1 San Francisco Public Utilities
Commission
(SFPUC)
Wildfire Mitigation Plan Comprehensive Revision
Margaret Hannaford
June 27, 2023
Operated by the San Francisco Public Utilities Commission Services of the San Francisco Public Utilities Commission 2 SFPUC Owns and Maintains Assets
within Wildfire Risk Areas
By state law, we are required to construct, maintain and operate these electrical lines and equipment in a manner that will minimize the risk of catastrophic wildfire posed by our electrical lines and equipment.
• Requirements
• Prepare a wildfire mitigation plan annually
• Submit our plan to the California Wildfire Safety Advisory Board annually
• Comprehensive update of the Plan with review by an
Independent Evaluator at least once every three years
High Fire Threat Districts
3 Wildfire Mitigation Plan Principles
4 • Minimizing source ignition of a fire
• Resiliency of the grid
• Measure plan effectiveness and performance to ensure we strive towards continual improvement
Plan Metrics and Evaluation
Self Evaluation (Audit)
Self-evaluation Audit Process
uality Control (QA / QC)
5 Metric Metric Description 2019 2020 2021 2022
Outcome Metrics
1 Vegetation inspections w ere
completed in an HFTD
(Through a combination of
aerial and ground
inspections).
Completed Completed Completed Completed
2 Transmission Line
Inspections – aerial Completed Completed Completed Completed 3 Distribution Line Inspections
– aerial Completed Completed Completed Completed
Performance Metrics
1 Reportable ignitions in the
HFTD associated w ith
SFPUC electric facilities (see
Section 9.4)
0 1 1 0
2 Number of times a circuit or
circuit segment is de-
energized w ithin the HFTD 1 4 7 0
3 Wire dow n in HFTD 1 2 1 0
4 Wire dow n outside HFTD
0 0 0 0
IE Evaluation
6 • Independent Evaluator Introduction
• Questions?
Independent Evaluator Report Overview
June 27, 2023
San Francisco Public Utilities
Commission
Wildfire Mitigation Plan
San Francisco Public Utilities Commission – 2023 WMP IE Report Overview • Account of responsible persons
• Preventative strategies and programs
• Protocols for disabling reclosers
• Protocols for de-energization
• Plans for vegetation management
• Inspection plans
• Identify risks and risk drivers
• Stakeholder engagement
• Metrics used to evaluate plan
• Monitor effectiveness of plan
• Contract with IE to assess comprehensiveness of plan
INDEPENDENT
EVALUATION
San Francisco Public Utilities Commission – 2023 WMP IE Report Overview • Technosylva Wildfire Analyst (WFA-E)
• Wildfire Risk Modeling
• Fire Potential Index
• Fire Size Potential
• Population Impacted
• Buildings Threatened
• Estimated Buildings Destroyed
• Weather Stations
• HD Cameras
• Air Quality Index
• Watches and Warnings
Technology Enhancements
San Francisco Public Utilities Commission – 2023 WMP IE Report Overview • Industry Best Practice:
• Procurement of T echnosylva Wildfire Analyst application • Programmatic Inspection Programs
• Asset Inspections
• Vegetation Management Inspections
• Substation / Switchyard / Powerhouse Inspections
• Disabling reclosers
• Excellent use of situational awareness tools
• Excellent stakeholder engagement
• Use of Preemptive De -Energization
• Recommendations:
• Operationalize the T echnosylva Wildfire Analyst application • Formalize use of Operating Conditions consistent across the SFPUC
IE COMMENTS &
RECOMMENDATIONS
San Francisco Public Utilities Commission – 2023 WMP IE Report Overview GridSME has determined that the SFPUC's WMP is
comprehensive and meets the statutory
requirements of California Public Utilities Code 8387
Evaluation Results
San Francisco Public Utilities Commission – 2023 WMP IE Report Overview
POWER YOUR WORLD WITH CONFIDENCE
QUESTIONS?
Daniel J. Zaragoza
Principal Consultant, GridSME
(619) 564-9464
DEPARTMENT
Hetch Hetchy Water and Power
AGENDA NO.
