Burbank Water and Power - W ildfire Mit igat ion Plan Page | 1 Burbank Water and Power
W ILD FIRE
MITIGATION
P LAN
2024
Burbank Water and Power - W ildfire Mit igat ion Plan Page | 2
TABLE O F CONTENTS
LIST OF ACRONYMS AND ABBREVIATIONS............................................................................................................................................ 5 DEFINITIONS .......................................................................................................................................................................................... 6 CHAPTER 1. INTRODUCTION ................................................................................................................................................................ 8
1.1 Policy statement ......................................................................................................................................................................... 8
1.2 Plan summary ............................................................................................................................................................................ 8
1.3 WMP objectives ........................................................................................................................................................................ 11 CHAPTER 2. BURBANK WATER AND POWER ..................................................................................................................................... 11
2.1 BWP profile .............................................................................................................................................................................. 11
2.2 Service territory ......................................................................................................................................................................... 12
2.3 Electric system .......................................................................................................................................................................... 12 CHAPTER 3. PREVENTATIVE STRATEGIES AND PROGRAMS OVERVIEW ............................................................................................... 14
3.1 Preventative strategies and programs overview ........................................................................................................................ 14 CHAPTER 4. RISK ANALYSIS AND RISK DRIVERS ................................................................................................................................. 16
4.1 Risk analysis methods ................................................................................................................................................................... 16
4.1.1 Hazard vs. risk discussion .............................................................................................................................................................................. 16
4.2 Wildfire risk bowtie analysis ......................................................................................................................................................... 16
4.2.1 Potential risk drivers ................................................................................................................................................................................ 18
4.2.2 Key risk impacts ........................................................................................................................................................................................ 19
4.3 Site fire environment assessment of BWP’s electric service territory ............................................................................................ 20
4.3.1 High fire threat district ............................................................................................................................................................................. 20
4.3.2 Wildfire-threat area site evaluation .......................................................................................................................................................... 22
4.3.3 Evaluation of higher fire-threat areas ....................................................................................................................................................... 24
4.4 Electrical facility assessment ......................................................................................................................................................... 24
4.5 Prioritization of wildfire risks ........................................................................................................................................................ 29
4.6 Mitigation activities that address risk drivers ............................................................................................................................... 30
4.7 Review of risk drivers and analysis ................................................................................................................................................ 30 CHAPTER 5. WILDFIRE PREVENTION STRATEGIES AND PROGRAMS..................................................................................................... 32
5.1 Facility design and construction .................................................................................................................................................... 32
5.1.1 Deteriorated pole replacements ............................................................................................................................................................. 32
5.1.2 Pole loading assessments & remediation ................................................................................................................................................ 32
5.1.3 Overloaded transformer replacements .................................................................................................................................................... 33
5.1.4 Distribution construction standard improvements ................................................................................................................................. 33
5.1.5 Conventional fuse replacements ............................................................................................................................................................. 34
5.2 Inspection and maintenance ........................................................................................................................................................ 35
5.2.1 Annual patrol inspection (GO 165) .......................................................................................................................................................... 35
5.2.2 Vegetation management program ........................................................................................................................................................... 36
5.2.3 Intrusive pole inspections ........................................................................................................................................................................ 36
5.3 Operational practices ................................................................................................................................................................... 37
5.3.1 Block reclosing and increase relay sensitivity during RFW ...................................................................................................................... 37
5.3.2 Line patrol after outage event during RFW .............................................................................................................................................. 37
5.3.3 Ignition potential work practices during RFW.......................................................................................................................................... 38
5.4 Situational/conditional awareness ............................................................................................................................................... 38
5.4.1 Weather/fire monitoring .......................................................................................................................................................................... 38
5.4.2 Geographic information system (GIS) applications .................................................................................................................................. 39
5.4.3 Enhanced system monitoring .................................................................................................................................................................. 39
5.5 Pre-emptive de-energization ........................................................................................................................................................ 39 Burbank Water and Power - W ildfire Mit igat ion Plan Page | 3
5.6 Description of customer outreach and education ........................................................................................................................ 40 CHAPTER 6. EMERGENCY PREPAREDNESS AND RESPONSE ................................................................................................................ 41
6.1 Emergency management ......................................................................................................................................................... 41
6.1.1 BWP Department Operations Center ............................................................................................................................................................ 43
6.2 Disaster and emergency response ............................................................................................................................................ 43
6.2.1 Fire agency emergency response .................................................................................................................................................................. 44
6.3 Customer support during emergencies .................................................................................................................................... 44
6.4 Restoration of service ............................................................................................................................................................... 44 CHAPTER 7. PERFORMANCE METRICS AND MONITORING ................................................................................................................ 45
7.1 Accountability of the plan ........................................................................................................................................................ 45
7.2 Metrics to evaluate plan performance ..................................................................................................................................... 46
7.2.1 BWP performance metrics ....................................................................................................................................................................... 46
7.2.2 Annual performance metrics ................................................................................................................................................................... 48
7.3 Monitoring and auditing the plan ............................................................................................................................................ 49
7.3.1 Identifying and correcting deficiencies in the WMP ................................................................................................................................ 49
7.3.2 Monitoring and auditing the effectiveness of inspections ....................................................................................................................... 49
7.3.3 Annual internal audit ............................................................................................................................................................................... 49 CHAPTER 8. PUBLIC COMMENT, PRESENTATION, AND INDEPENDENT EVALUATION ......................................................................... 54
8.1 Public comment ....................................................................................................................................................................... 54
8.2 Presentation to BWP Board and Burbank City Council ............................................................................................................. 54
8.3 Independent evaluation ........................................................................................................................................................... 54
8.4 Wildfire Safety Advisory Board ................................................................................................................................................. 55 CHAPTER 9. REFERENCES ................................................................................................................................................................... 56 EXHIBIT A. CONTEXT-SETTING INFORMATION TABLE ........................................................................................................................ 57 EXHIBIT B. SUMMARY OF KEY CHANGES IN BWP’S 2024 WMP .......................................................................................................... 59 Burbank Water and Power - W ildfire Mit igat ion Plan Page | 4
FIGURES
FIGURE 1 - BW P'S ELECTRIC LOAD ................................................................................................................................................................ 12 FIGURE 2 - BW P ELECTRIC DISTRIBUTION SYSTEM ........................................................................................................................................ 13 FIGURE 3 - BW P'S W ILDFIRE RISK BOW TIE .................................................................................................................................................... 17 FIGURE 4 - BW P'S TIER 2 HIGH FIRE THREAT DISTRICT .................................................................................................................................. 21 FIGURE 5 - HISTORICAL FIRES IN BURBANK .................................................................................................................................................... 23 FIGURE 6 - ELECTRICAL FACILITIES W ITHIN THE TIER 2 HFTD ....................................................................................................................... 25 FIGURE 7 - WILDFIRE RISK PRIORITIZATION W ITHIN THE TIER 2 HFTD ......................................................................................................... 29 FIGURE 8 - BW P EM ERGENCY RESPO NSE TEAM ORGANIZATIO N .................................................................................................................. 42
TABLES
TABLE 1 - PLAN CO M P LIAN CE W ITH PUC 8387( B) .......................................................................................................................................... 8 TABLE 2 - OVERVIEW O F MITIGATION ACTIVITIES .......................................................................................................................................... 14 TABLE 3 - BREAKDOW N OF BW P'S ELECTRICAL ASSETS W ITHIN THE TIER 2 HFTD ...................................................................................... 24 TABLE 4 - INVENTORY OF BWP ASSETS IN THE TIER 2 HFTD BY CIRCUIT ..................................................................................................... 26 TABLE 5 - ELECTRICAL EQUIPMENT RISK DRIVERS BASED ON HISTORICAL EVENTS ......................................................................................... 27 TABLE 6 - MITIGATION ACTIVITIES THAT ADDRESS RISK DRIVERS ................................................................................................................... 30 TABLE 7 - DISTRIBUTION INSPECTION CYCLES (MAXIMUM INTERVAL IN YEARS) ............................................................................................. 35 TABLE 8 - VEGETATIO N CLEARANCES ............................................................................................................................................................. 36 TABLE 9 - PRIO RITY LEVEL O F DETERIORATED PO LES BASED O N INTRUSIVE INSPECTIO NS .............................................................................. 37 TABLE 10 – ELECTRIC SERVICES TEAM RESPO NSIBILITIES DURING AN EMERGENCY RESPO NSE EVENT ............................................................ 42 TABLE 11 - ACCOUNTABILITY FOR WMP CO MPONENTS .............................................................................................................................. 45 TABLE 12 - BW P W ILDFIRE PREVENTION PERFORMANCE METRICS OVERVIEW ............................................................................................. 47 TABLE 13 - 2022 BW P W ILDFIRE PREVENTION PERFO RMANCE METRICS DATA ............................................................................................ 48 TABLE 14 - 2022 SUMMARY OF RISK DRIVER EVENTS IN THE TIER 2 HFTD .................................................................................................. 49 TABLE 15 - SUMMARY OF MITIGATION ACTIVITY ACCOMPLISHMENTS IN 2022 ............................................................................................ 51
Burbank Water and Power - W ildfire Mit igat ion Plan Page | 5 Lis t of Acro nyms and Abbreviations
AMI Advanced Metering Infrastructure
BWP Burbank Water and Power
CAL FIRE California Department of Forestry and Fire Protection CPUC California Public Ut ilit ies Commission
CW SAB California W ildfire Safe t y Advisory Board
DOC Department Operations Center
ECC Energy Control Center
EERP Electric Emergency Response Plan
ERP Emergency Response Plan
EM Emerge ncy Management
GIS Geographic Information System
GO General Order
HFTD High Fire Threat District
IC Incident Command or Incident Commander
ICS Incident Command System
IE Independent Evaluat ion
kV Kilovolt
MW Megawatts
NERC North American Electric Reliabilit y Corporation
NIMS National Incident Management System
NWS National Weather Service
OMS Outage Management System
PRC California Public Re source s Code
PUC Public Ut ilit ies Code
RFW Re d Flag Warning
SB Senate Bill
SCADA Supervisory Control and Data Acquisit ion
SEMS Standardized Emergency Management System
SME Subj ect Matter Expert
T&D Transmission and Distribut ion
WMP W ildfire Mit igat ion Plan
WUI W ildland Urban Int e rface
Burbank Water and Power - W ildfire Mit igat ion Plan Page | 6 De finitions
1. Energy Control Center (ECC): BW P ’s ECC personnel are responsi bl e for di recti ng the safe and rel i abl e operation of BWP’ s electric system while operating within current policies and procedures during normal and emergency situations. The ECC prepares, checks, and administ e rs the executi on of safe and reliable switching procedures. The ECC will monitor and maintain equipment -loading le ve ls t o prevent damage to equipment. The ECC is also responsible for updating outage informat ion t ime ly and accurately.
2. General Order 95 ( GO 95): GO 95 is a se t of rules formulat ed by t he California Public Ut ilit ie s Commission (CPUC) with the purpose of creating requirements for overhead line design, construction, and maintenance. W hile the CPUC does not have dire ct governance over publicly owned utilities, BWP designs, constructs, and maintains all overhead electrical lines to meet or exceed this industry standard.
3. General Order 165 (GO 165) : GO 165 is a set of rule s formulated by the CPUC wit h the purpose of creat ing require me nt s for t he inspe ct ion of e le ct ric distribut ion and transmission facilit ie s in order to ensure safe and hi gh -qualit y e le ctric service. BW P has an inspe ct ion program in place t hat me e ts or exceeds this industry standard.
4. Harden ing: Modificat ions to el ectri c infrastructure to reduce the likelihood of ignit ion and improve t he survivabilit y of ele ct rical assets.
5. High Fire Threat Dist rict (HFTD): In 2017, the CPUC adopted new fire safety regulat ions to combat the threat of wildfire for areas in Northern and Southern California. High Fire Threat Districts (HFTD) have be e n classified as High Hazard Zone s due t o tree mortalit y (Tie r 1), elevat ed risk for ut ilit y - associated wildfire s (Tie r 2 ), and extreme risk for ut ilit y-associ ated wildfire s (Tie r 3 ).
6. Incident Commander ( IC) : The IC is the person responsible for all aspects of an emergency response , including quickly de ve loping incide nt obje ct ive s, managing all incide nt operat ions, applicat ion of resources, as we ll as re sponsibilit y for all persons involved. The IC sets priorit ies and defines the organization of the incident response teams and the overall incident action plan.
7. Incident Command System (ICS): The ICS “a systematic tool used for the command, control, and coordination of emergency response” according to the state Standardized Emergency Management System and federal National Incident Management System. A more detailed definition of an ICS according to the United States Center for Excellence in Disaster Management & Humanitarian Assistance is “a se t of pe rsonne l, policies, procedure s, facilit ie s, and e quipme nt , inte grated int o a common organizational structure designed to improve emergency response operations of all t ype s and comple xit ie s.” Responding emergency se rvice providers would e stablish the ICS and designate an Incident Commander.
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8. Red Flag Warning (RFW ): An RFW is a warning issue d for a stated period of t ime by the National Weather Service using pre -determined criteria to ide nt ify part icularly crit ical wildfire danger in a particular geographic area. The Nati onal Weather Servi ce i ssues an R FW when “ warm temperatures, very l ow humidit y, and stronger winds are expected to combine to produce an incre ased risk of fire danger.”
9. Senate Bill 901 ( SB 901) : SB 901 is legisl ation enacted as of September 21, 2018 that, among other changes and requirements, amended California Public Ut ilit ies Code (CPUC) Se ct ion 8387 to provide in subpart (b ) that each local publicly owned elect ric ut ilit y and e le ctrical corporat ive shall annually prepare and present a wildfire mit igat ion plan (W MP) to it s governing board for revi ew and approval, and to specify in subpart (b ) (2) the elements that must be included in suc h WMP. As used herein, SB 901 refers to the requirements of CPUC Section 8387.
10. W ildfire Risk: The risk of a potential wildfire event caused by BWP electrical line s or equipment.
Burbank Water and Power - W ildfire Mit igat ion Plan Page | 8 Chapter 1. I ntroduction
1.1 Policy Statement
Burbank Water and Powe r is commit ted t o safe ly providing re liable , affordable , and sust ainable ut ilit y services for our community.
1.2 Plan Summary
While the City of Burbank has experienced several wildfires in the Verdugo Mountains throughout its history, no wildfire s have e ver bee n cause d by BW P ele ctrical facilit ie s. This W MP de scribe s t he range of activit ies t hat BWP i s taki ng to mi ti gate the threat of power -line ignited wildfires, including it s various programs, policie s and procedures. This plan will be reviewed and eval uated by its governing board each year. This plan meets or exceeds the requi rements of PUC se ct ion 8387 for publicly owned el ectri c ut ilit ie s to prepare a WMP by January 1, 2020, and annually thereafter . Table 1 below summarizes the plan compliance wit h the corresponding plan se ct ions referenced.
