2023 Independent Evaluation of Burbank
Water and Power’s 2022 Wildfire Mitigation
Plan
Prepared for:
Burbank Water & Power
Submitted by:
Guidehouse Inc.
4001 South 700 East
Salt Lake City, UT 84107
March 23, 2023
guidehouse.com
This deliverable was prepared by Guidehouse Inc. for the sole use and benefit of, and pursuant to a client relationship exclu sively with Lodi Electric Utility (“Client”). The work presented in this deliverable represents Guidehouse’s professional judgement based on the information available at the time this report was prepared. Guidehouse is not responsible for a third party’s use of, or reliance upon, t he deliverable, nor any decisions based on the report. Readers of the report are advised that they assume all liabilities incurred by them, or third parties, as a result of their reliance on the report, or the data, information, findings and opinions contained in the report.
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Table of Contents
Executive Summary ...................................................................................................... 1
1. Background ............................................................................................................... 2
1.1 Wildfire Mitigation Plans ................................................................................................. 2
1.1.1 SB 901 ................................................................................................................ 2
1.1.2 AB 1054 Statutory Modifications ........................................................................ 3
1.2 Burbank Water and Power Plan Preparation ................................................................. 3
1.2.1 Independent Evaluation Services ....................................................................... 3
2. Evaluation Scope and Approach ............................................................................. 5
2.1 Evaluation Parameters ................................................................................................... 5
2.1.1 WMP Requirements ........................................................................................... 5
2.1.2 Industry Knowledge and Regulatory Proceedings ............................................. 6
2.2 Evaluation Approach ...................................................................................................... 6
2.2.1 Statutory Compliance ......................................................................................... 7
2.2.2 Industry Wildfire Mitigation Practices Comparison ............................................. 7
3. BWP WMP Elements ................................................................................................. 8
3.1 Responsibilities of Persons Responsible for Executing the Plan ................................... 8
3.2 Objectives of the Plan .................................................................................................... 8
3.3 Wildfire Prevention Strategies ........................................................................................ 8
3.4 Metrics ........................................................................................................................... 9
3.5 Disabling Reclosers ..................................................................................................... 10
3.6 De-Energizing Protocols .............................................................................................. 10
3.7 Event Communication .................................................................................................. 10
3.8 Vegetation Management .............................................................................................. 11
3.9 Infrastructure Inspections ............................................................................................. 11
3.10 Risk Assessment and Drivers .................................................................................... 11
3.11 Asset Overview and Service Territory ........................................................................ 12
3.12 Restoration ................................................................................................................. 15
3.13 Monitoring and Auditing the Plan ............................................................................... 15
3.14 Annual Review ........................................................................................................... 16
4. FIRE INDUSTRY PRACTICES COMPARISON ........................................................ 17
5. Best Practice Comparison ...................................................................................... 21
6. Results and Discussion .......................................................................................... 35 Appendix A. Statutory Compliance Matrix .............................................................. A-1
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List of Tables
Table 2-1 – POU Requirements ................................................................................................... 5 Table 3-1 – Breakdown of BWP's 2022 electrical assets within Tier 2 HFTD ............................ 13 Table 3-2 – Inventory of BWP assets in the Tier 2 HFTD by circuit ........................................... 15 Table 5-1 – Industry Practice Strategy Comparison Matrix ....................................................... 21
List of Figures
Figure 1-1 – Fire Triangle ............................................................................................................ 2 Figure 2-1 – Mitigation Strategy Overview ................................................................................... 7 Figure 3-1 – Electrical facilities within the Tier 2 HFTD ............................................................. 14 Figure 5-1 – Determinations for Benchmarking ......................................................................... 21
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Executive Summary
Burbank Water & Power (BWP) contracted with Guidehouse Inc. (Guidehouse) to engage in an independent evaluation of its Wildfire Mitigation Plan (Plan or WMP). This independent evaluation report (Report) describes the technical review and evaluation provided by Guidehouse. Guidehouse performed this evaluation in February 2023 and finalized the Report on March 20, 2023. Guidehouse’s project team reviewed detailed information related to the Plan and assessed BWP’s procedures related to the Plan.
The Plan was prepared as a response to Senate Bill (SB) 901. SB 901 and included a number of provisions and directives, among which includes the requirement for electric utilities to prepare and adopt WMPs and revise and update the Plan annually thereafter. These requirements are codified in the California Public Utilities Code (PUC) Section 8387 for publicly owned utilities (POUs).
Guidehouse evaluated the Plan based on the statutory requirements of PUC Section 8387 as it relates to POUs. This PUC Section was amended in 2019 with the signing of California’s Assembly Bill (AB) 1054 into law. The POUs are now subject to the guidance provided by the California Wildfire Safety Advisory Board and mandatory cyclical reviews, including a comprehensive update every three years. The required elements for a WMP have not been modified by this new legislation. This Report meets BWP’s requirements under PUC Section 8387(c), which mandates an independent evaluation of BWP’s WMP. The Report was also developed to satisfy the statutory requirement for public review. This Report underlies the required presentation at a public meeting of the Burbank City Council scheduled for May 23, 2023. BWP will also present this information to the BWP Board on May 4, 2023, for advice and comments before presentation to the City Council. The Report includes the following:
• Background of the legislative history requiring WMPs and their independent evaluations • Approach and methodology evaluating the WMP’s comprehensiveness • BWP’s WMP elements and their compliance with SB 901 and PUC Section 8387 WMP elements and directives
• An evaluation of the WMP’s presented metrics to assess the effectiveness of the overall WMP
• Determinations and results
Based on relevant experience in grid hardening and resiliency, natural disaster response, prior experience in WMP development, and active tracking of wildfire legislative and regulatory proceedings Guidehouse has concluded that BWP’s WMP is comprehensive in accordance with PUC section 8387.
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1. Background
In recent years, California has seen numerous utility equipment-involved, catastrophic wildfires.
The unique geographic profile of California and the impacts of climate change, including prolonged drought, high winds, and elevated temperatures, have led to elongated fire seasons.
The state also has historically high levels of past fire suppression efforts. This increasingly abundant dry vegetation is the leading driver of wildfires. These fuel-rich environments, coupled with intensified climatological conditions with high wind gusts and inherent electrical infrastructure risks, produce the conditions conducive to potential wildfire ignition. The three attributes that provide optimal conditions for a fire ignition are illustrated through the graphic in Figure 1-1.
Figure 1-1 – Fire Triangle
Disastrous wildfire threat is a well-known and shared priority among electric utilities in California.
Disastrous utility-involved wildfire incidents and the significant financial and livelihood impacts associated with them led California legislators and regulators to formalize requirements to ensure safe operations of electric utility equipment and greater investment in wildfire mitigation efforts. Specifically, the state has approved legislation that strengthens governmental and regulatory oversight of wildfire prevention implementation activities, utility wildfire mitigation plans, and proper dispersal of state funds to wildfire victims. In an effort to minimize future devastating occurrences through risk-driven wildfire prevention, electric utilities, including cooperatives, were mandated, by SB 901 (Senator Bill Dodd, 2018), to prepare and annually adopt a wildfire mitigation plan. This effort is foundational to the state’s prioritized goal of minimizing the potential of devastating fires in future years.
1.1 Wildfire Mitigation Plans
1.1.1 SB 901
In an effort to minimize future devastating occurrences through risk-driven wildfire prevention, electric utilities, including publicly owned utilities (POUs), were mandated, by Senate Bill (SB) 901 to prepare and annually adopt a WMP. The WMPs must Include several mitigation and response elements in each utility’s strategies, protocols, and programs. The requirements for POUs are codified in Public Utilities Code (PUC) Section 8387. Details relating to POU requirements are discussed in Section 2 of this WMP evaluation report (Report).
