk driver events in the Tier 2 HFTD. In addition, this outage was also included in the electrical equipment risk driver historical outages in Table 5 of Section 4.4. While the cause of this outage is not known, there is a high likelihood that the outage was caused by a wire in contact with a foreign object or vegetation because it was not due to an overload condition. • There were no pole failures in the Tier 2 zone. The absence of no pole failures in the Tier 2 zone is a direct result of BWP’s active efforts over the past several years with deteriorated pole replacements, intrusive pole inspections, pole loading assessments and remediation, and annual patrol inspections.
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• All inspection, maintenance, and operation activities associated with this plan were completed in the Tier 2 HFTD. Over the past year, BWP and its tree trimming contractor performed an extensive line clearance work as part of its vegetation management program by trimming 213 trees and removing 1 “problem” tree which would have created a potential fire hazard. In addition, BWP enacted procedures to block reclosers, patrol the circuit before re-energizing a tripped circuit, and restrict ignition producing work during an RFW alert. • There were 11 days with RFW alerts. BWP will continue monitoring this metric in the future to gauge if there is an uptick in the number of RFW alerts which may occur due to climate change.
Consideration of Independent Evaluation Report recommendations As discussed in Sect ion 8.3, BWP had contracted with a qualified independent evaluator in 2020 to assess the comprehensiveness of its WMP. While the Independent Evaluator established that the WMP was comprehensive and met statutory requirements, the Independent Evaluator also provided a comparison of BWP’s mitigation measures with industry best practices and apprised BWP of additional mitigation measures/best practices to consider . Below is a summary of BWP’s consideration of those additional best practices mentioned in the Independent Evaluation Report. • Replacing bare wires with covered conductors.
o IE Report: Replacing bare wires with covered conductors is a common best practice. BWP will benefit from completion of the engineering evaluation study and may wish to install co vered conductors at that time.
o BWP Consideration: 25% of risk driver events since 2005 are associated with wire contact with foreign objects and vegetation. With exception to abnormal events that sever or take down a power line, replacing bare wires with covered conductors could mitigate that risk. An engineering evaluation study will be completed by June 2022 to review the cost, technology, and effectiveness of a covered conductor solution for the highest priority circuits within the Tier 2 HFTD. • Steel or composite poles swapped or fireproofing wooden poles (fire resistant material coating). o IE Report: Completion of the evaluation for the use of fire resilient materials for distribution poles within Tier 2 may provide storm hardening benefits.
o BWP Consideration : Stronger steel or composite poles are not expected to reduce BWP’s risk of wildfires because BWP has not had any wind loading related pole outage events as a result of its effective mitigation measures including deteriorated pole replacements, pole loading assessments, intrusive pole inspectio ns, and annual patrol inspections . However, BWP recognizes the value of composite poles, which do not require intrusive pole inspections and often require less pole guying to meet pole loading standards . BWP has completed a pilot of 7 composite pole instal lations using 2 separate manufacturers - Highland Composite and RS-poles. An engineering evaluation study showed that composite poles are a viable mitigation measure and will be utilized for pole replacements in the Priority 2.1 area of BWP’s Tier 2 HFTD where the benefits of a composite pole (I.e., increased strength, fire resistance, and ease of installation in difficult terrain) are deemed appropriate by BWP. • Expulsion fuse device change out to current-limiting (non-expulsive) fuses. o IE Report: Replacement of expulsion fuses with non -expulsion fuses is a common best practice.
Completion of the engineering evaluation for the use of non-expulsion fuses for new construction, and replacement construction within Tier 2 may provide wildfire hardening benefits. o BWP Consideration : 41% of risk driver events since 2005 are associated with conventional fuse operations within the Tier 2 HFTD . Replacing conventional fuses with non -expulsive fuses will eliminate this ri sk driver. After performing a n engineering evaluation study in 2021 , BWP has determined that replacement of all conventional fuses in the Tier 2 HFTD with CALFIRE “Exempt” ATTACHMENT 1
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fuses is a cost -effective method of reducing the risk of utility caused wildfires in the Tier 2 HFTD.