This plan is available on BW P’s website at BurbankW ate rAndPower.com under Elect ric > W ildfire Mit igat ion Plan. For a summary of changes to the 202 4 WMP, refer to Exhibit B, Summary of K ey Changes in BWP’ s 202 4 WMP.
Table 1 - Plan complian ce with PUC 8387( b)
SB 901
requirement
Descript ion
Plan sect ion number
b (2 ) (A) An accounting of the responsibilities of the persons responsible for executing the plan. 7.1
b (2 ) (B) The obje ct ive s of t he wildfire mit igat ion plan. 1.3
b (2 ) (C)
Description of the preventative strategies and programs to be adopted by the publicly owned electric utility or e le ctrical coope rat ive t o minimize t he risk of it s e le ct rical lines and equipment causing catastrophic wildfires, including consideration of dynamic climate change risks.
3, 5
b (2 ) (D)
A de script ion of t he me trics t he local publicly owne d elect ric ut ilit y or e le ctrical cooperative plans to use to evaluate the wildfire mitigation plan’ s performance and the assumptions made that underlie the use of those metrics.
7.2 Burbank Water and Power - W ildfire Mit igat ion Plan Page | 9 SB 901
requirement
Descript ion
Plan sect ion number
b (2 ) (E)
A discussion of how t he applicat ion of pre viously ide nt ifie d metrics to previous wildfire mitigation plan performances has informe d t he wildfire mitigat ion plan.
7.3.3 b (2 ) (F)
Protocols for disabling reclosers and de -e ne rgizing port ions of t he e le ct rical dist ribut ion syst e m t hat conside r t he associated impacts on public safety, as well as protocols related to mitigating the public safety impacts of those protocols, including impacts on critical first responders and on health and communication infrastructure
5.3.1, 5.5
b (2 ) (G)
Appropriate and feasible procedures for notifying a customer who may be impacted by the de -e nergizing of ele ct ric lines. The procedures shall consider the need to notify, as a priorit y, crit ical first re sponde rs, he alt h care facilit ie s, and operators of telecommunications infrastr ucture.
6.3 b (2 ) (H) Plans for vegetation management. 5.2.2 b (2 ) (I) Plans for inspe ct ions of the local publicly owne d ele ctric ut ilit ie s or el ectri cal cooperati ve’ s el ectri cal i nfrastructure. 5.2.1
b (2 ) (J)
A list t hat ide nt ifie s, de scribe s, and priorit ize s all wildfire risks, and drivers for those risks, throughout the local publicly owne d ele ct ric ut ilit ie s or el ectri cal cooperati ve’ s servi ce t e rrit ory. The list shall include , but not be limit ed to, bot h of t he following:
4.2, 4.5
b (2 ) (J) (i)
Risks and risk drivers associated with the design,
construction, operations, and maintenance of the local
publicly owned e le ctric ut ilit y or e le ctrical coope rat ive’s equipment and
facilit ie s.
4.2.1 b (2 ) (J) (ii)
Particular risks and risk drivers are associated wit h
topographic and climatological risk factors throughout the differe nt part s of t he local publicly owned ut ilit ie s or electrical cooperative’ s
service territory.
4.3 b (2 ) (K)
Ide nt ificat ion of any ge ographic area in t he local publicly owne d ele ct ric ut ilit ie s or el ectri cal cooperati ve’ s servi ce t e rrit ory t hat is a highe r wildfire t hre at t han is curre ntly ide nt ifie d in a commission fire t hreat map, and ident ificat ion of where th e commission should expand the high fire
threat district based on new information or changes to the environment.
4.3.3 Burbank Water and Power - W ildfire Mit igat ion Plan Page | 10 SB 901
requirement
Descript ion
Plan sect ion number
b (2 ) (L) A methodology for identifying and presenting enterprise - wide safe t y risk and wildfire -related risk.
4.1 b (2 ) (M) A st ateme nt of how t he local publicly owned ele ctric ut ilit y will rest ore se rvice aft er a wildfire .
6.4 b (2 ) (N)
A description of the processes and procedures the local publicly owned e le ctric ut ilit y or e le ctrical coope rat ive shall use to do all of t he following:
b (2 ) (N) (i) Monit or and audit t he wildfire mit igat ion plan. 7.3 b (2 ) (N) (ii) Ide nt ify any de ficie ncie s in t he wildfire mit igat ion plan or it s implementation, and correct those deficiencies.
7.3.1 b (2 ) (N) (iii)
Monitor and audi t the effecti veness of el ectri cal l i ne and equipment inspections, including inspections performed by contractors that are carried out under the plan, and other applicable statutes, or commission rules.
7.3.2 b (3 )
The local publicly owned e le ctric ut ilit y or e le ctrical cooperat ive shall prese nt each wildfire mit igat ion plan in an appropriate ly not iced public mee t ing. The local publicly owne d ut ilit y or ele ct rical cooperat ive shall accept comme nt s on it s wildfire mit igat ion plan from t he public, ot he r local and state agencies, and interested parties, and shall verify that t he wildfire mit igat ion plan complies wit h all applicable rules, regulations, and standards as appropriate.
8.2 (c)
The local publicly owne d e le ctric ut ilit y or e le ctrical cooperative shall contract with a qualified independent evaluator with experience in assessing the safe operation of el ectri cal i nfrastructure to revi ew and assess the comprehensiveness of its wildfire mitigation plan. The
independent e valuat or shall issue a re port t hat shall be made available on t he inte rne t we b site of t he local publicly owned electric utility or electrical cooperative and shall present the report at a public me e t ing of t he local publicly owne d ele ct ric ut ilit ie s or e lectrical cooperative’ s governing board.
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1.3 WMP Object ives
The primary obje ct ive s of t his WMP are to:
1. Reduce the probabilit y that BW P ’s electri c system may be the contributing source for the ignit ion of a wildfire
2. Harden and m aintain BWP’ s electric system against a pote nt ial wildfire
3. Create a WMP that i s consi stent wi th state l aw and obje ct ive s
BWP continually evaluates prudent and cost -effective improvements to its design standards, physical assets, inspection and maintenance programs, operations, and training in order to meet these objectives. This plan docume nts mit igat ion act ivit ie s t hat will be carried out by BW P. Last ly, t his plan will se t me asure s of effectiveness to inform future improvements or modificat ions t o spe cific programs and strate gie s.
Chapter 2. Burbank Water and Power
2.1 BWP Profile
Burbank Water and Power is a vertically integrated, publicly owned municipal utility that has served Burbank’ s electrical needs for more than 100 years. Being vertically integrated means that BWP generates, transmits, and distributes power to Burbank customers. BWP is o wned 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 se rvice at cost .
BWP is committed to providing reliable, affordable , and sustainable electrical service to Burbank. B W P ’s reliabilit y is superb, maint aining e le ctrical se rvice t o BW P’s cust omers 99.99% of the ti me in 2022 . In t e rms of affordabilit y, BW P’s rates are near t he lowe st in t he re gion. BW P’s commit me nt t o sust ainabilit y is strong: In 2007, BWP was the fi rst uti lity to commit to 33% renewabl es by 2020 and BWP reached 33.3% renewabl es i n fiscal ye ar 2016- 17. Consistent with BWP’ s 2019 Integrated Resource Plan, by the end of the planning period i n 2038, BWP woul d have renewabl es equi val ent to a 67% renewabl e portfo lio standard, approximately double the current l evel .
For a summary of informat ion regarding BW P’s se rvice territory, please refer to Exhibit A, Context -Setti ng Information Table .
Portions of t he context setting table in Exhibit A and this WMP Chapter 2 are updated on a three year cycl e coinciding wit h comprehensive revisions and independent evaluations.
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2.2 Service Territory
BW P ele ct ric syst em provide s power t o approximat ely 53, 000 customers across 17 square miles within the cit y limit s. Burbank is known as t he m edia capit al of t he world and is home to two of the world’ s largest studios : Warner Bros. Entertainment and The Walt Disney Company. The city is also home to thousands of smaller businesses, many of whom moved to Burbank in the early 1990s after the aerospace industry contracted and more real estate became avai l abl e. These busi nesses have come to expect cost -effecti ve and reliable e le ctrical service, as well as additional services such as fiber optic networking.
Burbank has a vibrant residential community, with a housing mix of about 18,750 single -family homes that range from post -World War II bungalows to two story view homes. There are about 28,850 multifamily homes.
I n total , BWP curre nt ly serves 46,148 re side nt ial, 5,495 small commercial, 1,269 medium comme rcial, 1 61 large commercial, and 82 extra -large customer accounts. These customer class counts are the 3 -year average through 2022.
2.3 Electric System
BW P supplie s e le ctrical service t o it s cust omers t hrough a distribut ion ne t work, which includes 12 distribution substations, 2 large customer substations, 4 swit ching stat ions, 4 4 mi les of 34.5 kilovolts (kV) sub-transmission line s, 33 mile s of 69kV t ransmission line s, 204 miles of overhead distribution lines, 132 miles of underground distribut ion lines, 584 miles of overhead secondary lines, 119 miles of underground secondary lines , 10,741 poles, and 5,8 25 transformers. BWP’ s all -time peak demand was 322 MW in 2017 but is forecast to remain flat for the next several years.
Figure 1 - BWP's elect ric load
Burbank Water and Power - W ildfire Mit igat ion Plan Page | 13
Figure 2 - BW P ele ct ric dist ribut ion system
Burbank Water and Power - W ildfire Mit igat ion Plan Page | 14 Chapter 3. Preventati ve Strategi es and Programs
Overview
3.1 Preventative Strategies and Programs Overview
BWP’ s strategy for preventing wildfires resulting from its electrical infrastructure includes attention to fire prevention during ongoing operations and maintenance and during planning, design, and construction of new asse t s. The ove rarching goal is t o minimize t he risk of BW P facilit ie s st art ing or cont ribut ing t o the ignit ion of vegetation fires. The BWP fire prevention strategi es and prog rams encompass four primary fire safety categories.
Each of the fire safety categories below have several mitigation measures, many of which have already been implemented. Each of the mitigation measures is discussed in more detail in Section 5 of the WMP. Table 2 is a summary of BWP’ s program and strategies that support wildfire prevention and mitigation.
Table 2 - Overview of mit igat ion act ivit ies
Mitigat ion act ivit ies Descript ion Timing*
Design and construction
1 Deteri orated pole
repl acements
Replacement of poles that do not pass condition -based assessments to prevent pole failure.
B
2 Pole loading assessments &
re me diat ion
Structural assessment of poles to identify potential loading issues during high wind events. Replacement of poles that do not pass GO 95 wind loading de sign crit e ria t o minimize t he risk of pole failure .
A
3 Overloaded transformer
repl acements
Replacement of overhead transformers that do not meet loading criteria to prevent transformer fa ilure .
B
4 Dist ribut ion construction
standards improvements
Engineering study of distribution construction standard improvements, which could provide additional risk reduction in the Tier 2 HFTD. Analysis will be ongoing as new techno l ogi es come to market and best practi ces are refi ned.
B
5 Conventional fuse
repl acements
Replacement of conventional fuses with CAL FI RE “ Exempt” non -e xpulsive fuses in the Tier 2 HFTD. These fuses do not emit sparks during normal operation and reduce the risk of wildfire ignitions from fuse operations.
A
6 Covered Conductor /
Conductor replacement
Inst allat ion of covered conductor in the highest risk areas in t he Tie r 2 HFTD significantly reduces the chance of contact with foreign objects.
Re placing old bare copper significantly reduces the risk of wire -down events .
B
Burbank Water and Power - W ildfire Mit igat ion Plan Page | 15 Mitigat ion act ivit ies Descript ion Timing*
7 Falling conductor protection
Detecti on of a broken conductor causing a wire to fall down onto the ground, or “ wires down” , which would aut omat ically de -energi ze a power line before the l i ve wire hits the ground , t he re by e liminat ing a pot e nt ial ignit ion.
P
Inspection and m aintenance
8 Annual pat rol inspection ( GO
165)
Annual system patrol to inspect the condition of electrical assets to avoid faults, which could cause ignitions. A
9 V egetati on management
program
Annual ve ge t at ion maint e nance and cle arance from e le ct rical line s t o avoid vegetati on contact in Ti er 2 HFTD A
10 Intrusive pole inspections
Condition based assessment of remaining pole strength to identify pole s at risk of failure A
11 Infrared inspections
Annual infrared patrol inspections allow for e arly de t e ct ion of system defects or loading issues B
Operational pract ices
12 Block re closing and i ncrease
re lay se nsit ivit y during RFW
Block re closing and incre ase re lay se nsit ivit y on all fe e de r line s in t he Tie r 2 HFTD during RFW events A
13 Lin e patrol after outage
event during RFW
Pat rol wit h physical inspe ct ion of tripped feeder l i nes i n Ti er 2 HFTD during RFW before re -e ne rgizing circuit A
14 Ignit ion potential work
pract ice s during RFW
Except during an emergency, disallow work that may potentially produce an ignit ion source on all fe e de r line s in t he Tie r 2 HFTD during RFW events A Sit uat ional/ condit ional awareness
15 Weather/ fire monit oring
Conduct we at he r and fire monit oring via publicly available we at he r resources to monitor weather forecast and any potential extreme fire conditions
A
16 Geographic information
syst e m (GIS) applicat ions
Implementation of Outage Management System ( OMS) , which uses GIS data and meter information to help BWP locate outages and decrease response time
A
17 Enhanced system monit oring
Imple me nt a pilot program of pole mounted sensor packages to detect fault s and anomalie s in re al t ime . Se e Se ct ion 5.4.3. B *A – Mit igat ion act ivit y already implement ed , B – Ongoing mit igat ion act ivit y
Burbank Water and Power - W ildfire Mit igat ion Plan Page | 16 Chapter 4. Risk Analysis and Risk Drivers
4.1 Risk Analysis Methods
During t he developme nt of it s W ildfire Mit igat ion Plan in 2019, BWP retained a consultant (Dudek) to perform a fire risk assessment of its electrical system and equipment utilizing the following approaches:
• Risk bowt ie analysis . Risk evaluat ion method to analyze all potential causes of a BWP-caused wildfire as well as the potential impacts of such an event.
• Sit e fire environment assessment . Assessment of natural and landscape environments around BWP facilit ie s to determine the presence of potential threats or conditions that could become a BWP-caused wildfire threat.