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1.1.2 AB 1054 Statutory Modifications
In 2019, Assembly Bill (AB) 1054 was signed into law, modifying the requirements for POU WMPs. AB 1054 aims to mitigate the intensity of wildfire impacts through several initiatives separate from those actions required of electric utilities. AB 1054 includes directives to establish the Wildfire Safety Division1 at the California Public Utilities Commission and the state’s Wildfire Safety Advisory Board (WSAB). AB 1054 requires POUs submit their WMPs by July 1 of each year for review by and recommendations from WSAB and requires POUs to comprehensively update their WMPs at least every three years. The most recent Guidance Advisory Opinion for 2022 POU WMPs was published on March 2, 2022.
1.2 Burbank Water and Power Plan Preparation
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 the BWP Board and the Burbank City Council. BWP is not-for profit, delivering service at cost.
BWP is committed to providing reliable, affordable and sustainable electrical service to Burbank.
BWP’s reliability is superb, maintaining electrical service to BWP’s customers 99.99% of the time in 2021.
BWP prepared its first WMP pursuant to SB 901 directives in 2019. 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.
1.2.1 Independent Evaluation Services
PUC Section 8387(c) directs POUs to procure an independent evaluation (IE) of the comprehensiveness of the WMP. The provisions of PUC Section 8387 state that the “qualified independent evaluator” shall be experienced in “assessing the safe operation of electrical infrastructure” and will perform an assessment to determine the comprehensiveness of the WMP.
Accordingly, BWP sought IE services to assess the comprehensiveness of its WMP pursuant to PUC Section 8387(c). BWP selected Guidehouse to perform this assessment based on Guidehouse’s prior experience with assessing the safe operation of electrical infrastructure, including grid-hardening and WMPs, with an emphasis on electrical equipment, public, and personnel safety. Guidehouse has conducted over 12 independent evaluations of POUs across California and is a California Office of Energy Infrastructure Safety (“Energy Safety”) designated
1 Oversight and responsibility for the Wildfire Safety Division was transferred from the California Public Utilities Commission to the California Natural Resources Agency on July 1, 2021 and is now known as the Office of Energy Infrastructure Safety.
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qualified independent evaluator for the last two years, and as such has conducted six independent evaluations of three CA IOUs.
This Report presents the results of Guidehouse’s WMP IE.
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2. Evaluation Scope and Approach
Guidehouse completed this evaluation based on industry standard practices, our experience performing independent evaluations of WMPs, our active tracking of wildfire regulatory proceedings, WSAB guidance, and, most importantly, a comparison of the specific criteria in PUC Section 8387(b)(2) to the specific wildfire-related plans outlined in BWP’s WMP.
2.1 Evaluation Parameters
2.1.1 WMP Requirements
Table 2-1 lists the requirements for the statutory requirements for POUs to address in their WMPs.
Table 2-1 – POU Requirements
PUC Section 8387
(a) Each local publicly owned electric utility and electrical cooperative shall construct, maintain, and operate its electrical lines and equipment in a manner that will minimize the risk of wildfire posed by those electrical lines and equipment.
(b) (1) The local publicly owned electric utility or electrical cooperative shall, before January 1, 2020, prepare a wildfire mitigation plan. After January 1, 2020, a local publicly owned electric utility or electrical cooperative shall prepare a wildfire mitigation plan annually and shall submit the plan to the California Wildfire Safety Advisory Board on or before July 1 of that calendar year. Each local publicly owned electric utility and electrical cooperative shall update its plan annually and submit the update to the California Wildfire Safety Advisory Board by July 1 of each year. At least once every three years, the submission shall be a comprehensive revision of the plan.
(2) The wildfire mitigation plan shall consider as necessary, at minimum, all of the following:
(A) An accounting of the responsibilities of persons responsible for executing the plan. (B) The objectives of the wildfire mitigation plan.
(C) A description of the preventive strategies and programs to be adopted by the local 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. (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 that underlie the use of those metrics. (E) A discussion of how the application of previously identified metrics to previous wildfire mitigation plan performances has informed the wildfire mitigation plan. (F) Protocols for disabling reclosers and deenergizing 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. (G) Appropriate and feasible procedures for notifying a customer who may be impacted by the deenergizing of electrical lines. The procedures shall consider the need to notify, as a priority, critical first responders, health care facilities, and operators of telecommunications infrastructure. (H) Plans for vegetation management.
(I) Plans for inspections of the local publicly owned electric utility’s or electrical cooperative’s electrical infrastructure.
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(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:
(i) Risks and risk drivers associated with design, construction, operation, and maintenance of the local publicly owned electric utility’s or electrical cooperative’s equipment and facilities. (ii) Particular risks and risk drivers associated with topographic and climatological risk factors throughout the different parts of the local publicly owned electric utility’s or electrical cooperative’s service territory. (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 identified in a commission fire threat map, and identification of where the commission should expand a high fire-threat district based on new information or changes to the environment.
(L) A methodology for identifying and presenting enterprise wide safety risk and wildfire-related risk. (M) A statement of how the local publicly owned electric utility or electrical cooperative will restore service after a wildfire.
(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:
(i) Monitor and audit the implementation of the wildfire mitigation plan. (ii) Identify any deficiencies in the wildfire mitigation plan or its implementation, and correct those deficiencies. (iii) Monitor and audit the effectiveness of electrical line and equipment inspections, including inspections performed by contractors, that are carried out under the plan, other applicable statutes, or commission rules. (3) The local publicly owned electric utility or electrical cooperative shall, on or before January 1, 2020, and not less than annually thereafter, present its wildfire mitigation plan in an appropriately noticed public meeting. The local publicly owned electric 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. (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 website 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.
2.1.2 Industry Knowledge and Regulatory Proceedings
The state’s priority towards abating future catastrophic wildfire events is demonstrated through aggressive measures, directing utilities to enhance their protocols for fire prevention, public communications, and response. That collection of information is presented in a comprehensive WMP. Guidehouse tracks state proceedings and routinely advises, assesses, and guides utility wildfire mitigation efforts. Accordingly, we reviewed BWP’s WMP against the provisions in PUC § 8387 and relative to its risk profile which includes, but is not limited to, its topography, climate, assets, and structure.
2.2 Evaluation Approach
Guidehouse assessed the comprehensiveness of the plan against the applicable regulations to determine whether BWP meets the standard set forth in PUC § 8387(c).
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2.2.1 Statutory Compliance
Guidehouse sought to determine compliance with the provisional requirements laid out in SB901 as codified in PUC Section 8387. The WMP’s alignment with the statutory requirement is presented in Appendix A. BWP’s mitigation measures are not required to exceed the statutory requirements.
2.2.2 Industry Wildfire Mitigation Practices Comparison Guidehouse’s understanding of an effective WMP draws on comparisons from existing WMPs and industry practices, WSAB guidance, risk profile, and mitigation strategy. This mitigation strategy analysis is visually summarized in Figure 2-1.
Figure 2-1 – Mitigation Strategy Overview
These critical elements are evaluated as part of Guidehouse’s review of the comprehensiveness of BWP’s WMP. This evaluation includes a consideration that not all of these strategies are necessarily present in or applicable to BWP’s WMP, due to BWP’s inherent risk, size, location, and operational characteristics.
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3. BWP WMP Elements
Guidehouse reviewed the WMP elements and determined whether the activities achieve the objective of WMP “comprehensiveness” of PUC Section 8387. This determination incorporates individual elements as well as underlying data sources that further describe data collection methodologies and implementation procedures to ensure measures are carried out and also tracked.
Guidehouse determined BWP’s WMP meets the requirement of comprehensiveness PUC Section 8387. In this section, we review the WMP’s elements and their purpose relative to the development and successful execution of the WMP. A table comparing each subsection of PUC Section 8387 to the significant sections of the WMP can be found in Appendix A.
3.1 Responsibilities of Persons Responsible for Executing the Plan2 BWP’s General Manager has overall responsibility for the WMP. Other members of the management team are responsible for executing the various components of the WMP. Section
7.1 of the WMP addresses accountability, roles, and responsibility for BWP’s WMP. In general, Design and Construction activities are under the purview of the Manager, T&D Engineering.