6 MEETING DATE
June 27, 2023
AGENDA ITEM
Public Utilities Commission
City and County of San Francisco
Calendar: Regular Calendar
Contract/Project Manager: Margaret Hannaford
Adopt the 2023 SFPUC Wildfire Mitigation Plan Comprehensive Revision and Independent Evaluator Report
Summary of
Proposed
Commission Action:
Adopt the 202 3 San Francisco Public Utilities Commission Wildfire Mitigation Plan Comprehensive Revision and Independent Evaluator Report; and authorize the General Manager to file the Plan with the California Office of Energy Infrastructure Safety Wildfire Safety Advisory Board on or before July 1, 2023.
Background: The San Francisco Public Utilities Commission (SFPUC) owns and operates overhead electrical lines and equipment that present a significant risk of wildfire because of their location in areas designated by the California Public Utilities Commission as High Fire Threat Districts . This equipment includes a transmission system with 230 and 115- kilovolt facilities and a distribution system with 22 and 2.4-kilovolt facilities.
Public Utilities Code § 8387 requires publicly owned u tilities, such as the SFPUC, to annually update their wildfire mitigation plans and allow for public comment before submi tting the W ildfire Mitigation Plan to the Wildfire Safety Advisory Board before July 1 of that calendar year.
Public Utilities Code Section 8387 further requires that every three years the utility’s Wildfire Mitigation Plan
undergo a comprehensive revision and be
reviewed by an independent evaluator. The findings of the independent evaluator are to be presented to the utilities governing body, this Commission.
The SFPUC Wildfire Mitigation Plan has been brought before this Commission four times and the Commission has adopted the Plan under Resolutions 19-0234, 20-0129, 21-0094, and 22-0111. The Wildfire Safety Advisory Board provided the following comments after its review of SFPUC’s 2022 Wildfire Mitigation Plan: “The Board appreciates the exemplary job that SFPUC’s Wildfire Mitigation Plan
does of describing wildfire prevention
plans and strategies, including vegetati on management practices, inspection protocols, and situational awareness and system hardening status and projects.”
Staff now brings the 2023 Wildfire Mitigation Plan comprehensive revision and independent evaluator update before this Commission for adoption along Agenda Title: Adopt the 2023 SFPUC Wildfire Mitigation Plan Comprehensive Revision and Independent Evaluator Report Commission Meeting Date: June 27, 2023
with a presentation from the contracted independent evaluator, Mr. Daniel Zaragoza a consultant with Grid Subject Matter Experts (GridSME).
Staff notes that the independent evaluator’s comments and recommendations for the 2023 SFPUC Wildfire Mitigation Plan were complimentary, especially for SFPUC’s plans to increas e situational awareness for fire weather monitoring. In FY 22, SFPUC purchased the Technosylva Wildfire Analyst™ application, which provides detailed fire weather analysis and forecasts up to four days. This product is used by CAL FIRE as well as many of the Investor- Owned Utilities to monitor fire weather; this can help the SFPUC make decisions on safe field operations as well as when to de -energize overhead lines for public safety.
Some highlights of the 2023 Wildfire Mitigation Plan include:
• Increased Risk Assessment and Situational awareness via the Technosylva Wildfire Analyst™ program;
• Creation of a vegetation management dashboard to track inspection progress on overhead lines and categorize trims by severity and tree species;
• Purchase of a satellite vegetation monitoring service for enhanced awareness of vegetation encroachments to overhead electrical lines; • Upgrades to switchyard transformers;
• Performing studies and cost-benefit analysis for replacement of older power pole electrical components; and
• The removal of over 200 hazard trees adjacent to SFPUC overhead electrical lines.
The SFPUC plans to continue improving the operation and maintenance of overhead electrical lines in the High Fire Threat Districts to minimize the potential for a catastrophic wildfire. The annual Wildfire Mitigation Plan review will allow SFPUC to evaluate progress and identify gaps in operations and maintenance of overhead lines and electrical facilities and the resources needed to close them.
Funding and Costs: Funding Source: Funds for Wildfire Mitigation Plan activities, programs, and projects are available from current and future appropriations to Water Enterprise and Power Enterprise operating and capital budgets.