• Electrical equipment assessment . Inventory of all BWP electrical assets wit hin the Tier 2 HFTD and analysis of hist orical out age information.
4.1.1 Hazard vs. r isk discussion
The de finit ion of a BW P risk of cat astrophic wildfires (W ildfire Risk) is a wildfire e ve nt itself t hat is caused by BWP electrical facilities. However, it is important to distinguish between hazard (which the hazard maps categorize) and risk (which the hazard maps do not quantify). Hazard is a property of the potential fire environment or wildfire behavior for a given area (such as flame length, crown fire occurrence, and capacity to generate embers) . A wi l dfire risk, however, relates to potential risk drivers (o r tri ggers) that i ndi cate i f a ri sk event could occur, and do not reflect actual conditions or threatened conditions. Thus, even if there is potential high fire hazard in a given area (with expected hi gh fl ame l engths, and aggressi ve wi l dfi re) , there may be a l ow ri sk of i gni ti on from BW P e le ct rical facilit ie s.
4.2 W ildfire Risk Bowt ie Analysis
The risk of a vegetation ignition and potential for an uncontrollable wildfire caused by BWP electrical facilities is related to the type of vegetation (fuel bed) within its vicinity, the local/ regional weather patterns, and the pot e nt ial for a failure of BWP’ s equipment. For example, areas that include uninterrupted, natural ( unmaintained) vegetation present a risk of ignition from ongoing operational activities or equipment failures. When the area also includes weather conditions that result in periodic high wind and low humidit y, t he wildfire risk is significant ly enhanced. Both of these weather conditions can occur in BWP’ s Tier 2 HFTD area. A bow tie analysis was conducted to identify these risk drivers as well as their potential resulting impacts. Figu re 3 provides the risk bow tie diagram, which summarizes the assessment process.
Burbank Water and Power - W ildfire Mit igat ion Plan Page | 17
Figure 3 - BW P's wildfire risk bowt ie
Key risk drivers Triggering event Key ris k impacts
Ele ct rical equipment failure :
• Conductor
• Crossarm
• Insulator
Se rious injurie s or fat alit ie s
• Splice /clamp/ connector
• Transformer
• Pole
Conventional fuse operation:
• Transformer f use
• L ateral fuse Ignition from BWP assets
that causes a wildfire
Prolonged electrical
outage for customers
Wire contact with foreign obje ct (s):
• Mylar balloons
• Animals
W ire contact with vegetation:
• Tree branch Damage and loss of BWP assets
• Palm frond
Extreme weather conditions:
• Climat e change
• High temperatures Claims from damaged property
• Extreme wind
• Lo w humidit y
Burbank Water and Power - W ildfire Mit igat ion Plan Page | 18
4.2.1 Pot ent ial risk drivers
Risk drivers are important t o ide nt ify because t hey are t he primary ways in which BW P ele ctrical facilit ies could result in a catastrophic wildfire. The center of the bow tie chart is the triggering event, which is an ignition caused by a BWP asset resul ti ng i n a catastrophi c wi l dfi re. Duri ng the wi l dfi re threat assessment, fi ve categori es were identified as potential drivers for causing fire ignit ions:
1. Ele ctrical equipme nt failure
2. Conventional fuse operation
3. W ire contact wit h fore ign object( s)
4. Wi re contact wi th vegetati on
5. Extreme weather conditions
It should be noted that the listed potential risk drivers are just an indication that a risk event could occur from a BW P asse t , but act ual condit ions may differ. This t ype of analysis he lps ide nt ify t he t ypes of mit igat ions ne cessary t o minimize t he risk of wildfire .
BWP’ s risk driver analysis identified and studied the fi ve categories of drivers:
4.2.1.1 Ele ct rical equipment failure
Electrical equipment failure is an inherent risk. Failure can occur for a variety of reasons such as manufacturer defects, loading conditions, or deterioration. Failure of electrical components, such as poles, crossarms, conductor, insulators, splices, connectors, or guy wires can result in a downed conductor (or “ wire down” ) situation, which could lead to fire ignition. Electrical equipment such as transformers, voltage regulators, or capacitor banks can have internal shorts that can potentially be destructive and eject materials which could lead to fire ignition.
4.2.1.2 Conventional fuse operat ion
Fuses are devices that protect electrical lines and equipment during fault or overload condit ions. Hist orically, BWP, as well as most of the electric industry, standardized on conventional type fuses to protect their system.
During overload or fault conditions, a conventional fuse will operate and can expel hot particles and gases, which cou ld ignite nearby vegetation.
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4.2.1.3 W ire contact wi th a f oreign ob je ct (s)
BWP constructs its overhead electrical lines in alignment with industry standards by installing bare wires spanned on top of insulators on wooden poles. These lines are constructed at a ce rtain height above the ground and a certain distance from adjacent objects based on appropriate design criteria to prevent contact and faults.
Unfortunately, foreign objects such as animals and mylar balloons can still occasionally come into contact with overhead e le ctrical line s.
Animals and mylar balloons are highly conductive and could result in a fault when contact is made with overhead el ectri c l i nes. Protecti ve devi ces such as rel ays, ci rcui t breakers, and fuses are set up to protect and i sol ate thes e types of situations . However, there is a time delay between the protective devices sensing the fault and operating to isolate the fault. Although this time delay is nearly instant (within fractions of a second) , there is still enough time to cause an emi ssion of sparks, molten metal, or burnt foreign objects, which could lead to a fire ignition. In a worst -case scenario, this could also cause the conductor to fail and land in an energized mode, causing a fire ignit ion.
Vehicles, that come in contact with an electrical pole or supporting guy wires can damage or break the pole. This could cause energized wires to break and fall to the ground igniting vegetation.
4.2.1.4 W ire contact wi th vegetation
Vegetation such as tree branches or palm fronds also pose a risk of coming into contact with overhead electrical lines. This contact can cause sparks and arcs, and in some cases can cause the vegetation to ignite into flames and drop to the ground. Vegetation contact could also lead to conductor failure, which coul d cause a fire ignit ion. In addition, trees that are near BWP’ s electrical lines could possibly uproot and fall onto an energized conductor, causing pole failures or wire down events that could cause fire ignition.
4.2.1.5 E xtreme weather condit ions
Climate cha nge , along wit h ext re me weat her condit ions, contribute to the risk of wildfires. Higher air temperatures and lower humidity cause trees and vegetation to dry out and create conditions that are ripe for fire ignit ion and expansion. Addit ionally, extreme winds can increase tree failure s, vegetati on contact wit h overhead e le ctrical line s, and failure of BW P asse ts such as pole s and conductors .
4.2.2 Ke y Risk Impacts
If one of t he risk drive rs list ed above were t o occur, re sult ing in a wildfire ignit ion caused by BWP electrical faci l i ti es, there coul d be potenti al consequences for BWP as presented on Fi gure 3.
Burbank Water and Power - W ildfire Mit igat ion Plan Page | 20 The worst -case scenarios could include:
• Se rious injuries or fatalit ie s
• Prolonged electrical outage for customers
• Damage and loss of BWP assets
• Claims from damaged property
BWP is fully aware of the impact s that wildfire s can have on the publicly owned ut ilit y, Bu r b a n k ’s populace, and local economy. As discussed in Se ct ion 5 of the WMP, BWP has e stablished programs and i mpl emented wildfire prevention strategi es to create barriers or methods of reducing the like lihood of the risk drive r events ide nt ifie d above from occurring and possibly leading to a catastrophic wildfire .
4.3 Sit e Fire Environment Assessment of BW P ’s Electric Service Territory
Due to its weather, topography, and native vegetation, the entire southern California area is at risk from wildland fire s. The t hre at of wildfire exist s t hroughout t his region, including BW P’ s servi ce terri tory. Thi s threat i s attributable to a variety of factors including extended drought, which has resulted in vulnerable vegetation for longer periods; climate change which may be driving the drought and vegetation drying; and population growt h into the fire -prone areas, which results in the potential for increased ignitions and higher threat based on private and public assets that may be exposed to wildfires.
An assessment was made of the surrounding terrain, vegetative fuels, regional weathe r patterns, and regional fire history for the HFTD areas within BWP’ s service territory. The factors evaluated were:
1. Fire risks: all acti vi ty periods (operation, maintenance, new project design, construction, mat erials, and methods)
2. Sit e and facilit y ignit ion sources: equipment, personnel, processes
3. Fire prevent ion strat egies: design, maintenance, inspections, monitoring
4. Best management practices for hardening of electrical system
5. Fire agency coordination: Fire fight ing and emergency response technical evaluat ion, t raining, and coordination
4.3.1 High Fire Threat Dist rict
BW P dire ct ly part icipat ed in t he de ve lopme nt of the California Public Ut ilit ie s Commission’ s (CPUC) Fire- Threat Burbank Water and Power - W ildfire Mit igat ion Plan Page | 21 Figure 4 - BW P's Tier 2 High Fire Threat Dist rict
Map which designates h igh-fire threat district s ( HFTDs) throughout the State of California. The CPUC Fire - Threat boundary map ranks HFTDs based on the need to increase infrastructure resiliency to mitigate the wildfire threat posed by electric infrastructure. The CPUC Fire -Threat Map is comprised of T ier 2 HFTDs ( elevated risk of potential impacts to people and property) and Tier 3 HFTDs ( extreme risk of potential impacts to people and property).
Burbank Water and Power - W ildfire Mit igat ion Plan Page | 22 In the map development process, BWP served as a territory lead and worked with local fire & government officials to identify the areas of BWP’ s service territory that are Tier 2 or Tier 3 HFTDs. It was determined through the development process and affirmed by both a peer review and a team of independent nationwide experts led by the California Department of Forestry and Fire Protection (CAL FIRE), that a portion of BWP’ s service territory is situated within a Tier 2 HFTD. Additionally, no portion of BWP’ s ser vice t errit ory falls wit hin a Tier 3 HFTD.
For a summary of informat ion re garding BW P’s service te rrit ory in t he Tie r 2 HFTD, please re fe r t o Exhibit A, Context -Setting Information Table.
It is BWPs understanding that CAL FIRE will be deve loping a re vise d HFTD boundary will like ly cause the boundary to be extended . This would mean that a future HFTD boundary would include addit ional urban BW P Ele ctric assets , especially in the northern portion of the city . A pre liminary revie w of e le ctric asse ts in t his area shows they are all urban , wit h t he majorit y ove r irrigat ed landscaping. The risk of the existing HFTD as adopted remains a priorit y and t he primary focus for mit igat ion. If a revised HFTD map is adopted BWP will provide an update in a future WMP .
4.3.2 W ildfire-Threat Area Sit e Evaluat ion
BWP staff provided Wildfire SME ( Dudek) with a guided tour on May 9, 2019, of t he e lect ric distribut ion syst em wit hin Tie r 2 HFTD area. The wildfire e xpert s evaluat ed e xist ing site condit ions (e.g., topography, vegetation, and fuel loading) and whether or not there is the presence of potential risk drivers or conditions that could become a BWP-caused wildfire threat. Based on Dudek’ s field assessment and BWP staff interviews, the following observations were recorded for the distribution system in the Tier 2 HFTD area.
Fire environment observations
1. Most of the Tier 2 HFTD Are as are hilly or mountainous and steeper slope s exacerbate fire spreading, which also impedes fire suppression efforts. In worst -case scenarios, fires on the steep slopes of the Verdugo Mountains could burn well into the heavily developed areas of Burbank.
2. W ildland fires are relat ively common in t he Verdugo Mountains and have historically burned into the wildland -urban interface or Tier 2 HFTD areas of Burbank. The most recent fire, L a Tuna fire ( 2017) , consumed large portions of the south face of the Verdugo range wit hin t he Cit y limit s. The La Tuna fire significant ly changed the fuel beds from chaparral -shrubby spe cies to non- nat ive grasses and other weedy species, especially north to northwest of overhead feeder line T-14.
3. Fue ls in Sunset Canyon, off of Country Club Drive , re main dense and pose a threat to the residents.
Defensible space has been provided around some of the residences along Country Club Drive.
4. The level of fire hazard in wildfire -threat Tier 2 HFTD areas prone to wildland fire s is also great ly increased during periods when weather conditions of high temperatures, low humidity, and high winds ( e.g., RFW days) would accelerate the spread of a wildland fire and make containme nt difficult . “90% of t he land are a burned in California occurs during wil dfires that ignite on the 10% of days that meet Re d Flag Warning conditions while 10% of the land area burns occurs during the 90% of fires that occur during typical weather Burbank Water and Power - W ildfire Mit igat ion Plan Page | 23 conditions.”
5. BW P ’s Tie r 2 HFTD area includes brush and grass -covered areas of significant topographic relie f in the Verdugo Mountain range that is susceptible to wildland fires. The most recent wildfire (L a Tuna fire ) in BWP’ s service territory occurred in September 2017.
6. Although large areas of the Verdugo Mountains are undeveloped, there are many single -family reside nt ial neighborhoods that have been developed in the canyons, and at the base or edge of the hillsides, within the Tier 2 HFTD area. In these areas, the wildfire hazard is of significant concern. This is espec ially true for those older residential areas in the canyons that were built in the 1960’ s to 1980’ s before current ignition resist ant fire and building codes.
7. Some of the older residential areas are typically reached by narrow roads that do not meet the current fire safety standards for access and egress of fire apparatus. Many roads in the canyons are also dead -end roads that are too long, do not have appropriate turnarounds at their end, and have no secondary access. Of the roads not meeting dead- end road standards, Count ry Club Drive poses by far the most serious concern regarding acce ssibilit y, as t his is the only way out during a wildfire for the residents on t his street.
Figure 5 - Hist orical Fires in Burbank
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4.3.3 Evaluat ion of Higher Fire-Threat Areas
A component of this WMP is the evaluation of the area’ s fire threat to determine whether it is accurately classified. Based on wildfire threat analysis conducted, there was no just ification for increasing t he Tier fire t hreat level beyond its current Tier 2 designation. BWP will continue to evaluate changes to the Tier 2 HFTD in future WMPs based upon new information that is obtained during the implementation and evaluation of B WP’ s WMP.
4.4 Elect rical Facilit y Assessment
Figure 6 presents the portion of BWP’ s service territory (e.g., feeder lines and equipment) within CPUC fire - t hreat are as. As illustrated in Figure 6, BW P’s ele ct rical syst em is locate d wit hin bot h Tie r 2 HFTDs, and areas not considered within the HFTD (referred to as outside HFTD in this WMP). Table 3 includes the breakdown of BW P’s e lect ric syst em t hat falls wit hin t he Tier 2 HFTD. The facility counts presented in this section are updated on a three year cycle coinciding with comprehensive revisions and independent evaluations.