Inspection and Maintenance is the responsibility of the Manager, Electrical Distribution and Manager, T&D Engineering. Operational Practices responsibility is split between the Managers of the Energy Control Center (ECC) and Electrical Distribution. The Manager, ECC and Manager, T&D Engineering are also responsible for Situational/Conditional Awareness activities. This level of assignment is appropriate for a utility the size of BWP.
3.2 Objectives of the Plan3
The primary objectives of this WMP, are described in Section 1.3 of the WMP and include:
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.
In support of these objectives, BWP intends to continually evaluate cost effective improvements to its design standards, physical assets, inspection and maintenance programs, operations, and training to meet these objectives.
3.3 Wildfire Prevention Strategies4
Chapter 3 provides an overview of BWP’s preventative strategies and programs for preventing wildfire. Table 2 of the WMP provides an overview of all the actions and programs already under way or planned by BWP to prevent wildfires. These strategies and programs are elaborated upon further in Chapter 5 which details the elements of those strategies and programs.
Specifically, BWP details how it incorporates wildfire mitigation into Facility Design and
2 PUC Section 8387(2)(A)
3 PUC Section 8387(2)(B)
4 PUC Section 8387(2)(C)
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Construction, Inspection and Maintenance, Operational Practices, and Situational/Conditional Awareness in accordance with this plan and in consideration of wildfire and dynamic climate change risks.
As noted by the WSAB in their evaluation of BWP’s 2020 WMP, Guidehouse believes that “Burbank has provided an excellent description of implementation of wildfire mitigation strategies.
Specifically, BWP conducts the following:
1. Facility Design and Construction
• Deteriorated pole replacements
• Pole loading assessments & remediation
• Overload transformer replacements
• Distribution construction standard improvements
• Conventional fuse replacements
2. Inspection and Maintenance
• Annual patrol inspection (GO 165)
• Vegetation management program
• Intrusive pole inspections
3. Operational Practices
• Block reclosing and increase relay sensitivity during RFW • Line patrol after outage event during RFW
• Ignition potential work practices during RFW
4. Situational Awareness
• Weather/fire monitoring
• Geographic information system (GIS) applications
• Enhanced system monitoring
It is noted that BWP updated the WMP for 2022 to add enhanced system monitoring as a new mitigation activity.
3.4 Metrics5
BWP sets forth and describes numerous metrics that may impact or contribute to wildfire prevention in section 7.2.1. These metrics are used by BWP to provide insight into BWP’s performance and dynamic conditions across BWP’s service area. BWP also designates the responsible party for collecting the metrics and the periodicity for each metric’s collection. BWP also tracks risk driver events in Table 14 of this section. The WMP also includes a broader discussion of previous metrics and how those metrics are used to shape and improve measures to reduce the risk of wildfires. For reference, a broader, multi-year period of historical outage information was previously highlighted in Table 5 of Section 4.4 of the WMP. The table includes “Wildfire Risk Event” and “Number of Occurrences (by circuit)”.
5 PUC Section 8387(2)(D) and PUC Section 8387(2)(E)
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Guidehouse agrees with the WSAB that BWP’s metrics are an excellent selection of and comprehensive tracking metrics to assess progress on mitigation of wildfire risks, as well as reporting and auditing metric data from previous years.
3.5 Disabling Reclosers6
Section 5.3.1 Block reclosing and increase relay sensitivity during RFW - BWP has reclosing capabilities on all substation circuit breakers in the electrical system. Reclosing a circuit could potentially ignite vegetation if fault conditions are still present. Accordingly, BWP enacted an operating procedure to block reclosing capabilities on all circuits in the Tier 2 HFTD during RFW conditions issued by the National Weather Service. Additionally, more sensitive, quicker acting relay settings are employed during RFW conditions to increase the chance of detecting and isolating a fault. Additionally, all of the recloser settings can be changed remotely which allows BWP to respond quickly to changing conditions.
3.6 De-Energizing Protocols7
Section 5.5 Public safety power shutoff (PSPS) discusses BWP’s approach to pre-emptive de- energization. Specifically, BWP details that they do not plan to implement a PSPS as a mitigation measure unless instructed to do so by the Burbank Fire Department, Burbank Police, CALFIRE, or other emergency responders. Additionally, BWP states ECC retain the authority to de-energize portions of the electric system for safety, reliability or during emergency situations as directed by the three identified entities or other emergency personnel.
BWP supports this approach by citing the following features:
• 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
Guidehouse does, however, recommend BWP develop an operating protocol for PSPS implementation, no matter how unlikely, that includes responsibilities and actions for de- energization. This protocol should describe how BWP will notify those affected, mitigate the public safety impacts of a PSPS, and expected impacts on critical first responders and on health and communication infrastructure.
3.7 Event Communication8
Section 6.3 describes customer support during emergencies describes how BWP maintains a communications protocol for communication and coordination with its primary stakeholders, including Burbank Fire, the City Manager, other utilities, elected officials, fire agencies and first
6 PUC Section 8387(2)(F)
7 PUC Section 8387(2)(F)
8 PUC Section 8387(2)(G)
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responders, and BWP’s emergency response support team. BWP notes that communication with customers impacted by the de-energizing of electrical lines during an emergency would be initiated using BWP’s standard communication protocols, however, Guidehouse recommends that notification be addressed in a PSPS protocol recommended above in Section 3.6.
3.8 Vegetation Management9
Section 5.2.2 details BWP’s Vegetation Management Program by describing how BWP’s vegetation management program 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, and is overseen by the Manager, Electrical Distribution. BWP’s vegetation management program is well designed to reduce wildfire hazards.
BWP also performs routine vegetation management specifically for vegetation clearances, as defined in Table 8 – Vegetation clearances, within the WMP, by pruning and removal, on an annual basis in the Tier 2 HFTD. These clearances are beyond those required by GO 95 Rule
35. 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, inspect tree and conductor clearances and identifies any hazard trees for removal. BWP contractor crews trim a minimum of 12 feet of clearance. BWP’s tree trimming contractors are specialists, supervised by a certified arborist. Finally, BWP performs a Quality Assurance review of field work and a Quality Control check of submitted reports and documentation.
3.9 Infrastructure Inspections10
Section 5.2.1 describes BWP’s annual infrastructure patrol inspection (GO 165) program to inspect each component of the electrical system to check that no obvious abnormalities exist to the extent possible. During these inspections, problems are identified, prioritized, and corrected.
The specific cycles, along with the cycles for detailed inspections are included in Table 7 of the WMP. Additionally, Section 5.2.3 describes BWP’s intrusive pole inspections for its Tier 2 areas.
BWP performs these inspections on cycles that meet or exceeds the timeframes given in General Order 165 (GO 165) and they are moving to a five-year cycle. Additionally, BWP is in the process of implementing digital inspection tools to improve record keeping and tracking of detailed inspections in the HFTD.
3.10 Risk Assessment and Drivers11
Chapter 4. Risk Analysis and Risk Drivers describes BWP’s risk assessment process and inputs. BWP’s WMP establishes three separate evaluations to identify, describe, and prioritize all wildfire risks and drivers for those risk. These evaluations include a Risk Bowtie Analysis, a Site Fire Environment Assessment, and an Electrical Equipment Assessment. The WMP also defines the difference between hazard and risk.
9 PUC Section 8387(2)(H)
10 PUC Section 8387(2)(I)
11 PUC Section 8387(2)(J)(i); PUC Section 8387(2)(J)(ii); PUC Section 8387(2)(L) ATTACHMENT 2
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Through these analyses BWP identified and documented the following key elements and actions:
1. Key risk impacts (injuries/fatalities, prolonged outages, damage/loss of equipment, and claims for damaged property),
2. Risk drivers (electrical equipment failure, conventional fuse operation, wire contact with foreign object(s) or vegetation, and extreme weather conditions), and
3. Prioritize risks based on location within the Tier 2 HFTD, proximity to overhead equipment, and density of vegetation underneath the overhead facilities.