Further discussion of this conventional fuse replacement program can be found in Section 5.1.5. • Infrared corona scanning and high-definition imagery technology for inspection practices along with visual inspections.
o IE Report: “Annual infrared inspections of OH lines within Tier 2, 3 is a common best practice.” o BWP Consideration: 22% of risk driver events since 2005 are associated with downed conductors within the Tier 2 HFTD. Performing annual infrared inspections of OH lines may reduce the frequency of these events as abnormalities such as loose connections can be detected before failure . An engineering evaluation study to review the cost, technology, and effectiveness of performing annual infrared inspections on all circuits within the Tier 2 HFTD is being conducted and an update will be provided in the 2023 WMP. Due to the difficult terrain and pole access limitations in portions of the Tier 2 HFTD, BWP is also evaluating aerial thermal inspections to identify priority wire replacement segments.
• Operational activities limitations during the fire season and/or during Red Flag Warnings issued by the National Weather Service (or as fire risk potential designates). o IE Report: BWP should evaluate addition of limiting operational activities during RFWs to the applicable operating procedure. Limiting operational activities during RFWs is a best practice. o BWP Consideration : BWP established a policy and procedure to limit the operational activity of Ignition Producing Work during an RFW alert. This policy and procedure is discussed further in Section
5.3.3. • Notify critical facilities and public safety partners. o IE Report: Establish s pecific communications protocols for wildfire emergency events to improve communication and coordination.
o BWP Consideration: BWP, as a department of the City of Burbank, follows the Standard Emergency Management System (SEMS) for improved communication and coordination. • Incident Command Team / Emergency Operations frameworks in the event a de-energization event or wildfire incident occurs.
o IE Report: Given the identified wildfire risks within portions of the BWP service area, may benefit from development of a PSPS plan with the associated emergency management plans and communications protocols.
o BWP Consideration: BWP has implemented mitigation measures that reduce the risk of its electrical assets igniting a wildfire. As a result, BWP does not require pre-emptive de -energization of any portions of its electric system as a mitigation measure . While BWP does not expect to perform pre - emptive de -energization, BWP will consider establishing a PSPS strategy as part of its Emergency Response Plan to enhance communication between BWP and others. See section 5.5. • Coordination with stakeholder agencies/entities with routine meetings to discuss emergency preparedness needs and areas of improvement, etc.
o IE Report: Establishment of regular meetings with City of Burbank agencies and other interested stakeholders to di scuss wildfire emergency preparedness and wildfire mitigation activities may provide coordination benefits.
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attend scheduled meetings to discuss wildfire emergency preparedness and wildfire mitigation activities.
Review of mitigation activity accomplishments
Section 5.0 highlighted several prevention strategies and programs that BWP implemented to minimize the risk of wildfires. Table 15 below is a summary of those accomplishments.
Table 15 - Summary of mitigation activity accomplishments in 2021 Mitigation activities Description Accomplishments
Design and construction
1 Deteriorated pole
replacements
Replacement of poles that do not pass
condition-based assessments to
prevent pole failure.
Replaced 5 poles in Tier 2 HFTD.
2 Pole loading assessments
& remediation
Structural assessment of poles to identify
potential loading issues during high wind
events. Replacement of poles that do not pass
GO 95 wind loading design criteria to minimize
the risk of pole failure.
All pre-emptive pole loading assessments
in the Priority 2.1 area of the Tier 2
HFTD were completed in 2020 and all
pole loading issues have been mitigated.
All future pole replacements require pole
loading review.
3 Overloaded transformer
replacements
Replacement of overhead transformers that do
not meet loading criteria to
prevent transformer failure.
Replaced 3 overloaded transformers
above 150% overload criteria in Tier 2
HFTD. There were no transformer
failures in the Tier 2 HFTD in 2021.
4 Distribution construction
standards improvements
Engineering study of distribution construction
standard improvements, which could provide
additional risk reduction in the Tier 2 HFTD.
Completed:
• An engineering study of
conventional fuse
replacements(2020). A program
was created to replace all
conventional fuses with
CALFIRE “Exempt” fuses as
discussed in Section 5.1.5.
Field reclosers study is complete, but
implementation is on hold pending the
completion of the remaining engineering
studies. This will help BWP determine
the most cost-effective risk reduction
method.