Table 3 - Breakdown of BWP's E le ct rical Assets Within the Tier 2 HFTD BWP asset Tot al assets in e nt ire system Tot al assets within Tier 2 HFTD Percent of t otal Overhead dist ribut ion wire 204 mile s 11 mile s 5.4%
Underground distribution
line s 132 mile s 14 mile s 10. 6%
Pole s 10,741 641 6.0%
Overhead
transformers 4,6 48 192 4.1 %
Overhead conventional
transformer fuses 4,6 12 156 3.3%
Overhead conventional
lateral and rise r fuses 2,060 72 1 3.5 %
Overhead non -e xpulsive
transformer fuses 36 36 100%
Overhead non -e xpulsive
lat e ral and rise r fuse s 2 2 100%
As shown in Table 3, approximat ely five percent of BW P ’s total 204 mile s of overhead wire s are locate d wit hin the Tier 2 HFTD area. In comparison, approximately 11 percent of the total underground lines occur wit hin the Tier 2 HFTD area.
See section 5.1.5 for update on conventional fuse replacement wit h non-expulsive fuses.
1 This number was updated in 2023 due to an updated inventory that captured some additional 3- phase fuse banks that were counted as 1 fuse unit
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Table 4 provides a detailed inventory of BWP assets within Tier 2 HFTD area organized by distribution feeder circuit. A s indicated, there is a total of approximately 25 mile s of dist ribut ion line s in Tie r 2 HFTD, wit h 14 mile s underground lines and 11 miles overhead wire. The overhead wire and related components are the focus of this WMP as they represent the primary source of potential wildfire ignitions. Approximately 56 percent of BWP - owne d ele ct rical lines in the Tier 2 HFTD area are currently underground, which significantly reduces the threat of fire ignit ion.
Figure 6 - Ele ct rical Facilit ies wit hin the Tier 2 HFTD Burbank Water and Power - W ildfire Mit igat ion Plan Page | 26
Table 4 - Inventory of BWP Assets in the Tier 2 HFTD by C ircuit Ele ct ric
"feeder" 1
Volt age
(kV)
No. of
miles
UG line s
No. of
miles
OH lines
No. of
poles
No. of
OH
transformers
No. of
OH
conventional
transformer
fuses 2
No. of
conventional
lateral fuses 2
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 10 10 7
M-13 4.16 4.58 0.8 48 11 11 4
M-15 4.16 0.0 0.46 25 9 9 0
T-10 4.16 1.2 2.3 167 54 54 12
T-14 4.16 1.54 1.53 83 25 25 3
T-19 4.16 1.0 2.91 134 37 37 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 11.06 641 192 192 45
—
1 Feeder l i nes are identified by the substation within their circuit. W= Winona Substation; M=McCambridge Substation; and T= Town Substation.
2 The fuse counts for T-14 and T -19 have not been reduced for the non -expulsive fuses installed on these feeders, an exact accounting of non -e xpulsive fuse deployment s by feeder will be provided once the deployment has been completed.
BWP analyzed outage records for energized circuits within wildfire -threat areas. The analysis focused on recent outage data between January 2005 and December 2022 that was obtained from BWP. These records provide documentation about the frequency and cause of outages and represent the most accurate depiction of how oft e n pote nt ial ignit ions may occur wit hin BW P’s Tier 2 HFTD . The elect rical equipme nt r isk assessment examined five categories: equipment failure, foreign object contact, vegetation contact, wire down events, and other or unspecified events. Table 5 presents the results of the analysis.
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Table 5 - Ele ct rical Equipment Risk Drivers Based on Hist orical Events W ildfire risk
event
Number of occurrences (by circuit )
M-5 M-8 M-11 M-13 M-15 T-10 T-14 T-19 T-21 W- 11 Count Percent Equipment failure
Transformer failure 1 1 1 3 5%
Conductor failure
(wire s down)
3 2 8 1
14 22%
Total 17 26%
Conventional fuse operation
Transformer fuse 1 3 1 1 4 4 1 3 18 28%
L ateral fuse 2 1 3 3 9 14%
Total 27 42%
W ire contact with foreign ob je ct (s)
W ire contact -
mylar balloons
1 4 1
6 9%
Total 6 9%
W ire contact with vegetation
W ire contact -
vegetati on 1
2 1 2 4
10 15%
Total 10 15%
Other
Other 1 1 1 1 1 5 8%
Total 5 8%
Tot al events per
feeder line
7 6 2 4 6 8 5 21 2 4 65
—
Source: BWP outage data between 1/1/2005 and 12/31/2022 , percentages are rounded
Burbank Water and Power - W ildfire Mit igat ion Plan Page | 28 The risk event frequency for the Tie r 2 HFTD area was determined to be 65 events over 18 years for 25 circuit mile s of distribution line, with a driver frequency as follows:
• Equipment failure (27%, 17 pot ent ial ignit ions). Failure of transformers and overhead copper conductor wire down events that could have resulted in fire ignit ion. • Conventional fuse operation (42%, 27 potential ignit ions). Operation of a transformer or lat e ral fuse for a faulted condition that resulted in sparks that could have led to fire ignit ion. • W ire contact with foreign ob je ct (s) (9%, 6 potential ignitions): Mylar balloons or ve hicles that could contact with conductors, resulting in ignit ion.
• W ire contact wit h veget at ion (16%, 10 potential ignit ions): Tree, tree limb, palm fronds or other vegetation contact with conductors that could result in ignit ion. • Other (8%, 5 potential ignit ion): Sit uat ions where BWP was unable to det e rmine the cause and locat ion of the outage . These outages are included because it is unknown whether these outages occurred on a portion of the circuit in the Tier 2 HFTD BWP has verified that these outages were not caused by an overload condition and suspects that t hese outages are l i kel y caused by a temporary or instantaneous wire contact with a foreign object or vegetation that has vaporized or was not discovered during a patrol of the overhead distribution line after the outage.
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4.5 Priorit izat ion of Wildfire Risks
Based on the findings of this risk assessment, Sunset Canyon (the upper road segment of Country Club Drive) pose s t he great est risk of wildfire wit hin Burbank’s Tier 2 HFTD. This is due t o t he cont inuit y of ve ge t at ion within the canyon and density of tree canopies surrounding the residential homes.
Prioritization of the Tier 2 HFTD mitigation efforts is broken down into three sub -categories as follows: Priority level 2.1 – Tie r 2 HFTD wit h dense ve ge t at ion adjace nt to overhe ad ele ct rical facilit ie s Priority level 2.2 – Tier 2 HFTD wit h low de nsit y vegetation underneath overhead electrical facilities
Priority level 2.3 – Tier 2 HFTD wit h no overhe ad e le ctrical facilit ie s
Risk Modeling for Priorit izat ion and Tracking
Alt hough commercial risk mode ling t ools have become commonplace for ut ilit ie s wit h significant assets in HFTD areas using AI t o cate gorize risk , BW Ps limited asse t quant it ie s made t hese comme rcial t ools le ss viable . Inst e ad, BWP developed an internal risk mode l, and in 2022 and 2023 created a de t aile d risk inve nt ory of all poles in t he HFTD. This model took into account weighted risk scores for pole type , locat ion, vegetati on, fi re access, as well as risk drivers on the pole . Using the model as a baseline re -confirmed BWPs prior assessment that the 2.1 priority Figure 7 - W ildfire Risk Priorit izat ion Within the Tier 2 HFTD Priorit y 2.1
Priorit y 2.2
Priorit y 2.3
Burbank Water and Power - W ildfire Mit igat ion Plan Page | 30 are a re mains t he highe st priorit y, with an average risk around 40% higher than the BWP HFTD average . As more mit igat ion measures are implemented, BWP expect s to see a corresponding reduction in risk in the mitigated areas and will continue to track this with the internal model .
4.6 Mit igat ion Activities That Address Risk Drivers
Table 6 be low summarizes each mit igat ion act ivit y along wit h risk drive r t hat it addresse s. Table 2 provides an overview and Se ct ion 5 goes int o more de tail for e ach mit igat ion act ivity.
Table 6 - Mit igat ion act ivit ies t hat address risk drivers
Mitigat ion acti vi ty
Risk driver
addressed
Ele ct rical
equipment
failure
Conventional
fuse operation
W ire contact wi th
fore ign obje ct
W ire contact
wit h vegetati on
1 Deteri orated pole repl acements X X X
2 Pole loading assessments &
Re me diat ion
X
X X
3 Overloaded transformer
Repl acements
X X
4 Dist ribut ion construction
standards improvements
X X X
5 Conventional fuse replacements
X
6 Covered Conductor / Conductor
repl acement X X X
7 Falling conduct or protection X X X
8 Annual pat rol inspection ( GO 165) X X X
9 V egetati on management program X X
10 Intrusive pole inspections X X X
11 Infrared inspections X
12 Block re closing and increase re lay
se nsit ivit y during RFW
X X X
13 Lin e patrol after outage event
during RFW
X X X X
14 Ignit ion potential work pract ice s during
RFW
X X X
4.7 Review of Risk Drivers and Analysis
BW P works wit h PO U associat ions t o discuss unide nt ifie d wildfire risk drivers and mit igat ion measure s t hat Burbank Water and Power - W ildfire Mit igat ion Plan Page | 31 could address these risks. BWP participates in ongoing industry discussions regarding wildfire risks and responses to evaluate potential opportunities for improvement. BWP also continuously works with industry suppliers to identify and review new solutions to improve grid hardening and monitoring, new solutions that may improve BWP’ s system and monitoring are piloted as discussed in section 5.1.
In 2023 BWP performed a comprehensive review of Chapter 4 – Risk analysis and risk drive rs as part of the comprehensive 3 -year WMP update . This re view in cluded updates , as warranted , t o facilit y asse ssme nt and counts , priorit izat ion, risk cat egorizat ion and tracking, and mitigation activities. BWP also coordinated with the Burbank Fire Department for a revi ew of the wildfire -t hreat are a site e valuat ion and no significant changes in t he are a sit e evaluat ion were i denti fi ed. BWP will continue to monitor and r espond to changing risks as they are ide nt ified. This section will continue to be updated on a three -year cycle coinciding with comprehensive revisions and independent evaluations.
Burbank Water and Power - W ildfire Mit igat ion Plan Page | 32 Chapter 5. W ildfire Preventi on Strategies And
Programs
This sect ion de scribe s the strategies and programs BWP has i mpl emented to mit igate the threat of e le ct rical infrastructure -related wildfire s wit hin Tie r 2 HFTD area of it s service territory. As previously mentioned, the prevention strategies and programs are developed to address four primary fire safety categori es:
1. Facilit y de sign and construction
2. Inspection and maintenance
3. Operational pract ice s
4. Sit uat ional/ condit ion awareness
5.1 Facilit y Design and Construction
5.1.1 Deteriorated Pole Repl acements
Because pole failure could result in a wire s -down e ve nt and pote nt ial fire ignit ion, it is imperat ive t o replace any poles that do not pass condition -based assessments. BWP prioritizes and schedules the replacement of deteri orated poles based on data obtained from intrusive pole inspections. Each year, all priority 1 and 2.1 poles are replaced per the timelines in Table 9 of Section 5.2.3.
Since 2018, BWP has replaced 5 1 deteriorated poles in our Tier 2 HFTD area, which is about 8% of the poles in our Tier 2 HFTD . In 2022 , BWP did not have any priority 1 or 2.1 poles that required replacement. One priorit y
2.2 pole was repl aced in 2022.
As described further in Section 5.1.4 , BWP will continue replacing addit ional pole s wit h composit e poles in the Priority 2.1 area of its Tier 2 HFTD where the benefits of a composite pole ( I .e., increased strength , fire resist ance , and e ase of inst allat ion in difficult t errain) are deemed appropriat e by BW P.
5.1.2 Pole L oading Assessments & Remediation
Wind L oading is also an important factor in the prevention of pole failure. BWP designs pol es to meet or exceed the wind loading criteria set in General Order 95 ( GO 95) in order to minimize the chance of pole failure during heavy winds. BWP w ill perform t his loading analysis on all of t he poles located wit hin t he Tie r 2 HFTD. Any pole s that do not pass the wind loading criteria are scheduled for replacement. I n some cases, poles may only require additional guying reinforcement to meet wind loa ding criteria.
Burbank Water and Power - W ildfire Mit igat ion Plan Page | 33 By the end of 2020, BWP completed pole loading analysis of all pole s inside BW P’s Priorit y 2.1 Zone (se e Figure 7) having dense vegetati on near overhead faci l i ti es. BW P will cont inue to pe rform pole loading analysis on all poles requiring replacement , during the design phase of each replacement.
5.1.3 Overl oaded Transformer Replacements
Distribution transformers are another identified risk because failure could lead to the expulsion of sparks or mat e rial t hat could cause a fire ignition. Ensuring that transformers are not excessively loaded past their capacity can help mitigate failures due to internal faults. Each year BWP uses advanced data analytics to measure the loading levels of e very transformer in t he e lect ric syste m. Any transformers that exceed the loading criteria of 175% are schedul ed for repl acement.
Excessive transformer loading can also lead to transformer fuse operations occurring during high- heat days. If t he transformer is fused with a conventional fuse, fuse o peration could expel sparks that could lead to fire ignition.
As discussed in section 5.1.5, all conventional transformer fuses will be replaced with CAL FIRE “ Exempt” fuses by June 2024. W hile t his will e liminate pot e nt ial ignit ion eve nts from convent ional transformer fuse operations, excessive transformer loading will still have an ignition risk from transformer equipment failure. Therefore, in the Ti er 2 HFTD, BWP uses a more conservati ve l oadi ng cri teri a of 150% as a threshol d for proact ive transformer repl acement.
In 2022 , no transformers in the Tier 2 HFTD exceeded the 150% loading threshold. T here were no transformer failure s in t he Tie r 2 HFTD. In t he near-term supply chain constraints may limit BWPs ability to perform proactive replaceme nt s, but BW P will cont inue to priorit ize t he HFTD mit igat ion whe re fe asible.
5.1.4 Dist ribut ion Construction Standard Improve me nt s
As an ongoing fire prevention strategy , BW P will continuously evaluate distribution construction standard improvements that could reduce the risk of ignitions and harden its electric system in the Tier 2 HFTD. This will include components of the electri c system such as fuses, overhead conductors , and detection & isolat ion technology. Each el ectri cal facilit y locat ion wit hin the Tier 2 HFTD will be analyzed to determi ne where material upgrades or the inst allat ion of new technology would be appropriate, as some locations may not have vegetation present. Ongoing evaluation is necessary to study and implement new technologies and new developments in industry best practices.