Environmental
Review:
Adoption of the Wildfire Mitigation Plan does not constitute a "project" under the California Environmental Quality Act (CEQA) Guidelines Section 15378 because it would not result in any commitment to any specific project that would result in a physical change in the environment. Environmental review under the CEQA, if required, would be completed for individual projects, including vegetation removal, implemented as a result of the plan.
Attachments: 1. 2023 SFPUC Wildfire Mitigation Plans
Agenda Title: Adopt the 2023 SFPUC Wildfire Mitigation Plan Comprehensive Revision and Independent Evaluator Report Commission Meeting Date: June 27, 2023
2. 2023 SFPUC Wildfire Mitigation Plan Independent Evaluator Report
3. Curriculum Vitae for Mr. Daniel Zaragoza
PUBLIC UTILITIES COMMISSION
City and County of San Francisco
RESOLUTION NO.
WHEREAS, Public Utilities Code 8387 requires that a local publicly owned utility or electrical cooperative, such as the San Francisco Public Utilities Commission (SFPUC), shall prepare a wildfire mitigation plan annually and shall submit the plan to the California Wildfire Safety Advisory Board on or before July 1 of each calendar year; and
WHEREAS, At least once every three years, the wildfire mitigation plan shall be a comprehensive revision and undergo an independent evaluation; and
WHEREAS, The SFPUC owns and operates overhead electrical lines and equipment that present a significant risk of wildfire because they are in areas the California Public Utilities Commission has designated as High Fire Threat Districts; and
WHEREAS, This Commission has adopted previous SFPUC Wildfire Mitigation Plans under Resolution Nos. 19-0234, 20-0129, 21-0094, and 22-0111; and
WHEREAS, Staff prepared the 2023 SFPUC Wildfire Mitigation Plan comprehensive revision and contracted with Grid Subject Matter consultant Mr. Daniel Zaragoza to provide independent evaluation of the Wildfire Mitigation Plan; and
WHEREAS, Staff seeks Commission adoption of the 2023 SFPUC Wildfire Mitigation Plan and the Independent Evaluator Report; and
WHEREAS, Adoption of the Wildfire Mitigation Plan does not constitute a "project" under the California Environmental Quality Act (CEQA) Guidelines Section 15378 because it would not result in any commitment to any specific project that would result in a physical change in the environment; and environmental review under the CEQA, if required, would be completed for individual projects, including vegetation removal, implemented as a result of the plan; and
WHER
EAS, Funds for Wildfire Mitigation Plan activities, programs, and projects are available from current and future appropriations to Water Enterprise and Power Enterprise operating and capital budgets; now, therefore be it
RESOLVED, That this Commission adopts the 2023 SFPUC Wildfire Mitigation Plan comprehensive revision and 2023 SFPUC Wildfire Mitigation Plan independent evaluator report; and
FURTHER RESOLVED, That this Commission hereby authorizes the General Manager, or the General Manager’s designee, to file the 2023 SFPUC Wildfire Mitigation Plan with the WSAB California Wildfire Safety Advisory Board on or before July 1, 2023, with any insubstantial changes or modifications to the exhibits, as may be acceptable to the General Manager.
I hereby certify that the foregoing resolution was adopted by the Public Utilities Commission at its meeting of June 27, 2023.