• Composite pole pilot completed
(7 poles total), composite poles
will be implemented as a
mitigation method in the HFTD
for future pole replacements.
The following studies are on track to be
completed:
• Replacement of bare overhead
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Mitigation activities Description Accomplishments
wire with covered conductor or
reinforcement of pole lines by
replacing aging copper with
ACSR (estimated completion by
June 2022).
• Infrared inspection technology
study (estimated completion by
June 2022).
• Falling conductor technology
(estimated completion by June
2023)
• Pole mounted sensor devices to
for real time monitoring, pilot to
be implemented this year.
Update will be provided once
pilot is complete (estimated
completion by June 2024).
• Replacement of oil filled
transformers with non-oil filled
pole mounted transformers
(pilot estimated completion by
June 2024).
Inspection and maintenance
5 Annual patrol inspection
(GO 165)
Annual system patrol to inspect the
condition of electrical assets to avoid
faults, which could cause ignitions.
Completed 100% of annual patrol
inspections in the Tier 2 HFTD
6 Vegetation management
program
Annual vegetation maintenance and clearance
from electrical lines to avoid
vegetation contact in Tier 2 HFTD
Completed 100% of annual maintenance
and clearance in the Tier 2 HFTD.
Trimmed 213 trees and removed 1
“problem” tree
7 Intrusive pole inspections
Condition based assessment of remaining pole
strength to identify
poles at risk of failure
BWP is up to date with all intrusive pole
inspections in the Tier 2 HFTD
Operational practices
8 Block reclosing and
increase relay sensitivity
during RFW
Block reclosing and increase relay sensitivity on
all feeder lines in the Tier 2 HFTD during RFW
events
Blocked reclosing and increased relay
sensitivity during all RFW alert days
9 Line patrol after outage
event during RFW
Patrol with physical inspection of
tripped feeder lines in Tier 2 HFTD during RFW
before re-energizing circuit
Patrolled lines after an outage event
during RFW
10 Ignition potential work
practices during RFW
Except during an emergency, disallow work
that may potentially produce an ignition source
on all feeder lines in the Tier 2 HFTD during
RFW events
No ignition potential work was
performed in the Tier 2 HFTD during
RFW events
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Mitigation activities Description Accomplishments
Situational/Conditional
Awareness
11 Weather/fire monitoring
Conduct weather monitoring via publicly
available weather resources to monitor
weather forecast and any
potential extreme fire conditions
Monitored weather and alerted staff on
each of the four days with an RFW
condition. In 2021, the ECC began using
the SCE owned fire-monitoring camera
in the Verdugo Mountains to enhance
situational awareness on an as-needed
basis.
12 Geographic information
system (GIS) applications
Implementation of Outage Management
System (OMS), which uses GIS data and meter
information to help BWP locate outages and
decrease response time
Updated GIS and OMS data which
helped BWP to locate outages and
decrease response time
In summary, BWP accomplishments indicate that’s it’s been effective in carrying out mitigation activities that reduce the risk of its electrical equipment igniting a wildfire. The ignition event on March 20th, 2021, highlighted the urgency to implement a conductor replacement program potentially in conjunction with falling conductor technology, especially with respect to older bare copper conductor that has been responsible for all wire down events. Some mitigation activities that appear to need some additional progress and focus are:
• Distribution Construction Standards Improvements . Based on the current workload of the engineering team, BWP expects to complete the remaining engineering studies by June 2022. o Continue implementation of conventional fuse replacement program as discussed in Section 5.1.5. o Complete pole mounted sensor pilot for real time monitoring. o Complete conductor replacement study
o Complete non-oil filled pole mounted transformer study o Complete falling conductor detection study
BWP has also completed the engineering study of field reclosers. BWP has determined that the decision to invest in field reclosers will be put on hold until fiscal year 2022/2023 as other mitigation activities have a greater cost -to- risk reduction ratio.
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Chapter 8. Public comment, presentation, and
independent evaluation
8.1 Public comment
A draft copy of the WMP will be made available for comment on BWP’s website prior to the City Council meeting.