BW P has comple ted some preliminary e ffort s toward its engineering study of distribution construction standard improvements , including t he following:
• Fi el d recl osers: BWP completed an init ial evaluat ion of fie ld recloser technology in fiscal year 2021/ 2022.
This evaluation analyzed the use of field reclosers in conjunction with falling conductor detection to allow for added isolation, reduced customer impact, and increased sensitivity settings. BWP determined that other mitigation activities could have a hig he r risk reduct ion -to -cost rat io. W hile BWP expected to make a final de t erminat ion regarding fie ld re close rs in the fiscal year 2022/2023, this final determination was postponed in order to consider the implementation of a new falling conductor technology i n lieu of or conjunction with a fie ld re close r .
Burbank Water and Power - W ildfire Mit igat ion Plan Page | 34 • Falling conduct or protection : Based on it s init ial re vie w of falling conduct or protection during t he fiscal year 2022/ 2023, BWP has decided to implement a pilot project with falling conductor protection on the Town -14 overhead circuit in the HFTD during the fiscal ye ar 2025 /2026. Pe rforming t his pilot project in 2025/2026 will allow BWP sufficie nt t ime to perform it s final evaluat ion of falling conductor technolog ies and to obtain the necessary budget approval s. Inst allat ion of falling conduct or prote ct ion would allow BWP to detect a broken conductor and automatically de -energi ze a power line before th e live wire hit s the ground, thereby e liminat ing a pot e nt ial ignit ion. • C omposite poles : BW P inst alle d two modular composite poles in the Tier 2 HFTD as a pilot project in 2019. These poles, which are manufactured by Highland Composites, are constructed in 3 modular sections, which allow the field crews to assemble the pole in place. Many poles in the Tier 2 HFTD are very difficult t o access during replaceme nt due t o t he exist ing hillside t errain. This modularit y allows for a significant gain in cre w e fficie ncy and safe t y during construct ion. Addit ional be ne fit s of composite pole s include increased strength, greater fire resistance, greater longevity, and a reduction in maintenanc e and inspection costs. The pilot was successful; however, Highland Composite ceased composite pole production. La t e r in the fiscal year 2021/2022, BWP completed an additional pilot of 5 composite pole inst allat ions in t he fiscal year 2021/2022 using a di f ferent manufacturer – RS Poles. After this pilot, BWP has made a final determination to continue replacing poles wit h composite poles in t he Priorit y 2.1 are a of it s Tier 2 HFTD , where the benefi ts of a composi te pol e ( I .e., i ncreased strength , fire resist ance, and e ase of installat ion in difficult terrain) are dee me d appropriate by BW P. • R
eplacement of #6 bare copper conductor in the Tier 2 HFTD : Afte r an analysis of outage events in the Tier 2 HFTD, BWP has found that #6 bare copper conductor has been present in all “ wires down” events.
For new construction, BWP uses #2 aluminum conductor steel reinforced (ACSR) as a standard for local circuit segme nt s that branch off from a main backbone. The increased strength gained from this steel rei nforcement hel p reduce “ wi res down” events i n the Ti er 2 HFTD . BWP also evaluated the use of ACSR covered conductor as a replacement option . The covered conductor has a layer of insulat ion around t he main high -strength ACSR conductor. This insulation would prevent outages (and risk driver events) from wire -to -wire contact and wire contact with foreign objects or vegetation. BWP comple ted a full analysis of covered conduc tor options and has selected a specific vendor product for it s covered conductor standard . As funding and resources allow , BWP intends to deploy this covered conductor in the HFTD to repl ace deteriorated wire where appropriate .
• No
n -oil fille d pole mounted transformers : BWP is pilot ing the installation of non- oil filled pole mounted transformers as a fire risk reduction strategy . Once the pilot is complete a decision on the use of non -oil filled transformers in t he Tie r 2 HFTD will be made. An init ial pilot inst allat ion of 3 dry -type overhead transformers was completed in 2023, with evaluation of the technology ongoing . • P ole mounted sensor packages : I n 2022 BWP inst alled a pilot of pole mounted sensor packages on 50 poles on T- 14 circuit in t he Tier 2 HFTD to detect distribution grid faults and continuously monitor equipment degradation or anomalies . The pilot was successful and i ni ti al access to the devi ces was gi ven t o t he e ne rgy control cent e r t o increase visibilit y int o distribut ion as sets. Furt her device inst allat ions are planned to cover all BWP poles wit h risk driver facilit ie s at t ache d in t he HFTD.
5.1.5 Conventional Fuse Repl acements
Burbank Water and Power - W ildfire Mit igat ion Plan Page | 35 Conventional fuses are used in the electric system to protect transformers and wires from damage during fault conditions. These conventional fuses are expulsive in nature and may generate electrical arcs, sparks or hot mate rial during normal operat ion. Conventional fuse operations account for 47% of BWP’ s risk driver events. To further reduce the risk of wildfire, BWP has created a program to replace all conventional fuses in the Tier 2 HFTD with CAL FIRE “ Exempt” fuses as determined in the “ California Power L ine Fire Prevention Field Guide.” These “ Exempt” fuses clear faults faster and reduce t he fault e ne rgy. This minimizes e le ctrical arcs and sparks during fault events and minimizes the impact of a fault on electrical equipment along the circuit.
By June 2022 , BWP planned to replace all conventional fuses with CAL FIRE “ Exempt” fuses in the Priority 2.1 zone of the Tier 2 HFTD. The Priority 2.1 zone contains 36 transformer fuses and 7 lateral fuses. BWP was not able t o complete t his repl acement due to supply chain constraints, and only 38 of the required 43 fuses could be delivered , and all 38 delive red fuses were inst alled . By June 2024, BW P intends to replace the remaining transformer fuses and lateral fuses in the Tier 2 HFTD, although ongoing supply chain constraints continue to pose a risk to completing this on schedule . Despite supply challenges causing delays to these replacements , al l recei ved fuses are deployed to the field as soon as operationally practical .
5.2 Inspection and Maintenance
5.2.1 Annual Pat rol Inspection (GO 165)
In general, BWP performs electrical infrastructure patrol inspections to inspect each component of the electrical system to check that no obvious abnormalities exist to the extent possible. BWP performs these inspections on a cycl e that meets or exceeds the ti meframes gi ven i n Gen eral Order 165 ( GO 165) . During these inspections, proble ms are ide nt ified, priorit ized, and corrected. Table 7 below summarizes the inspection cycles.
Table 7 - Distribution inspection cycles ( maximum interval in years)
Component Patrol Inspection Detailed Inspection Int rusive Inspect ion Overhead Component I nspection 1 5
Padmounted Transformer 1 5
Padmounted Switch 1 5
Padmounted Regulator/ Capacitor 1 5
Component Patrol Inspection Detailed Inspection Int rusive Inspect ion Wood Poles over 15 years old which have
not been subject to intrusive inspection
1 10*
Wood Poles less than 15 years old 1
Wood poles which have passed intrusive
inspe ct ion
1 20
—
Burbank Water and Power - W ildfire Mit igat ion Plan Page | 36 * Within 10 years or prior to 25 years of age
As noted in Table 13 of its Performance Metrics, BWP completed 100% of its annual patrol inspections for pole s within the Tier 2 HFTD this annual cycle. Addit ionally, BW P is impleme nt ing digital inspect ion t ools for tracking and record keeping detailed inspections in the HFTD.
5.2.2 Veget at ion Management Program
BWP meets or exceeds the minimum industry standard vegetation management practices. For all electri cal facilit ie s, BW P mee t s: (1) Public Resource s Code se ct ion 4292; (2) Public Re sources Code se ct ion 4293; (3) GO 95 Rul e 35: and (4) the GO 95 Appendix E Guidelines to Rule 35. These standards require significantly increased clearances in the High Fire Threat District. The recommended time -of-trim guide line s do not e st ablish a mandatory standard, but instead provide useful guidance t o ut ilit ie s. BW P will use spe cific knowledge of growing conditions and tree species to determine the appropriate time of trim clearance in each circumstance.
Tabl e 8 bel ow summari zes BWP’ s vegetati on cl earances.
Table 8 - Vegetation Clearances
Outside Tier 2 HFTD W it hin Tier 2 HFTD
Minimum clearance at all times between 4kV overhead
line s and ve ge t at ion 18 inches 4 feet
At time of trim, minimum trimming clearance between
4kV overhead line s and ve ge t at ion
4 feet 12 feet
BWP performs routine vegetation management, such as pruning and removal, on an annual basis in the Tier 2 HFTD. Each year, field patrols are performed to inspect tree and conductor clearances and to identify any hazard trees. Areas for vegetation pruning and removal are targeted based on the results of these patrols. BWP hires cont ract ed line cle arance tree t rimming cre ws t o trim ve ge t at ion near it s elect rical line s. The tre e crews will t rim a minimum of 12 fee t of clea rance. BWP’ s tree trimming contractors are specialists, supervised by a certified arborist. The tree crews are knowledgeable about work near energized electric lines and about trees, growth rates, and pruning methods that maintain tree health. BWP has review ed and patrolled to verify that the clearances were established by the contract crews with detailed spot checks .
As noted in Table 13 of its p erformance metrics, BWP completed 100% of its vegetation management inspections and trimming for poles within the Tier 2 HFTD this annual cycle . Over the past year, BWP and i ts tree -trimming contractor performed an extensive line clearance work as part of its vegetati on management program as detailed in Table 13 .
5.2.3 Intrusive Pole Inspections
BWP performs intrusive inspections on all poles in the electric system according to the cycle intervals in Table 7.
Burbank Water and Power - W ildfire Mit igat ion Plan Page | 37 The inspections provide information on the amount of rot and decay inside each pole to measure the amount of remaining strength left in the pol e before repl acement i s necessary. E ach pol e i s gi ven a rati ng that determi nes the priority and schedule of replacement. Table 9 summarizes the priority system.
Table 9 - Priorit y L evel of Deteriorated Pol es Based o n Intrusive Inspections
Priorit y level Recommended act ion
1 Immediate repl acement
2.1 Re place wit hin 1 ye ar
2.2 Re place wit hin 3 ye ars
2.3 Re place wit hin 5 ye ars
3 Replace when practical
All intrusive pole inspections were completed for the Tier 2 HFTD by the 2 nd quarter of 2019 and prioritized within the time frames noted above. Of the 3 deteriorate d poles replaced in 2023 , there were 2 priorit y level 1 poles, 1 priorit y leve l 2.1 pole , and zero priorit y leve l 2.2 pole s.
5.3 Operational Practices
5.3.1 Block Reclosing and Increase Relay Sensit ivit y During RFW
BW P has reclosing capabilit ie s on all subst at ion circuit bre akers in t he e le ctrical syst em. 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 st ill exists. The circuit will make two total attempts to re close 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 st ill present. This could pot e nt ially lead to an ignition of vegetati on. For t his reason, BWP enacted an operating procedure to block reclosing capabilities on all circuits in the Tier 2 HFTD during RFW conditions to prevent any pot e nt ial for veget at ion ignit ions. Addit ionally, more se nsit ive, quicker act ing relay set t ings are employe d during RFW conditions to increase the chance of detecting and isolating a fault.
I n 2023 there were 3 RFW eve nts t otaling 3 days. BWP blocked r e closing and enabled more sensi ti ve rel ay settings on RFW alert days for all circuits that extend into the Tie r 2 HFTD .
5.3.2 Line Pat rol After Outage Event During RFW
If a circuit wit hin a Tier 2 HFTD see s a fault during RFW condit ions, field cre ws will pe rform a patrol of t he entire circuit to locate the cause of the fault. The ECC dispatcher will wait for confirmation of the patrol inspection to ensure no fire ignition risks are present when the circuit is re -energi zed.
The following is a summary of the outages that occurred on Tier 2 HFTD circuits during RFW days:
Burbank Water and Power - W ildfire Mit igat ion Plan Page | 38
• No outages occurred during RFW days .
5.3.3 Ignit ion Pot ent ial W ork Pract ices During RFW
BWP enhanced the safety of its work practices associated with Ignition Potential Work ( IPW) within the Tier 2 HFTD during RFW conditions. IPW is any work having the potential to produce an ignition source to are as adjacent to the work location . BW P ’s ECC has issued a procedure to notify BWP construction and maintenance crews when an RFW condition exists.
During the RFW , IPW within the Tier 2 HFTD shall not be performed except in response to an emergency. In addition, emergency IPW in the Tier 2 HFTD shall be performe d wit h st rict adhere nce t o all required safe t y precautions including t he following:
• A pre -job briefing to review the pre -job brie fing form, work plan, and fire safety measures. • Removal, covering, or wetting of all combustible fuels below or adjacent to the work area as much as practical .
• Readily acce ssible fire e xt inguisher wit h a minimum rat ing of 3 -A-40 BC, a 5- gallon bucket of water, sand or clean dirt, and a round point shovel .
• FR rated clothing worn by all involved personnel.
Any ignitions will be immediately extinguished (as possible) by site personnel and shall be monitored and verified as out and cool by crew supervisor or their de signe e , prior t o leaving t he are a. BW P will also not ify t he Burbank Fire Department of any fire , eve n if ext inguishe d . For record keeping purposes, the ECC shall be informed of all ignit ions.
During the current annual cycle , no ignition potential work w as performed within the Tie r 2 HFTD on any RFW days .
5.4 Sit uat ional/ condit ional awareness
5.4.1 Weather / fire monit oring
The National Weather Servi ce may i ssue RFW s at any time when humidity and wind conditions meet pre - determi ned thresholds that would promote fire ignition and spread. BWP’ s electrical system is located within an area of Lo s Angeles County that is actively monitored for fire weather conditions. The Na t ional Weather Service monitors humidity, wind, and temperatures and will declare RFW s and watches ( https:/ /www. weather.gov/ sgx/ ), signaling that fire weather is anticipated. BWP’ s ECC monit ors Nat ional Weather Service warnings and watches and coordinates with other agencies and third par ti es i n the area.
Addit ionally, t he ECC will use the fire -monit oring came ras stationed at the peak of the Verdugo Mountains and on Mount L ee to enhance situational awareness of wildfires on an as -needed basis. These cameras offer a vi ew of the surrounding mount ains, including BW P’s Tier 2 HFTD. The live fe ed is publicly available and can be viewed at the Alert California links below:
Burbank Water and Power - W ildfire Mit igat ion Plan Page | 39 Verdugo Peak 2 camera :
ht t ps:/ / ale rt ca.live / cam-console/2478
Mount L ee North camera:
ht t ps:/ / ale rt ca.live / cam-console/2176
BWP’ s ECC monitored National Weather Service warnings and issued alerts to BWP staff for each of the RFW alert days that occurred i n the current annual cycle .