Secretary, Public Utilities Commission
SAN FRANCISCO PUBLIC UTILITIES
COMMISSION
2023
WILDFIRE MITIGATION PLAN
SFPUC
2023 Wildfire Mitigation Plan
i
TABLE OF CONTENTS
1. EXECUTIVE SUMMARY / INTRODUCTION ............................................................................................ 9
1.1 Utility Description and Context Setting Table .................................................................................... 10
1.2 Process for Utility Adoption and Submittal of Annual WMP and Opportunities for Public Comment .. 18
1.3 Wildfire Mitigation Funding ............................................................................................................... 18
1.4 Description of Where WMP Information Can be Found on the SFPUC Website ............................... 19
1.5 Purpose of the Wildfire Mitigation Plan ............................................................................................. 20
1.6 Organization of the Wildfire Mitigation Plan ...................................................................................... 21
1.7 Summary of Wildfire Mitigation Activities from 2020–2022 ................................................................ 21
1.7.1 Risk Assessment ...................................................................................................................... 21
1.7.2 Situational Awareness .............................................................................................................. 22
1.7.3 Vegetation Management .......................................................................................................... 22
1.7.4 Construction, Operations, and Maintenance ............................................................................. 23
1.7.5 Wildfire Mitigation and Recovery Analyst Position .................................................................... 23
1.7.6 Planned Initiatives for the 2023–2025 WMPs ........................................................................... 24
2. OBJECTIVES OF THE WILDFIRE MITIGATION PLAN.......................................................................... 25
2.1 Minimizing Sources of Ignition .......................................................................................................... 25
2.2 Improve Grid Reliability and Resiliency ........................................................................................... 25
2.3 Measuring Plan Effectiveness .......................................................................................................... 26
3. ROLES AND RESPONSIBILITIES ......................................................................................................... 27
3.1 POU Organizational Chart and Specific Responsibilities. ................................................................ 27
3.2 Coordination with Critical Infrastructure Providers ............................................................................ 29
3.3 Coordination with Water Utilities/Department .................................................................................... 29
3.4 Coordination with Communication Infrastructure Providers ............................................................... 30
3.5 Coordination with Healthcare and Public Health sector / Hospitals .................................................. 30
3.6 Standardized Emergency Management System .............................................................................. 30
3.7 Mutual Assistance Agreements ....................................................................................................... 30
4. WILDFIRE RISKS AND RISK DRIVERS ................................................................................................ 32
4.1 Ent
erprise-Wide Safety Risks ........................................................................................................... 32
ii
4.2 Risks and Risk Drivers Associated with Topographic and Climatological Risk Factors ..................... 32
4.3 Risks and Risk Drivers Associated with Design, Construction, Operations and Maintenance ........... 33
4.4 High Fire Threat District .................................................................................................................... 34
4.5 Changes to CPUC Fire Threat Map ................................................................................................. 37
4.6 Climate Change/ Weather Risks ....................................................................................................... 37
4.7 Extended Drought ............................................................................................................................. 38
5. WILDFIRE PREVENTATIVE STRATEGIES ........................................................................................... 40
5.1 Situational Awareness ..................................................................................................................... 40
5.1.1 Technosylva Wildfire Analyst™ / Fire Potential Index (FPI) ...................................................... 40
5.1.2 Weather Monitoring .................................................................................................................. 41
5.1.3 Weather Stations ...................................................................................................................... 42
5.1.4 Wildfire Cameras ...................................................................................................................... 44
5.1.5 Air Quality Monitoring ............................................................................................................... 46
5.1.6 Fire Mitigation / Suppression Equipment .................................................................................. 46
5.2 Design and Construction Standards ................................................................................................. 48
5.2.1 System Hardening .................................................................................................................... 48
5.2.2 Replace Wood Poles ................................................................................................................ 50
5.2.3 Replace Overhead #6AWG Copper Conductor ........................................................................ 50
5.2.4 Replacement of Non-Exempt Equipment .................................................................................. 51
5.2.5 Avian Protection ....................................................................................................................... 51
5.3 Overhead Line Removal .................................................................................................................. 51
5.3.1 Overhead to Underground Conversion ..................................................................................... 51
5.3.2 Micro-Hydro (Overhead Line Removal) .................................................................................... 52
5.4 Vegetation Management .................................................................................................................. 52
5.4.1 Annual Vegetation Management Work Plan ............................................................................. 54
5.4.2 Vegetation Inspections / Transmission Lines ............................................................................ 54
