1 STAFF REPORT
DAT
E: May 23, 2023
T
O: Justin Hess, City Manager
F
ROM: Dawn Roth Lindell, General Manager, Burbank Water, and Power VIA: Riad Sleiman, Assistant General Manager, Electric Services BY: Sven Knauth, Electrical Engineer
S
UBJECT: Verify Independent Evaluator Report and Annual Update to the Burbank Water and Power Wildfire Mitigation Plan
RE
COMMENDATION
1. Verify that Burbank Water and Power’s Wildfire Mitigation Plan complies with all applicable rules, regulations, and standards (Attachment 1).
2. Direct Burbank Water and Power to accept all reasonable and appropriate comments on the Wildfire Mitigation Plan from the public, other local and state agencies, and interested parties that are received prior to July 1, 2023.
BACKG
ROUND
This report is provided to inform the Burbank City Council (Council) about the comprehensive update of Burbank Water and Power’s ( BWP) Wildfire Mitigation Plan (WMP) and the results of the Independent Evaluator Report ( IER) and to accept comments from the public and the Council. The WMP must be updated annually and comprehensively every three years to comply with Public Utilities Code Section 8387 (PUC 8387) regarding wildfire mitigation for publicly owned utilities (POUs).
T
he state of California enacted Senate Bill 901 in September 2018 and Assembly Bill 1054 in July 2019. These bills amended PUC 8387, which addresses wildfire mitigation for POUs. This legislation included several new provisions, including a requirement for each POU to prepare and present a WMP to its governing body annually and comprehensively update its WMP every three years. Each POU must submit their WMP to the California Wildfire Safety Advisory Board (WSAB) by July 1st of every year. Since the first WMP was drafted in December 2019, BWP has complied with this state law. In addition, PUC 8387 requires every POU to contract with an independent evaluator (IE) to review and assess the comprehensiveness of its WMP, issue the IER on its website, and have the IE present the IER to its governing board. While PUC 8387 imposed no specific deadline for meeting these obligations and did not impose a clear frequency for the IER, BWP has chosen to match the IER frequency to the comprehensive update cycle of the WMP to ensure it remains in compliance and the mitigation methods are consistent with
WATER AND
POWER
2 industry best practices. This three- year IER cycle also aligns with WSAB recommendations.
In 2018, a single statewide fire-threat map was adopted to define different high fire-threat districts (HFTD), which are areas of elevated fire risk (Tier 2) and areas of extreme fire risk (Tier 3) from electric utility-related wildfires. Within these HFTDs, increased fire-safety regulations were enacted regarding vegetation management, clearances, and inspections. About 28% of BWP’s geographical service territory is within a Tier 2 HFTD.
BWP maintains approximately 11 miles of overhead electrical lines within the Tier 2 HFTD, about 5.4% of the total overhead lines in the service territory. BWP’s WMP analyzes the risk these assets pose and defines several mitigation activities that BWP pursues yearly to reduce the risk of electrical facilities igniting a wildfire in Burbank.
DISCUSSION
During the 2022 WMP cycle, BWP completed several wildfire mitigation activities in the Tier 2 HFTD, including:
• Replacing 1 deteriorated pole
• Completing all annual asset and vegetation inspections • Trimming 103 trees and removing 1 “problem” tree
• Blocking reclosing during the 5 Red Flag Warning days • Replacing 38 conventional fuses with non-expulsive fuses
BWP decided to implement three new mitigation activities in the 2023 WMP update after completing studies of improvements in the Tier 2 HFTD that could provide additional wildfire risk reduction. These three new mitigation activities are covered conductor replacement, falling conductor protection, and infrared inspections. BWP is now in the initial stages of deploying these mitigation strategies.
As part of the comprehensive update, BWP reviewed the plan in detail. We updated the facility counts, risk analysis (including a site assessment review), prevention strategies, and emergency preparedness. We also developed a new risk model to define higher-risk areas and track mitigation impacts. This risk model reaffirmed prior analysis of higher priority areas within the Tier 2 HFTD that remain the primary focus for mitigation activities.
BWP also reviewed all rules, regulations, and standards, including the state of California’s General Order 95 Rules for Overhead Electric Line Construction and General Order 165 Inspection Requirements for Electric Distribution and Transmission Facilities. BWP drafted a WMP compliant with all applicable rules, regulations, and standards.
BWP recently contracted with Guidehouse, Inc. (Guidehouse) to independently evaluate its 2022 WMP. This IER describes the technical review and evaluation provided by Guidehouse. This evaluation was performed over the last two months by reviewing detailed information and assessing BWP’s procedures related to BWP’s WMP. While the IER included some minor updated recommendations regarding the WMP, Guidehouse has concluded that BWP’s WMP is comprehensive and meets the statutory requirements in accordance with PUC 8387. As part of an annual compliance requirement to present 3 an updated WMP to its governing body, BWP will continue to address these minor recommendations from the report in its annual WMP update to the BWP Board and Council. The latest 2023 IER recommendations are addressed in this 2023 WMP update.
ENVIRONMENTAL REVIEW
This activity has no potential for resulting in either a direct physical change in the environment or a reasonably foreseeable indirect physical change in the environment, and as such, is not a “project” subject to the requirements of the California Environmental Quality Act (CEQA) 14 Cal. Code Regs § 15378.
The existing capital improvement programs in the approved budget used for the mitigation activities in the WMP consist of several projects. Prior to the commencement of each “project,” staff will determine if it has the potential to result in a direct or indirect physical change to the environment and if it is subject to the requirements of the California Environmental Quality Act (CEQA).
FISCAL IMPACT
The proposed WMP has a fiscal impact on BWP’s capital improvement plan (CIP) budget for 2022/2023. BWP previously budgeted $500,000 of CIP funds in the fiscal year 2021/2022 and has budgeted an additional $500,000 of CIP funds in the fiscal year 2022/2023 for the installation of new technology and materials needed to reduce further the risk of ignitions from electrical equipment in the Tier 2 HFTD. Future full deployment of all mitigation activities will require additional funding and will be accounted for in future budget proposals.
CONCLUSION
BWP’s 2023 WMP is a comprehensive document that meets the statutory requirements in accordance with PUC section 8387, as shown in the IER. The activities outlined in this WMP update will further reduce the risk of wildfire due to BWP electrical facilities, improve the reliability of circuits in the Tier 2 HFTD, and continue our long-standing commendable safety record in our community.
ATTACHMENTS
Attachment 1 – Burbank Water and Power Wildfire Mitigation Plan 2023 Attachment 2 – 2023 Independent Evaluation of Burbank Water and Power’s 2022 Wildfire Mitigation Plan