BW P is aware of and is revie wing t he Wi l dfi re Forecast & Threat I ntel l i gence I ntegrati on Center ( WFT I I C) Products as an addit ional pot e nt ial weather/ fire monitoring tool for the ECC to employ t o pot e nt ially modify ope rat ional pract ice s. At this time no formal decision to implement these additional tools has been made . The Burbank Fire Department also has access to W FTIIC products and is considering the i ntegrati on of these tool s i nto the ci tywi de empl oyee network. T he cit y also uses existing communication channels to disseminate weather hazard information t o cit y employe es.
5.4.2 Geographic Information System (GIS) Applicat ions
BWP has implemented a GIS system as well as GIS -based applications to improve situational awareness of the e le ctrical syst em. Using a fully implemented advanced metering infrastructure (AMI) network, BWP’ s smart meters will detect an outage and send out a fault message, which is picked up by the Outage Management System ( OMS) . The OMS helps ECC operators pinpoint the geographic location of the outage as well as the potential electrical component involved. This allows BWP crews to respond faster to the outage location.
BWP’ s GIS and OMS applications are continually updated on an ongoing basis , allowing BW P cre ws t o respond faster to outage locations.
5.4.3 Enhanced Syst em Monit oring
As discussed in Section 5.1.4, BWP has i mpl emented a pilot project to test new system monitoring devices on 50 poles on the T- 14 circuit within the Tier 2 HFTD. These devices are equipped with several optical, environmental, and mechanical sensors that have the potential to provide high visibility at every pole and span location. When processed, the data collected could provide continuous a sset he alt h informat ion, improve fault locat ion and response time, rapidly detect fire ignitions, and provide more granular weather monitoring. The pilot project was successful , and BWP intends to deploy the devices to all poles within the HFTD as funding and device availabilit y allow.
5.5 Pre -emptive De- energizat ion
A public safety power shutoff (PSPS) is a mitigation method used among several electrical utilities throughout California. This mit igat ion me t hod employs pre -e mpt ive de-energi zati on of el ectri cal lines when predicted extreme weather condi ti ons woul d create too great of a ri sk of a wi l dfi re bei ng i gni ted by el ectri cal faci l i ti es.
BWP has evaluated this approach and has determined that a PSPS is not a necessary mitigation activity for Burbank Water and Power - W ildfire Mit igat ion Plan Page | 40 several reason s:
• BWP’ s compact, urban service territory and accessibility allow 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 out age 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 mi ti gati on acti vi ti es, as described in Sec tion 5 of the WMP , furt he r reduce t he risk of it s facilit ie s ignit ing a wildfire in t he Tie r 2 HFTD
While BWP does not plan to implement a PSPS in its service territory, BWP does have a protocol for de - energizing portions of its electrical system . ECC per sonnel hav e the authority to de -energize portions of the el ectri cal system for safety and re liabilit y or during emergency conditions when requested by the BW P field crews, Burbank Fire Department, Burbank Police Department, CAL FI RE, or other emergency responding agenci es. Depending on the specific si tuati on that tri ggered the de -energi zati on requi rement , de -energization can be triggered remotely by the ECC or in t he fie ld at a distribut ion switch by BW P line cre ws. Current de - energization operational pract ice s cal l for i sol ati ng the smal l est necessary area at a fi el d swi tch to reduce the number of customers impacted by the outage whi le keeping the remainder of the circuit energize d . In the event of a widespread de -e ne rgizat ion during an emergency , the cit y has an existing communication protocol to keep residents informed and would be implemented through the c it y ’s Emergency Operation Center (E OC) to notify affected customers a s discussed further in Chapter 6. Addit ionally, BW P plans t o impleme nt a pre -recorded outage notification message that can be disseminated by an auto -dialer to residents in the HFTD in the event a significant planned de -energi zati on becomes necessary. BWP also plans to maintain a prepared list, updated at a minimum on an annual basis, of lifeline and life -support program customers in the HFTD that can be passed on to the EOC if necessary.
As the WMP is updated each year, BWP will continue to consider if a more aggressive de -energization protocol i s an appropri ate mi ti gati on acti vi ty for i ts el ectri cal system.
5.6 Descript ion of Customer Outreach and Education
In the City of Burbank , the majorit y of t he wildfire preve nt ion outreach and enforcement outside of the utility equipment is handled by the primary fire fight ing agency for BWPs resp onsibilit y are a – the Burbank Fire Department. For major projects that involve significant constr uction or service impacts to BWP customers , BWP devel ops a comprehensi ve, project -spe cific communication plan. The communication plan creates cohesive messaging across the organization and includes mult i-platform outreach using some or all of t he following: BWPs and/ or the cit ywide digital communication channels , bill insert s, printed letters, FAQ s, door hangers , palm cards, message signs, targeted phone calls , and in person or onsite meetings .
Burbank Water and Power - W ildfire Mit igat ion Plan Page | 41 Chapter 6. Emergency Preparedness and Response
6.1 E mergency Management
BWP responds to emergencies in accordance with its Emergency Response Plan and in alignment with the State Standardized Emergency Management System ( SEMS) and federal National Incident Management System (NIMS). In re sponding t o all -hazard emergencies, BWP staff would be organized based on SEMS and NIMS as outlined in BWP’ s Emergency Response Plan. The BWP Emergency Response Plan is comprised of separate plans for Electric, Power Supply, Telecommunication, and Water System. Each plan calls for convening a gr oup of experts, or Emergency Response Teams, to respond and coordinate efforts pertaining to any situation where communication and control of an incident would be needed. Once assembled, these Emergency Response Teams will asse ss a sit uat ion and make a rec ommendation to the General Manager on whether to declare a department system emergency and activate the BWP E mergency R esponse Plan. The declarati on of a department system emergency shall be by the General Manager, by which the Emergency Response Plan woul d be activated.
BWP’ s Emergency Response Team is comprised of four teams: o perational technology, ele ct ric se rvice s, power supply, and water. The collective work of these teams consists of preparing for, responding to, and recovering from incidents that m ay affect BWP operations.
To respond and recover e ffe ct ive ly from all hazards and t hreat s, such as wildfire s, t he Elect ric Service s Te am follows guide line s t hat are det ailed in t he Ele ctric Emerge ncy Response Plan (EERP).
The E E RP may be activated whenever any of the following conditions exist:
• Natural disaster
• Predicte d load shedding
• L oss of distribut ion, one -t hird or more of the distribution system, or ge nerat ion facilit y where load is not transferrable
• Emerge ncy curtailment
• Major civil disturbance
The E l ectri c Servi ces R esponse T eam i s compri sed of four response teams: d amage assessment, planning/ intel l i gence, construction, and l ogist ics, as presented in Figure 8 . The responsi bi l i ti es of each response team are described in Table 10 below.
Burbank Water and Power - W ildfire Mit igat ion Plan Page | 42
Figure 8 - BWP Emergency Response Team organization
Emergency Operations
Center
Department Operati ons
Center
Communications
Ope rat ional
Technology
Electric Services
Power Supply
Water
Damage Assessment
Planning/ Intelligence
Construction
Logistics
—
Source: BWP Emergency Response Plan
Table 10 – E lectric Services Team Responsibilit ies During a n E mergency Response E vent Team Responsibilit ies
Damage Assessment
• Visit affected areas to ide nt ify safe t y issue s and determi ne the extent of damage • Estimate labor, material, and equipment needed for restoration • Submit information to the restorati on team
Planning/ Intelligence
• Prioritize and coordinate restoration according to the r estorati on philosophy • Maint ain syst e m integri ty
• Ensure continued operation
Construction
• Assign and manage construction crews
• Coordinate with mut ual aid crews
Logistics
• Obt ain, manage, and control materials and equipment to support ope rat ions and construction teams
• Maintain communication and technology systems to support all teams —
Source: BWP Emergency Response Plan
Burbank Water and Power - W ildfire Mit igat ion Plan Page | 43
6.1.1 BWP Department Operations Center
BWP’ s is responsible for coordinating BWP’ s emergency management activities and activation of the Department Operati ons Center ( DOC) . The acti vati on of the DOC assembl es the i nternal subj ect matter experts for the E l ectri c Servi ces R esponse T eam to assess and provide situational awareness to internal and external stakeholders/ Assistant General Managers and to provide incident planning objectives and subsequent response.
6.2 Disaster and E mergency Response
BWP EERP is consistent with BWP’ s system wide response approach. The BWP EERP is customized to provide a framework by whi ch BWP can respond effecti vel y to wi l dfi re threats and other hazards. BWP recogni zes i ts essential role in both restoring normalcy afte r an incident and the importance of the utility sector to the daily lives of customers and stakeholders and the region’ s economic well -bei ng and securi ty. The WMP refl ects these considerations and is intended to be a framework for BWP’ s engagement with ext ernal enti ti es and the ci ti zens of Burbank.
In the event of a disaster, BWP expects to utilize experienced electric staff and affiliate support to perform incident response and management. Roles and responsibilities are divided by functional areas , and the emergency response is led by an area commander or an incident commander (IC) , depending on the incident's scope or complexity. BWP will use the Incident Command System ( ICS) as the foundation for its incident response organization. ICS is a standardized, on-scene, al l-hazard incident management concept, which provides responders with an integrated organizational structure to match the complexities and demands of single or multiple incidents. Through the use of span of control management and a top -down org anizational structure, ICS helps ensure full utilization of all incident resources, decreases confusion, and improves communication. As a system, ICS both provides an organizational structure for incident management, and guides the process for planning, building, and adapting that structure.
When an incident affects multiple entities and/ or jurisdictions, a Unified Command structure may be established.
The Unified Command organization consists of ICs from various jurisdictions or agencies, who form a singl e command structure and work together to make joint decisions. Institutions and responding agencies blend into an integrated, unified team.
A unified approach results in:
• A shared understanding of priorities and restrictions .
• A single se t of incide nt objecti ves.
• Collaborative strategies .
• Improved internal and external information flow.
• Le s s duplication of efforts .
• Better resource ut ilizat ion.
Burbank Water and Power - W ildfire Mit igat ion Plan Page | 44 By utilizing this emergency response framework, BWP will maintain a coordinated and standardized approach for activating and establishing the emergency response organization. The emergency response framework, along with all associated plans, serves to safeguard BWP’ s ability to meet its essential missions and functions under wildfire threats and hazards, with or w ithout warning, in preparation for or during any incident, regardless of its expected duration.
6.2.1 Fire Agency E mergency R esponse
In addition to its internal emergency preparedness procedures, emergencies , including act ive fire wit hin BW P’s Tie r 2 HFT D, would be responded to by a robust cit y fire-fight ing syst em. BW P distribut ion lines are locat ed within the Burbank Fire Department responsibility area. Emergency response for BWP distribution lines would be provided by the Burbank Fire Department along with L os Angeles County Fire and other agencies, as needed, under existing mutual and automatic aid agreements. The available firefighting resources are considered sufficient to respond to wildfires in BWP ’s Tier 2 HFTD .
6.3 Customer Support During E mergencies
Customer support is applicable in emergency situations , gi ven the BWP’ s servi ce area and customer base. BWP includes a communications protocol for communication and coordination with its primary stakeholders, which include the Burbank Fire Dep artment, the Cit y Manage r, ot he r ut ilit ie s, e le ct e d officials, fire age ncie s and first responders, and BWP’ s emergency response support team. Communication with customers impacted by the de -e nergizing of ele ct rical line s during an emerge ncy would be init ia ted using BWP’ s standard communication protocols. Customer notification of outages would follow the procedure outlined in section 5. 6.
6.4 Restoration of Service
Restoration of the electric system would occur in accordance with the BWP Emergency Response Plan. After a wildfire , BW P’s De partme nt Operat ions Ce nte r (DO C) will coordinate t he rest orat ion of service in alignme nt wit h the direction from the City of Burban k’ s Emergency Operations Center (EOC).
Burbank Water and Power - W ildfire Mit igat ion Plan Page | 45 Chapter 7. Performance Me t rics and Monitoring
7.1 Account abilit y of the Plan
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. Tabl e 11 below lists each component of the WMP along with the corresponding owner.
Table 11 - Accountability for WMP components
Mitigat ion act ivit ies Activity owner
Design and construction
1 Deteri orated pole repl acements Manage r, T&D Engine e ring 2 Pole loading assessments & r e me diat ion Manage r, T&D Engine e ring 3 Overloaded transformer repl acements Manager, T&D Engine e ring 4 Dist ribut ion construction standards improvements Manage r, T&D Engine e ring 5 Conventional fuse replacements Manage r, T&D Engine e ring Inspection and m aintenance
6 Annual pat rol inspection ( GO 165) Manage r, Ele ct rical Dist ribut ion 7 V egetati on management program Manage r, Ele ct rical Dist ribut ion 8 Intrusive Pole Inspections Manager, T&D Engine e ring Operational pract ices
9 Block reclosing during RFW Manager, Energy Control Center 10 Lin e patrol after outage event during RFW Manage r, Ele ct rical Dist ribut ion 11 Ignit ion potential work pract ice s during RFW Manage r, Ele ct rical Dist ribut ion Sit uat ional/ condit ional awareness
12 Weather / fire monit oring Manager, Energy Control Center 13 Geographic information sys t e m (GIS) applicat ions Manage r, T&D Engine e ring 14 Enhanced system monitoring Manage r, T&D Engine e ring Burbank Water and Power - W ildfire Mit igat ion Plan Page | 46
7.2 Met rics to Evaluate Plan Performance
BWP’ s performance metrics are focused on the success of fire prevention strategies in lowe ring t he risk of catastrophic wildfires. The metrics process would evaluate the effectiveness of a fire prevention strategy in reducing t he risk of wildfire ignit ion and spread. This performance metric tracking approach will utilize a format that offers the ability to track compliance trends over time, correct issues as they occur, and adapt metrics as conditions mandate.
These metrics will be measured by BWP personne l at timeframes indicated, and as needed to ensure adequate goal achievement tracking. As with this WMP, overall performance metrics will be managed according to an adaptive management approach, which will facilitate changes in the measures and metric goal s, as well as the measurement ti meframes, i f determi ned necessary. However, BWP recogni zes that there may be unforeseen circumst ance s t hat re sult in t he inabilit y t o mee t a spe cific me tric goal for a give n t ime frame. This doe s not ne cessarily indicate a fa ilure in the process that requires immediate action. The overall metric goal achievement trend will be the focus of this performance measurement process, with a primary focus on maintaining upward - t re nding performance.