5.4.3 Vegetation Inspections / Distribution Lines ............................................................................... 56
5.4.4 Vegetation Inspections / Substations. Switchyards, and Powerhouses ..................................... 58
5.4.5 Fire Break Clearance Requirements ........................................................................................ 58
5.4.6 Herbicide Use ........................................................................................................................... 60
5.4.7 Light Detection and Ranging (LiDAR) ....................................................................................... 60
5.4.8 Satellite Vegetation Monitoring ................................................................................................. 60
5.4.9 Vegetation Management Dashboard ........................................................................................ 61
iii
5.4.10 Integrated Vegetation Management (IVM) ................................................................................ 63
5.4.11 Wood and Slash Management ................................................................................................. 63
5.5 Asset Inspections ............................................................................................................................ 65
5.5.1 Work Order Documentation ...................................................................................................... 65
5.5.2 Transmission Inspections and Maintenance ............................................................................. 65
5.6 Asset Maintenance .......................................................................................................................... 66
5.6.1 Hot or Cold Wash ..................................................................................................................... 67
5.6.2 Distribution Inspection and Maintenance .................................................................................. 68
5.6.3 Powerhouse/Substation/Switchyard Inspections and Maintenance........................................... 68
5.6.4 Defensible Space Inspections .................................................................................................. 70
5.7 Asset Management .......................................................................................................................... 70
5.8 Workforce Training .......................................................................................................................... 70
5.8.1 Basic Fire Training ................................................................................................................... 70
5.8.2 NRLM/WSTD First Responder Training .................................................................................... 71
5.8.3 VM Training .............................................................................................................................. 71
5.9 Recloser Policy ................................................................................................................................. 71
5.10 Operational / Emergency Response Procedure ................................................................................ 72
5.11 De-energization for Public Safety ..................................................................................................... 73
5.11.1 Impacts on Public Safety .......................................................................................................... 76
5.11.2 Customer Notification Protocols ............................................................................................... 76
5.11.3 Restoration of Service .............................................................................................................. 77
6. STAKEHOLDER OUTREACH AND ENGAGEMENT ............................................................................. 78
6.1 Fire Agency (First Responder) Collaboration .................................................................................... 78
6.2 SFPUC Relationship with PG&E ....................................................................................................... 80
6.3 California Municipal Utilities Association (CMUA) Collaboration ....................................................... 80
7. EVALUATING PERFORMANCE OF THE PLAN .................................................................................... 82
7.1 Metrics and Assumptions for Measuring Plan Performance .............................................................. 82
7.2 Metric 1: Fire Ignitions ................................................................... .................................................. 83
7.3 Metric 2: Wires Down ...................................................................................................................... 83
7.4 Impact of Metrics on Plan ................................................................................................................ 83
7.5 Monitoring and Auditing the Plan ..................................................................................................... 84
iv
7.6 Corrective Action Program ............................................................................................................... 84
7.7 Monitoring the Effectiveness of the Plan .......................................................................................... 84
8. INDEPENDENT EVALUATOR ............................................................................................................... 86
v
ACRONYMS
AGM Assistant General Manager
AI Artificial Intelligence
AVMWP Annual Vegetation Management Work Plan
BLM Bureau of Land Management
BMP Best Management Practice
CAISO California Independent System Operator
CAL FIRE California Department of Forestry and Fire Protection CCSF City and County of San Francisco
Commission San Francisco Public Utilities Commission (SFPUC) Commission CM Corrective Maintenance
CMMS Computerized Maintenance Management System. SFPUC utilizes Maximo (IBM™) as our enterprise CMMS.
CPUC California Public Utilities Commission
CUEA California Utility Emergency Association
C5 Climate Change Collaboration and Coordination Committee e-Logger Electronic Logger used by Hetch Hetchy Water to collect, store, and distribute real-time data about
ESF Emergency Support Functions
ESO Electrical Safety Orders, State of California
FPI Fire Potential Index
FAC-003-4 NERC Reliability Standard: Transmission Vegetation Management FY Fiscal Year
GO CPUC General Order
vi
ACRONYMS
HFT / HFTD High Fire Threat / High Fire Threat District HHWP Hetch Hetchy Water and Power
HHWPP Hetch Hetchy Water and Power Project, or HHWP Project HHW
Hetch Hetchy Water. The Division of Hetch Hetchy Water and Power that is managed by the Water Enterprise. Commonly referred to as Hetch Hetchy Water and Power.
HHZ High Hazard Zone
HRRR NOAA's High-Resolution Rapid Refresh Model
IAP Incident Action Plan
IC Incident Commander
ICS Incident Command System
IE Independent Evaluator
IOU Investor-Owned Utility
ISA International Society of Arboriculture
IVM Integrated Vegetation Management
kV Kilovolt (1,000 volts)
LiDAR Light Detection and Ranging - Survey technology for the evaluation of existing overhead electrical lines
LiveEO Software that provides artificial intelligence satellite observation data specific to infrastructure assets, such as overhead electrical lines.