BWP analyzed outage records for energized circuits within wildfire-threat areas and recent outage data between January 2005 and December 2021 that was obtained from BWP. These records include 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 – Failure of electrical assets and equipment can result in downed wires or sparking which may cause an ignition.
• Conventional fuse operation. 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). 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 vegetation: Tree, tree limb, palm fronds or other vegetation contact with conductors that could result in ignition.
• other or unspecified events: Situations where BWP was unable to determine the cause and location of the outage.
3.11 Asset Overview and Service Territory12
Section 4.1 states BWP retained a third-party consultant to perform a risk assessment of its electrical system and equipment which included an electrical equipment assessment that provided an inventory of BWP electrical assets within the Tier 2 HFTD along with analysis of historical outage information.
BWP has 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 of underground lines and 11 miles overhead wire. The overhead wire and associated components are the focus of this WMP, which represents the primary source of potential wildfire ignitions. Approximately 56 percent of BWP-owned electrical lines in the Tier 2 HFTD area are currently underground, which significantly reduces the threat of fire ignition.
Section 4.3 describes the electrical facility assessment and includes a breakdown of BWP’s electrical assets within the Tier 2 HFTD.
As shown in Table 3-1, approximately five percent of BWP’s total 204 miles of overhead wires are located within the Tier 2 HFTD area. Approximately 11 percent of the total underground lines occur within the Tier 2 HFTD area.
12 PUC Section 8387(2)(K)
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Table 3-1 – Breakdown of BWP's 2022 electrical assets within 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%
Table 3-1 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, however, as of the 2022 WMP, 38 are installed with an outstanding number of additional fuses to be installed once supply chain issues are resolved.
BWP also included Figure 3-1, below, which represents the portion of BWP’s service territory (e.g., feeder lines and equipment) within CPUC fire-threat areas. As illustrated in Figure 3-1, 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).
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Figure 3-1 – Electrical facilities within the Tier 2 HFTD There is a total of approximately 25 miles of distribution lines in Tier 2 HFTD, with 14 miles underground lines and 11 miles overhead wire. The overhead wire and related components are the focus of this WMP as they represent the most likely source of potential wildfire ignitions. It is noted that approximately 60 percent of BWP- owned electrical lines in the Tier 2 HFTD area are currently underground, as depicted in column 3, which significantly reduces the threat of fire ignition. Section 4.3.1 notes BWP participated in, and was a territory lead, in the threat mapping process with the CPUC. BWP believes the current CPUC HFTD designations are accurate and do not recommend any changes.
Table 3-2, below, provides an inventory of BWP assets within Tier 2 HFTD area organized by distribution feeder circuit. This table provides an excellent understanding of how the risks identified in the risk assessment present in real life.
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Table 3-2 – Inventory of BWP assets in the Tier 2 HFTD by circuit Electric
"feeder"13
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
3.12 Restoration14
Section 6.4 Restoration of Service describes how BWP restores its electric system 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). BWP also noted that it conducts a patrol before re-energizing any de-energized portion following an outage on a circuit with a disabled recloser.
3.13 Monitoring and Auditing the Plan15
Section 7.3 describes how the WMP is monitored and audited. Specifically, the WMP states that BWP will audit the WMP annually to monitor the effectiveness of the implementation of the
14 PUC Section 8387(2)(M)
15 PUC Section 8387(2)(N)(i) and PUC Section 8387(2)(N)(ii) ATTACHMENT 2
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WMP and will align with BWP’s planning and budget process. The audit will include an assessment of the metrics and the effectiveness of the WMP implementation and mitigation activities. After completion of the annual internal audit, the WMP will be updated accordingly.
BWP also audits the effectiveness of electrical line and equipment inspections. Any problems identified will be recorded and prioritized for correction.
3.14 Annual Review16
Section 7.3 also describes BWP’s process to annually review and update the WMP following the internal audit.
16 PUC Section 8387(2)(N)(iii)
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4. FIRE INDUSTRY PRACTICES COMPARISON
In consideration of industry-accepted and demonstrated mitigation measures, Guidehouse is providing a comparison against approved California utility WMPs, where comparable to BWP by service territory, risk profile, and equipment within the HFTD. This comparison is separate and additional to the regulatory evaluation required by PUC Section 8387(c). The complete comparison matrix with supporting information is provided in TABLE 5-1 – Industry Practice Strategy Comparison Matrix. Five areas have been highlighted for detailed discussion of the applicability and efficacy of the proposed WMP strategy.
Service Area
BWP is owned and operated by the City of Burbank and is governed by the BWP Board and the Burbank City Council. BWP electric system provides power to approximately 53,133 customers across 17 square miles within the City limits. In total, BWP currently serves 46,173 residential, 5,629 small commercial, 1,088 medium commercial, 156 large commercial, and 87 extra-large customer accounts. 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 is responsible for an area adjacent to the Verdugo Mountains designated as Tier 2 (elevated risk) HFTD. The Tier 2 area is 4.89 square miles with approximately 25 miles of distribution lines of which approximately 14 miles are underground lines and 11 miles are overhead wire. Ten distribution circuits have facilities within Tier 2 span across 643 distribution poles and 184 distribution transformers, 184 conventional transformer fuses, and 45 conventional lateral fuses.
BWP performed a risk assessment and determined that due to continuity of vegetation within the canyon and density of tree canopies surrounding the residential homes, Sunset Canyon (the upper road segment of Country Club Drive) poses the greatest risk of wildfire within Burbank’s Tier 2. BWP further prioritized their Tier 2 mitigation efforts into three sub-categories:
• 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 Fuels Management
Accumulation of vegetation, both live and dead, increase the chances of catastrophic wildland fire. Excess fuel allows fires to burn hotter, larger, longer, and faster, making them more difficult and dangerous to manage. The intensity and severity of wildfires is often reduced through fuels management activities. Fuels management is an action designed to reduce fire hazards by removing or rearranging fuels. When applied to strips of land, they are designated as a fuel ATTACHMENT 2
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break or fire break. Fuel breaks are strips of land in which vegetation, both dead and alive has been modified, but some trees and shrubs are retained.
The Burbank Fire Department has a Fire Hazard Reduction Program for brush clearance. Two Mountain Fire Zones are designated by the Fire Department. One zone is located along the foothills of the Verdugo Mountains in northeast Burbank, and the other is located in the southwestern portion of the city adjacent to Warner Bros. Studios. The program is designed to have property owners maintain their property in a safe fire condition throughout the year. The program guidelines have 12 specific requirements for 0-100 foot clearance, guidelines for 100- 200 foot clearance (fuel modification zone) and recommendations for vegetation management and defensible spaces. Beginning June1, 2020 Burbank Fire Department conducts annual brush clearance inspections. Burbank Fire Department also provides compliance enforcement.
The City of Burbank’s approach to fuels management is well designed and can be considered a leading practice.
Disabling Reclosing Operations
Disabling reclosing refers to the ability to turn off the functionality of substation reclosing circuit breakers and line reclosers to attempt to isolate fault conditions and re-energize (turn back on) areas of the electric grid. Traditionally, electrical circuits were designed to automatically open and close to detect and isolate faults. In many cases, the relays would make two or three attempts to isolate a fault condition. Each potential attempt could cause an electrical spark, which could be a source of ignition. Disabling reclosing significantly reduces the number of potential ignition sources.
BWP has a documented operating procedure that has been enacted to block reclosing capabilities on all circuits in the Tier 2 HFTD during RFW conditions to prevent any potential for vegetation ignitions. Additionally, BWP uses more sensitive, quicker acting relay settings during RFW conditions to increase the chance to detect and address a fault. These practices were enacted through four RFW events that extended across 11 days in 2021.
From the WMP, BWP states it “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. 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, BWP employed “more sensitive, quicker acting relay settings are employed during RFW conditions to increase the chance of detecting and isolating a fault.” Guidehouse finds BWP’s approach to disabling/blocking reclosing, and the use of more sensitive relays on RFW days is consistent with the best practices at other Utilities.