7.2.1 BWP Performance Metrics
Performanc e metrics are derived from and address program measures by fire safety category. Table 12 provides the performance metrics developed to directly address the identified primary wildfire risk drivers.
Burbank Water and Power - W ildfire Mit igat ion Plan Page | 47 Table 12 - BW P W ildfire Prevention Performance Metrics Overview Category Metric Responsible Frequency
Equipment failure
Number of wire -down events caused by conductor failure in Tie r 2 HFTD
T& D Engineering
Manager
Annually
Numbe r of pole failures in Tie r 2 HFTD
Number of transformer failure s in the Tie r 2 HFTD
Conventional fuse
ope rat ions
Number of conventional transformer fuse operation
events i n Ti er 2 HFTD
T& D Engineering
Manager Annually
Number of conventional lateral fuse operation events in Tier 2 HFTD
Number of non- expul si ve “ E xempt” transformer fuse operation events in Tier 2 HFTD
Number of non- expul si ve “ E xempt” l ateral fuse operati on events i n Ti er 2 HFTD
W ire contact wi th
fore ign ob je ct (s )
Number of outage events caused by wire contact wi th an animal in Tie r 2 HFTD
T& D Engineering
Manager
Annually Number of outage events caused by wire contact wi th mylar balloons in Tie r 2 HFTD
Number of pole failure s caused by ve hicle contact in the Tie r 2 HFTD
W ire contact wi th
vegetati on
Number of outage events caused by wire contact wit h vegetation in Tie r 2 HFTD
T& D Engineering
Manager Annually
Intrusive pole
inspections
1 0 0 % of int rusive pole inspe ct ions in t he Tie r 2 HFTD compl eted T& D Engineering
Manager Annually
Summary of pole replacements based on priority level
determined by intrusive inspections in Tie r 2 HFTD Inspection and
maintenance
Number of trees tri mmed i n the Ti er 2 HFTD
Manage r Ele ct ric
Dist ribut ion Annually
Number of recurring “ problem” trees remove d in Tie r 2 HFTD
100% of vegetation management inspections in t he Tie r 2 HFTD completed on t ime
100% of patrol inspections of ove rhe ad facilit ie s in t he Tier 2 HFTD compl eted
Operations
Number of outages on circuits in Tie r 2 HFTD
ECC Manager Annually
Number of outages on circuits in Tie r 2 HFTD during RFW days
Number of ignit ions caused by BWP e lect rical infrast ruct ure in Tie r 2 HFTD
E xtreme weather
conditions Number of RFW days ECC Manager Annually
Burbank Water and Power - W ildfire Mit igat ion Plan Page | 48
7.2.2 Annual Performance Metrics
Performance metrics are derived from and address program measures by fire safety category. Table 13 provides an annual account of the performance metrics developed to directly address the identified primary wildfire risk drive rs list ed in Table 12.
Table 13 - 2023 BWP wildfire prevention performance metrics data Category Metric
Equipment failure
Number of wire down events caused by conductor failure in Tier 2 HFTD 0 Number of pole failure s in Tie r 2 HFTD 0
Number of transformer failure s in the Tie r 2 HFTD 0 Conventional fuse
operations 2
Number of conventional transformer fuse operation events in Tier 2 HFTD 1 Number of conventional lateral fuse operation events in Tie r 2 HFTD 0 Wi re contact wi th
foreign object( s)
Number of outage events caused by wire contact with an animal in Tie r 2 HFTD 0
Number of outage events caused by wire cont act wit h mylar balloons in Tie r 2 HFTD 0
Number of pole failure s caused by ve hicle contact in the Tier 2 HFTD 0 W ire Cont act wit h
V egetati on
Number of outage events caused by wire contact with vegetation in Tie r 2 HFTD 0
Number of trees trimmed in the Tier 2 HFTD 145
Number of recurring “ problem” trees removed i n Ti er 2 HFTD 0 Inspection and
Maintenance
Percentage of vegetation management inspections in the Tier 2 HFTD completed on t ime 100%
Percentage of patrol inspections of ove rhe ad facilit ie s in t he Tie r 2 HFTD compl eted
100%
Percentage of required int rusive pole inspe ct ions in t he Tie r 2 HFTD completed
100%
Pole s re placed based on priority level
determined by int rusive inspe ct ions
in Tie r 2 HFTD
Priorit y 1 2
Priorit y 2.1 1
Priorit y 2.2 1
Ope rat ions
Number of outages on circuits in Tier 2 HFTD 1
Number of outages on circuits in Tie r 2 HFTD during RFW days 0 Number of ignit ions caused by BWP e le ct rical infrast ruct ure in Tie r 2 HFTD 0 Extreme Weather
Condit ions
Number of RFW days 3
2 BWP has had non-expulsive fuse operations which are not accounted for as risk drivers. As the fuse replacement program is completed it is expected that this metric will go to zero because there will be no conventional fuses installed in the HFTD.
Burbank Water and Power - W ildfire Mit igat ion Plan Page | 49 A summary of the risk driver events that occurred in 2022 is shown in Table 14 below. For reference, a broader, mult i-year period of hist orical outage informat ion was previously highlight e d in Table 5 of Se ct ion 4.4.
Table 14 - 2023 summary of risk driver events in the Tier 2 HFTD Date of
outage
Volt age
(kV)
Circuit
no.
Cause of
outage
Risk driver events
During RFW
alert ?
7/29/23 4.16 T-10 Transformer Fuse
Ope rat ion - Conventional fuse operations N
An assessment of the above performance metrics above is provided in Section 7.3.3 as part of the annual internal audit.
7.3 Monitoring and Audit ing the Plan
BW P will perform an int ernal audit of t he W MP annually t o monitor the effectiveness of the plan. This internal audit will align with BWP’ s planning and budgeting process. This review will include an assessment of the previous plan me trics as we ll as t he e ffe ct ive ne ss of t he W MP mit igat ion act ivit ie s. After t he completion of the annual internal audit, the WMP will be updated accordingly. As part o f t he current annual WMP update, BWP performed an internal audit to monitor the effectiveness of the plan , as discussed in Section 7.3.3 .
7.3.1 Identifying and Correcting Deficiencies in the WMP
At any point in time when deficiencies are identified, they should be corrected through the Assistant General Manager – Ele ct ric Service s. BWP has monitored and audited the imple me nt at ion of it s W MP in the current annual cycle. No deficiencies in the WMP or it s imple me nt at ion were found.
7.3.2 Monitoring and Audit ing the Effectiveness of Inspections
BWP meets or exceeds the inspection cycles in GO 165. For the Tier 2 HFTD, BWP performs annual patrols for all overhead equipment. Problems that are identified during inspection are prioritized for correction. Inspection findings are examined to identify trends and recurring problems. These findings will be combined with analysis of performance metrics to develop changes to design, construction, or maintenance standards and practices so t hat t he ove rall performance of t he elect ric syst em, including safe t y and re liabilit y, is improved.
BWP has monitored and audited the effective ne ss of electrical equipment inspections in the current annual cycle , including inspections performed by its vegetation management contractor. As indicated in the WMP performance metrics in Table 13, all inspection, maintenance, and operation activities associated with this plan were completed in the Tier 2 HFTD in the current annual cycle , and no wildfire s were caused by BW P’s e le ctrical equipme nt .
7.3.3 Annual Int ernal Audit
BWP performed an internal audit to measure the effectiveness of its WMP in the current annual cycle u sing t he Burbank Water and Power - W ildfire Mit igat ion Plan Page | 50 following methods :
• Assessment of performance m et rics
• Consideration of recommendations in t he Independent Evaluation Report dated April 1 7, 2023, by BWP ’s independent e valuat or, Guidehouse .
• Revie w of mit igat ion acti vi ty accomplishments
Assessment of performance metrics
The following assessment was made regarding the 2022 WMP performance m e t rics listed in Table 13, Sect ion
7.2.2 :
• I n 2022 , only 1 risk driver event occurred in t he Tie r 2 HFTD. A conventional transformer fuse operated .
Conventional fuse operation is a risk driver accounting for the largest percentage of outages, both this year and hist orically in the Tier 2 HFTD . BWP has created a program to replace all conventional fuses in the Tier 2 HFTD wit h CALFIRE “Exe mpt” fuse s, as discussed in Section 5.1.5. • There were no pol e fai l ures i n the Ti er 2 zone. The absence of no pol e fai l ures i n the Ti er 2 zone i s a di rect result of BWP’s acti ve efforts over the past several years wi th deter iorated pole replacements, intrusive pole inspect ions, pole loading assessments and remediation , and annual patrol inspe ct ions. • All inspection, maintenance, and operation activities associated with this plan we re comple t e d in t he Tier 2 HFTD. Over the past year, BWP and its tree trimming contractor performed extensi ve l i ne cl earance work as part of its vegetation management program by trimming trees and removing “ problem” trees, which would have creat ed a potential fire hazard, as de t ailed in Table 13 . In addition, BWP enacted procedures to block reclosers, patrol the circuit before re -energizing a tripped circuit, and restrict ignition producing work during an RFW alert.
• There was no signi ficant chang e in the number of R FW al erts. BW P will cont inue monit oring t his me tric in the future to gauge if there is an uptick in the number of RFW alerts which may occur due to climate change.
Consideration of Independent Evaluation Report Recommendations As discussed in Se ct ion 8.3, BW P had contracted with a qualified independent evaluator in 2023 to re-assess the comprehensiveness of its WMP. Whi l e the independent evaluator established that the WMP was comprehensive and met statutory requi rements, the i ndependent evaluator also provided a comparison of BWP’ s mitigation measures with industry best practices and apprised BWP of additional mitigation measures/ best practices to consider . Be low is a summary of BW P’s conside rat ion of those additional best practice s mentioned in the Independent Evaluation Report. • Replacing bare wires with covered conductors .
o IE Report : Replacing bare wires with covered conductors is a common best practice successfully e mploye d by several ut ilit ie s wit h similar operat ing and e nvironme nt al condit ions as BW P. BW P will benefit from a full analysis and installation of covered conductors at th at ti me. o BW P Conside rat ion: 25 % of risk driver events since 2005 are associated with wire contact with foreign objects and vegetation. With exception to abnormal events that sever or take down a power line, replacing bare wires with covered conductors could mit igat e t hat risk. BWP has completed the engineering review of a covered conductor solution for the highest priority circuits within the Tier 2 HFTD and plans to deploy a covered conductor as budget, supply, and resources allow . • Expulsion fuse dev ice change out to current -limit ing (non-expulsi ve) fuses. o IE Report : Replacement of expulsion fuses with non- e xpulsion fuse s is a common be st pract ice .
BW P plans to replace all conventional fuses with CAL FIRE “ Exempt” fuses in the Priority 2.1 zone of the Ti er 2 HFTD by June 2024.
Burbank Water and Power - W ildfire Mit igat ion Plan Page | 51 o BW P Conside rat ion: 42% of risk driver events since 2005 are associated with conventional fuse operat ions wit hin t he Tier 2 HFTD . Re placing conventional fuses with non- e xpulsive fuse s will e liminate t his risk driver. After performing a n e nginee ring evaluat ion st udy in 2021 , BWP has determined that replacement of all conventional fuses in the Tier 2 HFTD with CAL FIRE “ Exempt” fuses is a cost -effective method of reducing the risk of ut ilit y-caused wildfire s in t he Tier 2 HFTD.
Further discussion of this conventional fuse replacement program can be found in Section 5.1.5. • Not ify crit ical facilit ies and public safe t y part ners. o IE Report : Specific communications protocols for PSPS events, even if unlikely, improve communication and coordination.
o B W P Considerat ion : BWP, as a department of the City of Burbank, follows the Standard Emergency Management System ( SE MS) for improved communication and coordination. Further discussion regarding PSPS communication is in section 5.5.
Review of mitigat ion act ivit y accomplishments
Sect ion 5.0 highlighte d se veral preve nt ion strate gie s and programs t hat BW P impleme nted t o minimize t he risk of wildfire s. Table 15 below summarizes those accomplishments.
Table 15 - Summary of Mit igat ion Act ivit y Accomplishment s i n 2023 Mitigat ion act ivit ies Descript ion Accomplishment s Design and construction
1 Deteri orated pole
repl acements
Replacement of poles that do not pass
condition -based assessments to
prevent pole failure.
Replaced 3 pole s in Tier 2 HFTD .
2 Pole loading assessments
& re me diat ion
Structural assessment of pol es to i denti fy
potential loading issues during high wind
events. Replacement of poles that do not pass
GO 9 5 wind loading de sign crit e ria t o
minimize
t he risk of pole failure .
All pre -empti ve pole loading
assessments in the Priority 2.1 area of
the Tier 2 HFTD were compl eted in
2020 , and all pole loading issue s have
been mit igat e d. All poles that have been
replaced since t he init ial asse ssme nt also
had new pole loading performed. All
fut ure re place me nt s will also re quire
pole loading per GO 95.
3 Overloaded transformer
repl acements
Replacement of overhead transformers that do
not me e t loading crit e ria t o
prevent transformer failure.
Replaced 4 transformers in Tier 2 HFTD
4 Dist ribut ion construction
standards improvements
Engineering study of distribution construction
standard improvements, which could provide
addit ional risk reduction in the Tier 2 HFTD.
Completed :
• An engineering study of
conventional fuse repl acements
(2020) . A program was created
t o re place all conve nt ional fuse s
w it h CALFIRE “Exe m p t ” fu s e s,
as discussed in Section 5.1.5.
• Fie ld reclosers study is
complete, but imple ment ation is
Burbank Water and Power - W ildfire Mit igat ion Plan Page | 52 Mitigat ion act ivit ies Descript ion Accomplishment s on hold pending the completion
of the remaining engineering
st udie s. This will he lp BW P
determi ne the most cost -
effective risk reduction method.
• Composite pole pilot completed,
composite poles will be
imple me nt e d as a mit igat ion
method in the HFTD for future
pol e repl acements.
• Replacement of bare overhead
wire with covered conductor or
rei nforcement of pol e l ines by
replacing aging copper with
ACSR, study is completed and
t his will be imple me nt e d as a
mit igation strategy as budget ,
supply, and re source s allow.
• I nfrared inspection technology
study is completed,
imple me nt at ion is pe nding
vendor selection through the
standard procurement processes
The following pilot projects are e it he r
planned or on track to be completed:
• Pole mounted sensor devices
for re al t ime monit oring, pilot
i mpl emented in 2022. W it h
grant funding support it is
expected to deploy these
se nsors t o all pole s in t he HFTD.
• Re place me nt of oil fille d
transformers with non- oil filled
pole mounted transformers
pilot
inst allat ion comple t e d, ongoing
monitoring before final
de t e rminat ion by July 2 025 .