LTO Licensed Timber Operator
Maximo Maximo (IBM™) SFPUC's enterprise Computerized Maintenance Management System or CMMS
MID Modesto Irrigation District
MVCD Minimum Vegetation Clearance Distance
NEC National Electric Code
vii
ACRONYMS
NERC North American Electric Reliability Corporation
NESC National Electrical Safety Code
NIMS National Incident Management System
NOAA National Oceanic and Atmospheric Administration
NRF National Response Framework
NRLM Natural Resources and Lands Management, a division of the Water Enterprise.
NWS National Weather Service
OEIS
Office of Energy Infrastructure Safety (or Energy Safety) was established on July 1, 2021, to ensure electrical utilities are taking effective actions to reduce utility- related wildfire risk.1
OH Overhead
PAL Project Activity Level
PG&E Pacific Gas & Electric
PIO Public Information Officer
Plan Wildfire Mitigation Plan
PM Preventative Maintenance
POU Publicly Owned Utility
PRC Public Resources Code
PSPS Public Safety Power Shutoff
PUC Public Utilities Code
QEW Qualified Electrical Worker
RAWS Remote Automatic Weather Station – RAWS provides timely local weather data used primarily in fire management
1 https://energysafety.ca.gov/who-we-are/about-energy-safety/
viii
ACRONYMS
RFW
Red Flag Warning – Issued by the National Weather Service when warm temperatures, very low humidity, and stronger winds are forecasted and combined are expected to produce an increased risk of fire danger ROW Right of Way
SCADA Supervisory Control and Data Acquisition
SEMS Standardized Emergency Management System
SFPUC San Francisco Public Utilities Commission
SRA State Responsibility Area
SVWTP Sunol Valley Water Treatment Plant
SWIFT Southwest Interface Team
TRAQ ISA Tree Risk Assessment Qualified
TVMP Transmission Vegetation Management Program
UC Unified Command
USFS United States Forest Service
WMP Wildfire Mitigation Plan
WMRA Wildfire Mitigation & Recovery Analyst
WSAB Wildfire Safety Advisory Board
WSTD Water Supply & Treatment, a division of the Water Enterprise.
SFPUC
2023 Wildfire Mitigation Plan
9 1. EXECUTIVE SUMMARY / INTRODUCTION
The San Francisco Public Utilities Commission’s ( SFPUC) mission is to provide our customers with high-quality, efficient, and reliable power, water, and sewer services in a manner that is inclusive of environmental and community interests and that sustains the resources entrusted to our care.
We adopted the Wildfire Mitigation Plan (WMP or Plan) template recommended by the Wildfire Safety Advisory Board (WSAB) for our 2023 Plan which builds upon the successes and learnings of our previous WMP programs and initiatives and incorporates lessons learned to date from annual WMPs prepared from 2020-2022.
We are committed to building, maintaining, and operating a safer and more resilient electrical grid. SFPUC-owned and operated assets are described in Table 1 which includes transmission and distribution line assets, substations, and hydro generation with a n allocation of assets within and outside the California Public Utilities Commission’s (CPUC) designated High Fire Threat District (HFTD). HFTDs are areas considered to be of elevated or extreme wildfire risk within the State of California where there is a higher risk for power line fires igniting and spreading rapidly.
This WMP addresses the following 17 requirements as identified within the WSAB 2023 Advisory Opinion for Publicly Owned Utilities (POU) (Figure 1).
Figure 1 – WSAB WMP Requirements
10 1.1 Utility Description and Context Setting Table
The SFPUC, a department of the City and County of San Francisco (CCSF), provides power to the residents and businesses of San Francisco through the CleanPowerSF2 (Community Choice Aggregation) program and serves CCSF municipal load through Hetch Hetchy Power. Additionally, the SFPUC provides retail drinking water and wastewater services to the City of San Francisco and wholesale water to three Bay Area counties.