BWP Board and City Council meetings are open and accessible to the public. Meeting notices and agendas are posted, at a minimum, 72 hours in advance on the City’s website. Those who are unable to attend the meeting in- person can livestream the meeting or view a recording on the City’s website.
BWP also maintains a copy of the current and previous WMP and independent evaluation report on its website at BurbankWaterAndPower.com under Electric > Wildfire Mitigation Plan. Council action and public comment are available on BurbankCA.gov.
8.2 Presentation to BWP Board and Burbank City Council
The WMP will be posted on BWP’s website and will be presented to the BWP Board prior to a presentation to the City Council.
BWP follows the process below:
• Draft WMP is posted on BWP website and open for public comment • BWP presentation to BWP Board, along with public comment and comment from BWP Board • BWP presentation to City Council, along with public comment and comment from City Council • WMP is posted on BWP website and submitted to WSAB for review by July 1st annually
8.3 Independent evaluation
In accordance with a statutory requirement in Public Utilities Code Section 8387, BWP contract ed with a qualified independent evaluator to assess the comprehensiveness of the January 2020 WMP. The Independent Evaluator completed an Independent Evaluation Report and presented the following evaluation results and conclusions to City Council on October 27, 2020. The complete Independent Evaluation Report is available at BurbankWaterAndPower.com.
Evaluation results
• BWP has addressed each of the mandatory requirements in its WMP • BWP analyzed and prioritized its territory residing within the Tier 2 High Fire Threat District, maximizing impact of measures undertaken
• BWP has implemented many industry best practices to prevent and mitigate against the impacts of wildfire including, but not limited to:
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• Enhanced situational awareness
• Pole loading assessments
• Blocking reclosers during Red Flag Warnings
• Strong vegetation management practices
Evaluation conclusion
• Guidehouse determined that BWP’s WMP is comprehensive and meets the statutory requirements listed in PUC Section 8387
• The Plan elements align with industry standards and practices
The Independent Evaluator’s report has been posted to BWP’s website and remains available for public consumption. In addition, BWP has used this report as a tool for its internal audit in Section 7.0. An independent evaluation of the WMP will be completed every 3 years. The results of the next evaluation report will be shared in the 2023 update of the WMP.
8.4 Wildfire Safety Advisory Board
On or before July 1, 2020, and annually thereafter, Public Utilities Code Section 8387 requires that BWP submit its WMP to the California Wildfire Safety Advisory Board (WSAB). BWP fulfilled this obligation by submitting its WMP to WSAB in June 2021.
On February 23, 2022 , WSAB approved its final “Guidance Advisory Opinion for the 202 2 Wildfire Mitigation Plans of Elec tric Publicly Owned Utilities and Rural Electric Cooperatives.” BWP has considere d the recommendations from the WSAB in this 202 2 update to the WMP and has implemented changes where applicable. BWP will continue to consider comments and opinions received by the WSAB in future updates of the WMP.
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Chapter 9. References
BWP. 2020. Burbank Water and Power Emergency Response Plan. September 2020
BWP. 2020. Independent Evaluation Report by Guidehouse Inc., May 13, 2020
California Wildfire Safety Advisory Board. 2021. Guidance Advisory Opinion for the 2021 Wildfire Mitigation Plans of Electric Publicly Owned Utilities and Cooperatives, December 9, 2020
CALFIRE. 2020. California Power Line Fire Prevention Field Guide, 2020 edition
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Exhibit A. Context-setting information table
Utility name BWP
Service territory size 17 square miles
Owned assets ☒ Sub-transmission ☒ Distribution ☒ Generation Number of customers
served
52,970 customer accounts
Population within
service territory
103,703 people in 2019
Customer class makeup
Number of accounts Share of total load (MWh)
87.0% Residential;
10.2% Small commercial;
2.4% Medium commercial;
0.3% Large commercial;
0.1% Extra large commercial;
25.4% Residential;
7.3% Small commercial;
18.9% Medium commercial;
20.2% Large commercial;
25.1% Extra large commercial;
Service territory