• Falling conductor technology
( estimated completion by June
2025/2026)
Inspection and m aintenance
5 Annual pat rol inspection
(GO 165)
Annual system patrol to inspect the
condit ion of e le ct rical asse t s t o avoid
fault s, which could cause ignit ions.
Completed 100% of annual patrol
inspections in the Tier 2 HFTD
6 V egetati on management
program
Annual vegetation maintenance and clearance
from e le ct rical line s t o avoid
vegetati on contact in Ti er 2 HFTD
Completed 100% of annual maintenance
and clearance in the Tier 2 HFTD . See
Table 13 for de t ails.
Burbank Water and Power - W ildfire Mit igat ion Plan Page | 53 Mitigat ion act ivit ies Descript ion Accomplishment s
7 Intrusive pole inspections
Condit ion-based assessment of remaining pole
strength to identify
pole s at risk of failure
BW P is up t o dat e wit h all int rusive pole
inspections in the Tier 2 HFTD
Operational pract ices
8 Block re closing and
increase re lay se nsit ivit y
during RFW
Block re closing and incre ase re lay se nsit ivit y
on all fe e de r line s in t he Tier 2 HFTD during
R FW events Blocked reclosing and increased relay
se nsit ivit y during all RFW alert days
9 Lin e patrol after outage
event during RFW
Pat rol wit h a physical inspection of
tripped feeder lines in Tier 2 HFTD during
RFW before re -e ne rgizing the circuit
Patrol l ed l i nes after an outage event
during RFW
10 Ignit ion potential work
pract ice s during RFW
Except during an emergency, disallow work
that may
potentially produce an ignition source
on all feeder lines in the Tier 2 HFTD during
R FW events
No ignit ion pot e nt ial work was
performed in the Tier 2 HFTD during
R FW events
Sit uat ional/ Condit ional Awareness
11 Weather / fire monit oring
Conduct we at he r monit oring via publicly
avai l abl e weather resources to moni tor
weather forecasts and any
pot e nt ial e xt re me fire condit ions
Monitored weather and alerted staff on
each of the days with a RFW condition.
I n 2021, the ECC began using the SCE
owned fire -monitoring camera in the
Verdugo Mountains to enhance
sit uat ional awareness on an as -needed
basis.
12 Geographic information
syst e m (GIS) applicat ions
I mplementation of Outage Management
System ( OMS) , whi ch uses GI S data and meter
information to help BWP locate outages and
decrease response time
Updated GI S and OMS data , which
helped BWP locate outages and
decrease response ti me
In summary, BWP's accomplishments indicate that it ’s be e n e ffect ive in carrying out mit igat ion act ivit ies t hat re duce t he risk of it s e le ct rical e quipme nt ignit ing a wildfire . BWP is planning to implement a conductor replacement program potentially in conjunction with falling conductor technology , e specially wit h respe ct t o olde r bare copper conductors that have be e n re sponsible for all wire -down events. As de tailed in Table 15 BWP has made significant progress and has now completed the bulk of its pilot and testing processes. Going forward , there will be a greater focus on deploying the chosen mitigation strategies as budget, supply chain, and resources allow, with a primary focus on the higher -risk areas. BWP has seen a decrease i n ri sk dri ver events ; as this trend continues, it is an indicator of t he succe ssful result s of t he mit igat ion strate gie s implemented to date . Although environmental factors contribute to the stresses on the electric system and corresponding risk drivers, c ontinued refinement and increased mitigation are expe cted to continue to reduce risk and, therefore, risk driver events.
Burbank Water and Power - W ildfire Mit igat ion Plan Page | 54 Chapter 8. Public Comment , Presentati on , and
Independent Evaluat ion
8.1 Public Comment
A draft copy of the WMP will be made available for comment on BW P ’s websit e prior to the Cit y Council mee t ing.
BWP Board and City Council meetings are open and accessible to the public. Meeting notices and agendas are posted, at a minimum, 72 hours in advance on the c it y ’s website. Those who are unable to attend the meeting in person can livestream the meeting or view a recording on the c it y ’s websi te.
BW P also maint ains a copy of the current and previous WMP and independent evaluation report s on it s website at BurbankWaterAndPower.com under Electric > W ildfire Mit igat ion Plan . Council action and public comment are available at BurbankCA.gov.
8.2 Presentation to BWP Board and Burbank City Council
The WMP will be posted on BWP’ s website and presented to the BWP Board before being presented to the Cit y Council.
BWP follows the process be low:
• Draft WMP is posted on BWP website and open for public comment • BWP presentation to BWP Board, along with public comment and comment from BWP Board • BWP presentation to City Council, along with public comment and comment from City Council • WMP is posted on BWP websi te and submitted to WSAB for review by July 1 st, annually
8.3 Independent Evaluation
In accordance with a statutory requirement in Public Utilities Code Section 8387, BWP contract ed wit h a qualified independent evaluator to assess t he comprehensiveness of the January 2020 WMP. The independent e valuat or completed an Independent Evaluation Report and presented the following evaluation results and conclusions to the City Council on October 27, 2020. The complete Independent Evaluation Report is available at BurbankWaterAndPower.com. During the comprehensive 3 -year revie w cycle of BWP’ s 2022 WMP, BWP contracted with a qualified independent evaluator to re -evaluate it s W MP . This e valuat ion was performe d to ensure the plan’ s continued comprehensiveness and compliance, along with a re -evaluation of industry best pract ice s. Section 7.3.3 was updated with the revised recommendations.
2022 WMP Independent Evaluat ion result s
• BWP has addressed each of the mandat ory requirement s in it s WMP • BWP has implemented many industry best practices to prevent and mitigate against the impacts of wildfire, including, Burbank Water and Power - W ildfire Mit igat ion Plan Page | 55 but not limited to:
• Enhanced situational awareness
• Blocking reclosers during Red Flag Warnings
• Operat ional limit at ions during RFW
• S trong vegetati on management practi ces
• Engineering and design best practices
• Non-expulsive fuse devices
Evaluat ion conclusion
• BWP’ s WMP aligns appropriately with PUC Section 8387 and includes all required elements. • BWP’ s WMP is comprehensive as described through this Report in accordance with PUC Section 8387s.
The Independent Evaluator’ s report has been posted to BWP’ s website and remains available for public consumption . In addition, BWP has used this report as a tool for its internal audit in Section 7.0. An independent eval uati on of the WMP wi l l be compl eted every 3 years. The resul ts of the next evaluat ion report will be shared in the 2026 update of the WMP.
8.4 W ildfire Safety Advisory Board
On or before July 1, 2020, and annually thereafter, Public Ut ilit ie s Code Se ct ion 8387 requires that BWP submit it s WMP to the California W ildfire Safety Advisory Board (W SAB). BW P fulfilled t his obligat ion by submitt ing its WMP to WSA B i n June 202 2.
On December 4, 2023, W SAB approved its final “ Advisory Opinion for the 202 4 W ildfire Mit igation Plans of Ele ctric Publicly O wned Ut ilit ie s and Rural Ele ct ric Cooperatives.” BWP has considered the recommendations from the WSAB in this 202 4 update to the WMP and has implemented changes where applicable. BWP will continue to consider comments and opinions received by the WSA B in future updates of the WMP .
Burbank Water and Power - W ildfire Mit igat ion Plan Page | 56 Chapter 9. R eferences
BWP. 2020. Burbank Water and Power Emergency Response Plan. September 2020
BWP. 20 20. Independent Evaluation Report by Guidehouse Inc., May 13, 2020
BWP. 2023. Independent Evaluation Report by Guidehouse Inc., Ap ril 1 7 , 202 3
California Wildfire Safety Advisory Board. 2020 . Guidance Advisory Opinion for t he 2021 W ildfire Mit igat ion Plans of Elect ric Publicly O wned Ut ilit ie s and Cooperat ives, De cember 9, 2020
California Wildfire Safety Advisory Board. 202 1. Guidance Advisory Opinion for the 202 2 W ildfire Mit igat ion Plans of Elect ric Publicly Owned Utilities and Cooperatives, March 2 , 2022
California Wildfire Safety Advisory Board. 202 2. Guidance Advisory Opinion for the 202 3 W ildfire Mit igat ion Plans of Elect ric Publicly O wned Ut ilit ie s and Cooperat ives, November 18 , 2022
California W ildfire Safety Advisory Board. 2023. A dvisory Opinion for the 2024 Wildfire Mitigation Plans of Ele ctric Publicly O wne d Ut ilit ie s and Cooperat ives, De ce mbe r 4, 2023
CA L FI RE. 2020. California Powe r Line Fire Pre ve nt ion Field Guide , 2020 edit ion
Burbank Water and Power - W ildfire Mit igat ion Plan Page | 57 Exhibit A. Context -setti ng Information Table
Ut ility name BWP
Service territory size 17 square mil es
Owned assets ☒ Sub -transmi ssion ☒ Dis t rib u t io n ☒ Generati on Number of customers
served
53, 717 customer accounts
Popul ation wit hin servi ce
territory 3
107, 337 peopl e
Cust omer class makeup
Number of accounts Sha re of tot a l load ( MWh)
86.8% R esi dential;
10. 3% Small commercial;
2.4% Me d ium commercial;
0.3 % La r g e co mme rcia l;
0.2 % Ext ra-large comme rcial;
27.5 % R esi dential;
7.5 % Small comme rcia l;
17 .8% Me d ium comme rcia l;
18.5 % La r g e commercial;
24.4 % Ext ra-large commercial;
Servi ce territory
locati on/ topography 4
B arren/Other 1.012423 %
Hardwood Woodl and 0.555464%
Herbaceous 1.212171%
Shrub 19.943359%
Urban 77.21228%
Water 0.064303 %
Servi ce territory
Wildland Urban
In t e rfa ce5
( based on total area)
28% Wil dl and Urban I nterface
Percent of servi ce
te rrit o ry in CPUC High
Fire Thre at Dist rict s
( based on total area)
☒ R efer to WMP, Secti on 4.3.1, Fi gure 4 for a map of BWP’ s Ti er 2 High Fire Thre a t Dist rict
Tie r 2 : 2 8 % (ge ogra p hic are a )
Tie r 2 w it h o ve rhe ad e le ct rical fa cilit ie s: 9 % (ge ogra p hic are a ) T i er 3: 0%
Pre vailing wind dire ct io ns
& speeds by sea son
☐ I ncl udes maps
int e rmit t e nt , we st e rly a nd e ast e rly w ind s Mile s o f owned line s
underground and/ or
overhead
Overhead dis t .: 2 0 4 circuit m ile s
Overhead tra ns.: 48 circuit m ile s
Underground d ist .: 132 circuit mile s
Underground tra ns.: 3 0 circuit m ile s
Percent of owned line s in
CPUC High Fire Thre at
Dist rict s
Overhead distribution lin e s a s % o f tot a l distribution syst em (inside and outside service territory)
Tie r 2 : 5 .4 % (o f t o t a l circu it m ile s)
T i er 3: 0%
3 This d at a shall be based on the United States Census Bureau stati sti cs found i n the 2016 -2020 A merican Community Survey 5-Y ear E sti mates a t : https:/ / data.census.gov/ cedsci / profi l e?g=1 600000US0608954 4 Thi s data shal l be based on the Cal i forni a Department of Forestry and Fi re Protecti on, Califo rnia Mult i- Source V egetati on Laye r Map , d e p ict ing W HR1 3 Typ e s (W ild life Hab it at Re lat io nship classe s gro up e d i nto 13 major l and cover types) avai l abl e at:
https: / / www.arcgi s.com/ home/ i tem.html ?i d=b7ec5d68d8114b1fb2bfbf4665989eb3 . 5 Thi s data shal l be based on the defi ni tions and maps maintai ned by the Uni ted States Department of A gricul ture, as most recentl y assembl ed i n The 2 0 1 0 Wildla nd -Urban I nterface of the Conterminous United States , avai l abl e at https:/ / www.fs.fed.us/ nrs/ pubs/ rmap/ rmap_ nrs8.pdf .
Burbank Water and Power - W ildfire Mit igat ion Plan Page | 58 Ut ility name BWP
Overhead transmission lines as % of tot al transmission system (inside and outside service territory)
Tier 2: 0%
Tier 3: 0%
Customers have ever lost
service due to an IOU
PSPS event?
☐ Ye s ☒ No
Customers have ever been
notified of a potential loss
of service to due to a
forecasted IOU PSPS event?
☐ Yes ☒No
Has developed protocols to
pre-emptively shut off
electricity in response to
elevated wildfire risks?
☐ Yes ☒ No
Has previously pre-
emptively shut off
electricity in response to
elevated wildfire risk?
☐ Yes ☒ No
If yes, then provide the following data for calendar year 2020:
Number of shut-off events: [____]
Customer Accounts that lost service for >10 minutes: [____] For prior response, average duration before service restored: [____]
Burbank Water and Power - W ildfire Mit igat ion Plan Page | 59 Exhibit B. Summary of Key C hanges i n BWP’ s 2024
WMP
This document provides a summary of the key changes between BWP’ s 202 4 W ildfire Mit igat ion Plan (W MP), and BWP’ s 2023 W ildfire Mitigat ion Plan.
This document is intended to simplify the process of reviewing BWP’ s current WMP but does not comprehensively identify every update to BWP’ s WMP. Therefore, a full review of BWP’ s wildfire mitigation efforts should be based on the actual WMP.
Changes to the current WMP
Chapter 2 – Burbank Water and Power
- Se ct ion 2.1 – Clarified update freque ncy t o coincide wit h a comprehensive update
Chapter 4 – Risk a nalysis and risk drivers
- Section 4.4 – Clarified update freque ncy t o coincide wit h a comprehensive upd ate - Section 4.7 – Clarified update freque ncy t o coincide wit h a comprehensive update
Chapter 5 – W ildfire preve nt ion strategies and programs - Section 5.1 – Provided update on facility design and construction progress/ improvements - Section 5.2 – Updated to current inspection cycles
- Section 5.3 – Updated RFW counts, updated events
- Section 5.4 – Updated remote sensing deployment plans
Chapter 7 – Performance me t rics and monit oring
- Section 7.2 – Updated all performance metrics based on annual cycle data - Section 7.3 – Updated information in Annual Internal Audit (Section 7.3.3) and Mitigation Activity Accomplishments ( Table 15)
Chapter 8 – Public comment, p resentation, and independen t e valuat ion - Section 8.4 – Updated for current cycle
Chapter 9 – R eferences
- Updated to include the lat e st W SAB opinion
Exhibit A – Context -setti ng information table
- Updated with current information
Exhibit B – Summary of key changes in BWP’ s 202 4 WMP
- Updated for the current cycle