Non-Expulsive Fuse Devices
Fuses (Fusing) refer to protective devices that defend the distribution system from faulted or damaged lines and equipment. Historically, BWP, other utilities in California, and utilities across the country have used conventional fuses to protect powerlines. These conventional fuses, when operated, expel hot particles and gases, which can start fires. In order to mitigate the ATTACHMENT 2
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potential for fire ignitions, non-expulsive fuses can be installed to replace expulsion type fuses.
Fuses manufacturers now provide current-limiting dropout fuses with a self-contained design that eliminates expulsive showers associated with expulsion fuse operation. These non- expulsive fuses are more suitable for HFTDs. These non-expulsive fuses have also been granted permanent exemption by the California Department of Forestry and Fire Protection (CALFIRE) from pole clearance requirements if installed in the field according to manufacturer’s specifications.
BWP has made a substantial effort to replace its traditional fuses in the Tier 2 HFTD with exempt non-expulsive fuses, which it had identified as a key risk driver. Tables 3 and 4 in WMP Section 4.4 - Electrical Facility Assessment shows 229 OH distribution transformer and lateral fuses remaining within Tier 2. Additionally, BWP indicates in Section 4.4 - Electrical Facility Assessment, Table 5 - Electrical Equipment Risk Drivers Based on Historical Events that 41% of the historical events (26 potential ignitions) occurred with Tier 2, this section even breaks the numbers down by circuit for granular analysis.
BWP’s records show that 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 risk driver. After performing an engineering evaluation study in 2021, BWP determined that replacement of all conventional fuses in the Tier 2 HFTD with CALFIRE “Exempt” fuses is a cost-effective method of reducing the risk of utility caused wildfires in the Tier 2 HFTD.
According to BWP’s own investigation on this matter “Conventional fuse operations account for 47% of BWP’s risk driver events.” Therefore, BWP developed and implemented “a program to replace all conventional fuses in the Tier 2 HFTD with CALFIRE “Exempt” fuses based on the “California Power Line Fire Prevention Field Guide.” to further reduce the risk of wildfire.” BWP plans replace all conventional fuses with CALFIRE “Exempt” fuses in the Priority 2.1 zone of the Tier 2 HFTD. by June 2024.
BWP’s fuse replacement program to replace expulsive fuses with the non-expulsive fuses is a best practice and aligns with other utilities in the state.
Operational Activities Limitations
Procedures and routine operational practices that limit or curtail operational activities during periods of increased risk within fire threat districts are a best practice used by some California utilities. These procedures and practices provide employees and contractors specific information and instructions to improve the reliable and safe operations of electric facilities and mitigate the threat of utility caused inadvertent ignitions.
BWP has implemented several operational practices in the Tier 2 HFTD to reduce fire risk on Red Flag Warning (RFW) days. In the WMP Section 5.3 - Operational Practices, BWP notes that it blocks reclosing and increases its relay sensitivity to prevent the ignition of vegetation and debris. BWP also conducts line patrol after an outage event during an RFW to ensure lines are intact and free from flammable material. The utility also limits certain operational activities designated as Ignition Potential Work (IPW) within Tier 2. This is a best practice to reduce the probability of inadvertent ignitions by BWP workers and contractors. For emergency IPW that must be performed BWP also sets forth several fire prevention and safety practices that must be undertaken before any IPW can be performed. Finally, BWP records the number of outages and RFW days that occur each and the responsive actions taken by staff.
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BWP has developed and implemented several operational limitations during Red Flag Warning periods of extreme fire risk. These practices align with industry best practices.
Selective Undergrounding
Selective undergrounding is an effective option for hardening electric facilities for wildfires. The selection criteria can include areas of high tree density, circuits that may be impacted by a PSPS and areas with limited ingress and egress. Often, areas with mountainous terrain are not good candidates for undergrounding of OH lines due to right of way and construction complications. Selective undergrounding of distribution facilities also improves aesthetics and service reliability.
BWP has approximately 25 miles of distribution lines in Tier 2 HFTD, with 15 miles underground lines and 11 miles overhead wire. Currently, 60% of BWP’s distribution facilities in Tier 2 are underground. This undergrounding of distribution facilities within Tier 2 significantly reduces the threat of fire ignition.
BWP’s approach to selective undergrounding is consistent with the best practices at other Utilities.
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5. Best Practice Comparison
The following describes the scoring determinations of the benchmarking practice. Guidehouse weighed strategies that have been demonstrated globally as well as from those proposed by state utilities. As expressed in Figure 5-1, this benchmarking practice supports efforts to determine the Plan’s comprehensiveness when investigating the mitigation measures proposed in BWP’s WMP.
This assessment is designed to confirm prudent measures as proposed by BWP and did not result in any material findings that would result in non-compliance or lack of comprehensive WMP elements.
Figure 5-1 – Determinations for Benchmarking
The selected strategies represented in Table 5-1 include both statutory requirements that exist as industry standards for POUs as well as accepted industry practices within the state.
Table 5-1 – Industry Practice Strategy Comparison Matrix Situational Awareness / Weather Conditions
Identified Practice
Strategy Mitigation Rationale BWP Applicability Plan Elements Determination ATTACHMENT 2
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Real-time situational
awareness of
conditions that lead to
high risk of wildfires
requires a multi-
faceted approach
including but not
limited to coordination
with local public
agencies, weather
monitoring,
strategically placed
high visibility cameras
and other early
warning systems.
Having access to internal
and external mechanisms
to track fire conditions
(high wind, dry conditions,
high heat), will aid in
responding to and
preventing potential fires
by enacting related
protocols during fire watch
conditions
Especially in the
HFTD, weather
stations and
cameras would
allow BWP
personnel to have
access to real-time
monitoring of these
areas
In 2021, BWP’s ECC began
using the SCE owned fire-
monitoring camera in the
Verdugo Mountains to enhance
situational awareness as-
needed.
BWP’s Energy Control Center
monitors National Weather
Service warnings and watches
and coordinates with other
agencies and third parties in
the area.
BWP meets the basic
requirements of real-
time situational
awareness. Further
coordination with Los
Angeles Department
of Water and Power
(LADWP) is
encouraged
Cameras with night
vision mode capability
atop of electrical
structures
Visual inspections can be
enhanced through the use
of cameras with high
definition and night vision
capabilities. This measure
improves response times
in addressing risk incidents
and de-energization
The Tier 2 zone
within the BWP
service territory
mostly suburban
Given that the majority of
BWP’s Tier 2 is suburban, night
vision cameras may not be
necessary.
This best practice
strategy does not
apply to BWP
System Hardening / Design & Construction / Operational Practices Identified Practice
Strategy Mitigation Rationale BWP Applicability Plan Elements Determination ATTACHMENT 2
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Selective
undergrounding of
distribution facilities
within Tier 2,3.
Selective undergrounding is
an effective option for
hardening electric facilities
for wildfires. The selection
criteria can include areas of
high tree density, circuits
that may be impacted by a
PSPS and areas with
limited ingress and egress.
Often, areas with
mountainous terrain are not
good candidates for
undergrounding of OH lines
due rights of way and
construction
complications
Poles and overhead wires within
known areas of high fire severity
zones or past wildfires, should be
considered for selective
undergrounding
BWP has
approximately 25
miles of distribution
lines in Tier 2 HFTD,
with 14 miles
underground lines
and 11 miles
overhead wire. 60%
of the distribution
facilities in Tier 2 are
underground. This
undergrounding of
distribution facilities
within Tier 2 can
significantly reduce
the threat of fire
ignition. BWP has
determined that the
Sunset Canyon area
in Tier 2 is not
feasible for selective
undergrounding
BWP’s
undergrounding of
distribution
facilities is
implemented
primarily to
improve aesthetics,
service reliability
but it also
significantly
mitigates wildfire
risk.