location/topography1
17% Barren/other
83% Urban
Service territory
Wildland Urban
Interface2
(based on total area)
28% Wildland Urban Interface;
Percent of service
territory in CPUC High
Fire Threat Districts
(based on total area)
☒ Refer to 2021 WMP, Section 4.3.1, Figure 4 for a map of BWP’s Tier 2 High Fire Threat District
Tier 2: 28% (geographic area)
Tier 2 with overhead electrical facilities: 9% (geographic area) Tier 3: 0%
Prevailing wind
directions & speeds by
season
☐ Includes maps
intermittent, westerly and easterly winds
Miles of owned lines
underground and/or
overhead
Overhead dist.: 204 circuit miles
Overhead trans.: 59 circuit miles
Underground dist.: 129 circuit miles
Underground trans.: 30 circuit miles
Percent of owned lines in
CPUC High Fire Threat
Districts
Overhead distribution lines as % of total distribution system (inside and outside service territory)
Tier 2: 5.4% (of total circuit miles)
Tier 3: 0%
Overhead transmission lines as % of total transmission system (inside and outside service territory)
Tier 2: 0%
Tier 3: 0%
1 This data shall be based on the California Department of Forestry and Fire Protection, California Multi-Source Vegetation Layer Map, depicting WHR13 Types (Wildlife Habitat Relationship classes grouped into 13 major land cover types) available at: https://www.arcgis.com/home/item.html?id=b7ec5d68d8114b1fb2bfbf4665989eb3. 2 This data shall be based on the definitions and maps maintained by the United States Depar tment of Agriculture , as most recently assembled in The 2010 Wildland -Urban Interface of the Conterminous United States , available at https://www.fs.fed.us/nrs/pubs/rmap/rmap_nrs8.pdf.
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Utility name BWP
Customers have ever lost
service due to an IOU
PSPS event?
☐ Yes ☒ No
Customers have ever been
notified of a potential loss
of service to 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
If yes, then provide the following data for calendar year 2020:
Number of shut-off events: [____]
Customer Accounts that lost service for >10 minutes: [____] For prior response, average duration before service restored: [____]
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Exhibit B. Summary of key changes in BWP’s 2022
WMP
This document provides a summary of the key changes between BWP’s 2022 Wildfire Mitigation Plan (WMP), and BWP’s 2021 Wildfire Mitigation Plan.
This document is intended to simplify the process of reviewing BWP’s current WMP but does not represent a comprehensive identification of every single update to BWP’s WMP. Therefore, a full review of BWP’s wildfire mitigation efforts should be based on the actual WMP.
Changes to current WMP
Chapter 1 – Introduction
- Section 1.2 – Added reference to website and reference to summary of changes - Section 1.3 – Added objective 2 to highlight need for continuous evaluation, not just removal of ignition sources
Chapter 2 – Burbank Water and Power
- Section 2.2 – Updated customer makeup
Chapter 3 – Preventative strategies and programs overview - Table 2 – Added enhanced system monitoring as a new mitigation activity
Chapter 4 – Risk analysis and risk drivers
- Section 4.4 – Updated Table 3 and Table 4 to reflect current system configuration. Updated Table 5 total risk drivers events based on new data from 2021.
- Section 4.7 – Added section 4.7 to integrate comments from Informational Response into WMP
Chapter 5 – Wildfire prevention strategies and programs - Section 5.1 – Provided update on facility design and construction progress/improvements in 2021 - Section 5.3.2 – Updated events
- Section 5.4.3 – Added enhanced system monitoring pilot - Section 5.5 – Updated PSPS language
Chapter 7 – Performance metrics and monitoring
- Section 7.2 – Updated all performance metrics based on 2021 data - Section 7.3 – Updated information in Annual Internal Audit (Section 7.3.3) and Mitigation Activity Accomplishments (Table 15)
Chapter 8 – Public comment, presentation, and independent evaluation - Section 8.1 – Added website references and how to request older WMP copies - Section 8.2 – Clarified public comment and review/approval process - Section 8.3 – Added website reference
- Section 8.4 – Updated for 2021
Exhibit A – Context-setting information table
- Added Exhibit A to integrate comments from Informational Response into WMP
Exhibit B – Summary of key changes in BWP’s 2022 WMP
Added change log into WMP in response to WSAB comments
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