Replacing bare
wires with covered
conductors
Covered wire is a well-
demonstrated prevention
method to sparks / ignitions
during severe weather
conditions. Several utilities
are employing pilot
programs of covered wire
replacement of distribution
lines, prioritizing HFTDs for
implementation.
BWP has overhead distribution lines
(11 circuit miles in Tier 2). This area
may benefit from additional
hardening such as covered wire
replacement for existing legacy bare
wire.
BWP performed an
analysis of #6 bare
copper conductor
and identified the
use of #2 aluminum
conductor steel
reinforcement
(ACSR) as an
alternative option.
This is currently
what BWP uses for
all new construction.
Replacing bare
wires with covered
conductors is a
common best
practice
successfully
employed by
several utilities with
similar operating
and environmental
conditions as
BWP.
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A deeper analysis of
the use of covered
conductor was
performed in
2022.Based on the
results of that study,
BWP will be
installing covered
conductor based on
location and risk.
BWP will benefit
from a full analysis
and installation of
covered
conductors at that
time.
New or planned
electrical lines
(distribution and
transmission) that
are designed to
withstand working
loads under the
stress above
design standards
to address high
wind speeds
As new capital
infrastructure plans are
developed, it would be
prudent to consider resilient
design standards that can
withstand sustained winds
and gusts that occur during
Red Flag Warning periods.
Construction of distribution facilities
meet or exceed GO 95 standards.
Specifically, BWP increases pole
strength requirements to meet the
GO 95 safety factors.
BWP designs poles
in accordance with
the wind loading
criteria set in
General Order 95
(GO 95) in order to
minimize the chance
of pole failure during
heavy winds.
As part of the
Design and
Construction
mitigation activities,
BWP performs
structural
assessments of
poles to identify
potential issues
during high wind
events. BWP
replaces the poles
that do not pass the
BWP’s actions are
consistent with
Utility best
practices for
design and
evaluation of poles
withstand working
loads under stress
for high winds.
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GO 95 wind loading
design criteria.
Steel or composite
poles swapped out
for wood poles, at
minimum, within
HFTDs or
fireproofing
wooden poles (fire
resistant material
coating)
When considering pole
replacement strategies,
when applicable, composite
or steel poles can reduce
the risk that wood poles
present. At minimum, fire
retardant material can be
coated to temporarily
enhance the ability to
prevent fire spread or
impact the stability of the
structure under fire threat.
Poles within known areas of high fire
severity zones or past wildfires,
should be considered for
replacement with more fire resilient
materials.
BWP continued
replacing poles that
were in the Priority
2.1 area of its Tier 2
HFTD with
composite poles,
where deemed
appropriate to
increase strength,
fire resistance, and t
assist with ease of
installation in difficult
terrain.
BWP is swapping
high risk poles with
composite
annually.
Pole loading
assessment, pole
intrusive inspection
and testing
Carry out programs that
address pole loading issues
and inspections that would
result in remediation to
infrastructure.
GO 165 is considered a “best
practice” by many public owned
utilities. GO 165 Section III A (5)
defines "Intrusive" inspection as one
involving movement of soil, taking
samples for analysis, and/or using
more sophisticated diagnostic tools
beyond visual inspections or
instrument reading.
BWP has performed
and will continue to
perform intrusive
pole inspections
within Tier 2. 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.
BWP’s actions are
consistent with
Utility best
practices for
intrusive pole
inspection and
testing.
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Expulsion fuse
device change out
to current-limiting
(non-expulsive)
fuses
Traditional fuses pose a fire
risk due to the ignited
material that can be
expelled. Best practices for
mitigating this risk is to
change out these fuses with
non-expulsive fuses.
A protective device
coordination study achieves
an optimum balance
between equipment
protection and selective
isolation that is consistent
with the operating
requirements of power
systems.
HFTDs would benefit from the
replacement of traditional fuses with
ones that minimize sparks and arcs
Electrical systems use fuses and
circuit breakers to protect electrical
equipment. Equipment failures and
other anomalies may cause a short
circuit. Risks are reduced within
HFTDs when a short circuit impacts
only that portion of the system
where the failure occurs.
BWP has made a
substantial effort to
replace its traditional
fuses in the Tier 2
HFTD with exempt
non-expulsive fuses,
which it had
identified as a key
risk driver. BWP
also determined
such replacements
are cost effective.
Tables 3 and 4 in
WMP Section 4.4 -
Electrical Facility
Assessment shows
229 OH distribution
transformer and
lateral fuses
remaining within Tier
2. Replacement of
expulsion fuses
with non-expulsion
fuses is a common
best practice.
BWP plans replace
all conventional
fuses with
CALFIRE “Exempt”
fuses in the Priority
2.1 zone of the Tier
2 HFTD. by June
2024.
Tree attachment
removals
This practice involves the
removal of electrical
infrastructure fastened to
trees for infrastructural
support but can be a source
of ignition. The removal of
these legacy devices may
reduce electrical spark risk.
BWP has no tree attachments within
Tier 2 that require evaluation
BWP does not have
tree attachments nor
use tree
attachments for new
construction
This best practice
strategy does not
apply to BWP
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Disabling reclosers
through blocking
reclosing
operations
(distribution level)
in HFTDs during
the fire season
and/or during Red
Flag Warnings
issued by the
National Weather
Service (or as fire
risk potential
designates)
Disabling reclosing reduces
the number of potential
ignition events during a fault
condition
Reclosing operations should be
defined within the Plan as per
statute PUC 8387 (b) (2) (F)
Operational best practices align with
having settings that align with fire
potential weather conditions to
prevent potential ignition
BWP has ten
distribution circuits
feeding Tier 2. No
OH line reclosers
are present in Tier 2.
BWP enacted an
operating procedure
to block reclosing
capabilities on all
circuits in Tier 2
during red flag
warning (RFW)
conditions.
Additionally, during
an RFW, BWP
enables high speed
tripping on the
distribution circuits
feeding Tier 2.
BWP’s actions
represent a Utility
best practice for
blocking reclosing
on distribution lines
within Tier 2
Ground patrol as
well as aerial
inspection
practices
Routine ground patrols are
implicit practices in
equipment and vegetation
inspection protocols.
Increasing the frequency,
especially in the HFTD,
represents an effective
preventative measure and
ensures the integrity of
electrical equipment. Aerial
inspections, by way of
helicopters, will lead to
greater coverage of the
service territory and areas
Ground patrols are a required
strategy in ensuring safe and
reliable delivery of electricity. When
access concerns arise, aerial
inspections provide better coverage
in surveying and inspecting electrical
equipment throughout the utility
service territory
BWP performs
inspection cycles in
accordance with GO
165. For Tier 2,
BWP performs
annual patrols for all
overhead
equipment.
Problems that are
identified during
inspection are
prioritized for
correction.
Inspection findings
are examined to
BWP’s actions are
consistent with
Utility best
practices for
ground patrols and
inspection
practices
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adjacent to required
clearances
identify trends and
recurring problems.
BWP has no areas
that would benefit
from an aerial
inspection.
Wildfire
Infrastructure
Protection Teams
An internal team to help
coordinate efforts to ensure
the Plan is being followed
as well as coordinating
efforts to enhance the
Plan's strategies and quality
check that activities are
being performed and
tracked aligning with the
Plan
An internal team to prepare and
protect physical aspects of the
electric system as well as ensure
effective mitigation measures are
carried out would be a prudent
activity to pursue
In Chapter 7,
Section 7.1. BWP
defines that the
General Manager
has overall
responsibility for the
plan. Table 11
shows activity
owners for the four
categories of
mitigation activities.
These assignments
can be as viewed
formation of a
Wildfire
Infrastructure
Protection team.
BWP’s actions are
consistent with
Utility best
practices for
Wildfire Protection
Teams.
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Vegetation Management
Identified Practice
Strategy Mitigation Rationale BWP Applicability Plan Elements Determination Routine vegetation
management &
inspections in
accordance with:
Public Resources
Code (PRC) 4292 &
4393, General Order
(GO) 95 Rule 35 and
State and federal
compliance for vegetation
management and
inspection, as well as
California Public Utilities
Commission GO 95, which
is accepted as industry
standard amongst all
PRC sections 4292
and 4293; GO 95 is
required by the
CPUC for investor
owned utilities.
Public Owned
Utilities (POUs)
BWP performs routine
vegetation management, such
as pruning and removal, on an
annual basis in Tier 2. Each
year, field patrols are
performed to inspect tree and
conductor clearances and to
identify any hazard trees.
Areas for vegetation pruning
BWP’s actions are
consistent with Utility
best practices for
routine vegetation
management
inspections.
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)
Establishment of
procedures and routine
operational practices that
limit or curtain operational
activities during periods of
increased risk within fire
threat districts. These
procedures and practices
provide employee and
contractors specific
information and instructions
to improve the reliable and
safe operations of electric
facilities and mitigate the
threat of utility caused
inadvertent ignitions.
Limiting operational practices may
reduce the probability of inadvertent
ignitions by utility workers and utility
contractors
In the WMP Section
5.3 - Operational
Practices, BWP
indicates blocking
reclosing and line
patrol after an
outage event during
an RFW as part of
the overall strategy
for Wildfire
Prevention. Limiting
operational activities
within Tier 2,3 is a
common best
practice to reduce
the probability of
inadvertent ignitions
by BWP workers
and contractors.
BWP has
implemented
several operational
practices in the
Tier 2 HFTD to
reduce fire risk on
RFW days
including limiting
IPW, blocking
reclosers and
adjusting trip
settings, and
instituting safety
protocols for
emergency work.
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Appendix E, and
ANSI A300
utilities. (Community and
investor owned).
generally follow
these guidelines.
and removal are targeted
based on the results of these
patrols.
Hazardous
tree/vegetation
identification and
removal protocols
and programs
Recording and tagging
trees that pose risks to
adjacent electrical
equipment or are
dead/dying are considered
prudent efforts for
vegetation management
practices
Within the HFTD,
danger trees could
pose a greater
potential to catch on
fire or contribute to
fire spread.
Addressing, though
identification and
surveying, as well
as implementing
remediation
activities will result
in further wildfire
risk reduction
Each year, field patrols are
performed to inspect tree and
conductor clearances and to
identify any hazard trees.
BWP’s actions are
consistent with Utility
best practices for
hazardous tree
identification and
removal protocols and
programs.
Fuels management
Fuels management is an
action designed to reduce
fire hazards by removing
or rearranging fuels. When
applied to strips of land,
they are designated as a
fuel break or fire break.
Fuel breaks are strips of
land in which vegetation,
both dead and alive has
been modified, but some
trees and shrubs are
retained.
Fuels management
is an effective
practice to reduce
fire intensity and
can provide safe
passage zones for
the public, BWP
workers and
Burbank Fire
Department
The Burbank Fire Department
has a Fire Hazard Reduction
Program for brush clearance.
Two Mountain Fire
Zones are designated by the
Department. One zone is
located along the foothills of
the Verdugo Mountains in
northeast Burbank, and the
other is located in the
southwestern portion of the city
adjacent to Warner Bros.
Studios. The program is
designed to have property
owners maintain their property
in a safe fire condition
The Fire Hazard
Reduction Program is
an effective program
to provide standards
and compliance for
fuels management for
the City of Burbank.
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throughout the year. The
program guidelines have 12
specific requirements for 0-100
feet clearance, guidelines for
100-200 clearance (fuel
modification zone) and
recommendations for
vegetation management and
defensible spaces. Beginning
June1, Burbank Fire
Department conducts annual
brush clearance inspections.
Burbank Fire Department also
provides compliance
enforcement.
BWP has a Line Clearance
Tree Trimming in Elevated Fire
Risk Areas Communications
Plan. The communications
plan informs the approximately
850 Burbank residents within
Tier 2 that they have until May
31, 2020 to trim trees on their
property to the California state
standards. Customers are also
notified that line clearance tree
trimming should only be
performed by arborists that are
certified to work around
energized power lines. After
May 31, 2020, and before the
wildfire season, BWP will trim
trees near BWP OH
distribution lines on customer
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property to the compliance
standard.
Off-Cycle / Call-in
vegetation removal or
corrective work,
especially during the
fire season
Off-cycle practices of
vegetation inspection and
management
Within BWP’s
HFTD, impact trees
could pose a
greater potential to
catch on fire or
contribute to fire
spread. Addressing,
though identification
and surveying, as
well as
implementing
remediation
activities will result
in further wildfire
risk reduction
BWP has a Line Clearance
Tree Trimming in Elevated Fire
Risk Areas Communications
Plan. The communications
plan informs the approximately
850 Burbank residents within
Tier 2 that they have until May
31, 2020 to trim trees on their
property to the California state
standards. Customers are also
notified that line clearance tree
trimming should only be
performed by arborists that are
certified to work around
energized power lines. After
May 31, 2020, and before the
wildfire season, BWP will trim
trees near BWP OH
distribution lines on customer
property to the compliance
standard.
A majority of the BWP
OH distribution lines in
Tier 2 traverses
through customer
backyards. The BWP
program and
communications to
trim trees in
compliance with the
state standards is a
proactive program and
best practice.
Emergency Response & Recovery
Identified Practice
Strategy Mitigation Rationale BWP Applicability Plan Elements Determination ATTACHMENT 2
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Notify critical facilities
and public safety
partners, which may
include first
responders, incident
origin law
enforcement, acute
health care facilities,
essential service
providers, related
governing local and
state agencies,
adjacent jurisdictions,
vulnerable
populations, and the
Independent System
Operator (ISO) (for
transmission level de-
energization)
Following a sequence of
events in contacting public
safety partners and
impacted community
facilities will enable
quicker response in
reacting to an emergency
event (such as a wildfire or
de-energization). Utilities
should describe their
processes to notify critical
facilities as it applies to
their service territory and
impacted communities as
well as grid operators.
Notification
practices targeting
key stakeholders
are crucial during
emergency events
such as storms and
wildfires.
BWP relies upon its Electric
Emergency Response Plan
(EERP) respond effectively to
wildfire threats and other
hazards. BWP does not have a
formal communications
protocols for direct notification
to all public safety offices,
critical first responders, health
care facilities, and operators of
telecommunications
infrastructure with premises
within the footprint for a PSPS
event.
Specific
communications
protocols for PSPS
events, even if
unlikely, improves
communication and
coordination.
Incident Command
Team / Emergency
Operations
frameworks in the
event a de-
energization event or
wildfire incident
occurs
Using the State
Emergency Management
System (SEMS)
framework, which is
determined on the Federal
Emergency Management
Agency (FEMA) structure
for incident command
protocols will ensure
prepared and adequately
trained staff to respond in
effective communication
manners as well as
respond to risk events in a
Establishment of
Emergency Action
Plans between the
Electric
Department, the
City Emergency
Operations Center
and other City
departments
assures effective
identification,
assignment and
training for
emergency
management roles.
BWP responds to emergencies
in accordance with its Electric
Emergency Response Plan
and in alignment with SEMS
and NIMS. This plan aligns
with the City of Burbank
Emergency Response Plans
and establishes a clear
Incident Command Structure
Sections 6.1 and 6.2
of the WMP set
forward a thoughtful,
comprehensive
approach to
emergency response.
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sequence of effective
procedures.
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6. Results and Discussion
Guidehouse finalized this assessment on March 17, 2023. Over the course of reviewing BWP’s WMP, discussions with BWP staff, and review of supporting documentation, Guidehouse captured takeaways and findings that align the WMP with state laws and effective wildfire measure demonstration for a utility of BWP’s size and low-risk profile. BWP’s WMP appropriately responds to each of the required elements of PUC Section 8387, which is detailed in Appendix A. The following describes the assessment and resulting findings of the WMP’s proposed and established mitigation measures as it applies to safe, reliable operation of all electric infrastructure and wildfire prevention and response.
Report Conclusions
After internal review of the latest version of the WMP and associated data collection products, Guidehouse concludes this Report with the following:
• BWP’s WMP aligns appropriately with PUC Section 8387 and includes all required elements.17
• BWP’s WMP is comprehensive as described through this Report in accordance with PUC Section 8387.
17 Following acceptance of this Report, BWP will post the Report and results online for public view. The Report is scheduled for presentation to the City Council at a public meeting in May 2023. Accomplishing these follow-up tasks will meet all required statutory provisions up until presenting the final WMP to the City Council.
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Appendix A. Statutory Compliance Matrix
Required Statutory Element
Plan
Section
Reference(s)
BWP Plan Elements
(Summarized)
Meets
Section
Elements
(Determination
)
(a) Each local publicly owned
electric utility and electrical
cooperative shall construct,
maintain, and operate its
electrical lines and equipment in
a manner that will minimize the
risk of wildfire posed by those
electrical lines and equipment.
(b) (1) The local publicly owned
electric utility or electrical
cooperative shall, before January
1, 2020, prepare a wildfire
mitigation plan. After January 1,
2020, a local publicly owned
electric utility or electrical
cooperative shall prepare a
wildfire mitigation plan annually
and shall submit the plan to the
California Wildfire Safety Advisory
Board on or before July 1 of that
calendar year. Each local publicly
owned electric utility and
electrical cooperative shall
update its plan annually and
submit the update to the
California Wildfire Safety Advisory
Board by July 1 of each year. At
least once every three years, the
submission shall be a
comprehensive revision of the
plan.
(2) The wildfire mitigation plan
shall consider as necessary, at
minimum, all of the following:
(A) An accounting of the
responsibilities of persons
responsible for executing the
plan.
Section 7.1
BWP has a Roles and Responsibilities
section in its plan with descriptions of
the roles of the Electric Utility Director,
Engineering and Operations Manager,
and Electric Superintendent as well as
each City Department.
Yes
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(B) The objectives of the wildfire
mitigation plan. Section 1.3
BWP has clearly stated objectives in
its plan. 1) Reduce the probability that
BWP’s electric system may be the
contributing source for the ignition of a
wildfire; 2) harden and maintain
BWP’s electric system against a
potential wildfire; and 3) create a
WMP consistent with state laws and
objectives.
Yes
(C) A description of the
preventive strategies and
programs to be adopted by the
local 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.
Sections 3
and 5
Section 3 provides an overview and
Section 5 provides a detailed
description of BWP’s preventative
strategies with specific subsections on
design and construction, inspection
and maintenance (including
vegetation management) operational
practices, and situational/conditional
awareness. BWP also considers
dynamic climate change risks in its
risk assessments and strategies.
Yes
(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 that underlie the use
of those metrics.
Section 7.2
BWP tracks numerous metrics that
can serve as leading indicators of
wildfire and associated risks. These
metrics are used by BWP to provide
insight into BWP’s performance and
dynamic conditions across BWP’s
service area. BWP also designates
the responsible party for collecting the
metrics and the periodicity for each
metric’s collection. BWP can be
considered a leader in this effort.
Yes
(E) A discussion of how the
application of previously identified
metrics to previous wildfire
mitigation plan performances has
informed the wildfire mitigation
plan.
Section 7.3.3
BWP discusses in detail how the
application of previously identified
metrics to previous wildfire mitigation
plan performances has informed the
wildfire mitigation plan.
Yes
(F) Protocols for disabling
reclosers and deenergizing
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.
Section 5.3.1
and 5.5
BWP discusses how BWP blocks
reclosing and increases trip speed
during Red Flag Warning conditions.
BWP discusses PSPS in section 5.5
but does not intend to use proactive
de-energization as a wildfire
prevention strategy but makes clear
the ECC has authorization to de-
energize if conditions warrant it or if
directed by Burbank Fire, Police, or
CAL FIRE
Yes
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(G) Appropriate and feasible
procedures for notifying a
customer who may be impacted
by the deenergizing of electrical
lines. The procedures shall
consider the need to notify, as a
priority, critical first responders,
health care facilities, and
operators of telecommunications
infrastructure.
Section 6.3
While BWP’s stated policy is NOT
performing de-energization, it would
use the communication procedures
noted in Section III.E to notify
customers.
Yes
(H) Plans for vegetation
management. Section 5.2.2 BWP details its vegetation
management program in its WMP Yes
(I) Plans for inspections of the
local publicly owned electric
utility’s or electrical cooperative’s
electrical infrastructure.
Section 5.2.1
BWP’s WMP states that it meets or
exceeds the inspection cycles and
requirements provided in GO 95 and
165.
Yes
(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:
Section 4.2,
4.5 BWP’s WMP includes a thorough
assessment of risk and risk drivers
and addresses the topics of design,
operation, and construction, as well as
topographic and climatological risk
factors.
Yes
(i) Risks and risk drivers
associated with design,
construction, operation, and
maintenance of the local publicly
owned electric utility’s or electrical
cooperative’s equipment and
facilities.
Section 4.2.1
BWP identifies five categories of risk
drivers and details their potential
impacts.
Yes
(ii) Particular risks and risk
drivers associated with
topographic and climatological
risk factors throughout the
different parts of the local publicly
owned electric utility’s or electrical
cooperative’s service territory.
Section 4.3
BWP discusses the risks and risk
drivers associated with its
climate/weather, topography, and
vegetation and applies those to a
detailed analysis of its service
territory.
Yes
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(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 identified in a
commission fire threat map, and
identification of where the
commission should expand a
high fire-threat district based on
new information or changes to
the environment.
Section 4.3.3
BWP’s WMP states that BWP’s
service area is appropriately classified
as Tier 1 and Tier 2 areas. BWP
further states it did not see a
justification for increasing the risk of
any particular area within its service
territory.
Yes
(L) A methodology for identifying
and presenting enterprise wide
safety risk and wildfire-related
risk.
Section 4.1
BWP includes a three-part process to
evaluate its risk. 1) a bowtie risk
analysis; 2) a site fire environment
assessment; and 3) an electrical
equipment assessment.
Yes
(M) A statement of how the local
publicly owned electric utility or
electrical cooperative will restore
service after a wildfire.
Section 6.4
BWP’s WMP provides a statement of
how it plans to restore service after a
wildfire, including a discussion of
efforts to inspect the condition of the
system prior to energization.
Yes
(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:
(i) Monitor and audit the
implementation of the wildfire
mitigation plan.
Section 7.3,
7.3.3 BWP states it will conduct annual
internal audits of the plan to identify
deficiencies. BWP also provides an
extensive writeup of its prior year
audit and responses. Yes
(ii) Identify any deficiencies in the
wildfire mitigation plan or its
implementation, and correct
those deficiencies.
Section 7.3.1
BWP has stated that deficiencies
identified should be corrected through
the Assistant GM.
Yes
(iii) Monitor and audit the
effectiveness of electrical line and
equipment inspections, including
inspections performed by
contractors, that are carried out
under the plan, other applicable
statutes, or commission rules.
Section 7.3.2
BWP has monitored and audited the
effectiveness of electrical equipment
inspections in 2021, including
inspections
performed by its vegetation
management contractor.
Yes
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(3) The local publicly owned
electric utility or electrical
cooperative shall, on or before
January 1, 2020, and not less
than annually thereafter, present
its wildfire mitigation plan in an
appropriately noticed public
meeting. The local publicly owned
electric 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.
Section 8.2
BWP will presents its WMP to the City
Council at a public annually, following
public posting and opportunities for
public comment.
Yes
(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 website
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.
Section 8.3
BWP contracted with Guidehouse
Consulting, Inc. to perform an
independent evaluation of its WMP.
Qualifications are described in Section
1. Yes
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