The SFPUC is comprised of six business functions, or enterprises, including the Water Enterprise. The Water Enterprise has six divisions, including HHW, Water Supply & Treatment Division (WSTD), and Natural Resources and Lands Management (NRLM) (Figure 3). Each of these divisions has defined responsibilities for managing and maintaining the electrical assets described in this Plan. The Water Enterprise is responsible for the development, execution, and oversight of this WMP.
The HHW, WSTD, and NRLM divisions of the Water Enterprise maintain and operate assets from Hetch Hetchy Reservoir in Yosemite National Park to the CCSF County line. HHW is responsible for managing, operating, and maintaining the Hetch Hetchy Water and Power (HHWP) Project. The HHWP Project consists of power generation facilities, electric transmission and distribution assets, water storage and conveyance systems, roads, bridges, and ancillary facilities. These assets originate at the Hetch Hetchy Reservoir, located in Yosemite National Park, traverse the counties of Tuolumne, Mariposa, Stanislaus, and San Joaquin, and span to the East Bay communities of Sunol and Newark in Alameda County. WSTD is responsible for managing, operating, and maintaining the Bay Area portion of the System which includes water storage, treatment, and water transmission facilities in Alameda and San Mateo counties. The SFPUC owns the watersheds above reservoirs in Alameda and San Mateo counties. NRLM Division is responsible for managing, operating, and maintaining these watersheds.
2 https://www.cleanpowersf.org/
11 The HHWP Project consists of four hydroelectric powerhouses (generator facilities) .
HHWP transmits this power through SFPUC-owned and operated 230kV and 115 kV transmission lines to the California electric grid. The SFPUC transmits this power through SFPUC-owned and operated transmission lines to the California electric grid.
A portion of the transmission facilities are within Pacific Gas & Electric’s (PG&E) and Modesto Irrigation District’s (MID) service territory. A detailed breakdown of overhead lines in the HFTD is included in Table 1.
The SFPUC owns, operates, and maintains distribution lines operated at various voltage levels
with distribution lines providing service to SFPUC-owned and operated facilities. Ad ditionally, a small number of the SFPUC distribution facilities located within PG&E’s service territory are connected to PG&E’s primary distribution circuits.
HHW manages, operates, and maintains the distribution lines within the HHWP Project. WSTD and NRLM manage, operate, and maintain distribution lines that serve SFPUC water treatment plants and facilities within SFPUC watersheds in the Bay Area. Detailed overhead circuit miles in the HFTD are included in Table 1.
Table 1 – Context Setting Table SFPUC
Utility Name
San Francisco Public Utilities Commission
All line lengths are defined as circuit miles
Service Territory Size The SFPUC is primarily a generation (hydro) and transmission provider. The SFPUC has no defined “service territory” with boundaries like a traditional utility serving distribution load.
Owned Assets Transmission, Distribution, and Generation Number of Customers
Served
Two (2) customer accounts served from a distribution line in Tier 2 High Fire Threat District (HFTD) and one (1) in the non-HFTD.
Population Within Service
Territory
N/A
Customer Class Makeup
Number of Accounts Share of Total Load (MWh)
0% Residential;
0% Government;
0% Agricultural;
100% Small/Medium Business;
0% Commercial/Industrial
N/A
12 Utility Name
San Francisco Public Utilities Commission
All line lengths are defined as circuit miles
Service Territory
Location/Topography3
4% Agriculture
27% Barren/Other
25% Conifer Forest
0% Conifer Woodland
0% Desert
3% Hardwood Forest
16% Hardwood Woodland
18% Herbaceous
0% Shrub
7% Urban
0% Water
Service Territory
Wildland Urban Interface4
(based on total area)
1% Wildland Urban Interface;
1% Wildland Urban Intermix;
The percentages above refer to overhead transmission and distribution line miles.
3 This data was determined by using the California Department of Forestry and Fire Protection, California Multi-Source Vegetation Layer Map, depicting WHR13 Types (Wildlife Habitat Relationship classes grouped into 13 major land cover types) available at:
https://www.arcgis.com/home/item.html?id=b7ec5d68d8114b1fb2bfbf4665989eb3 . 4 This data was determined by using the definitions and maps maintained by the United States Department of Agriculture, as most recently assembled in The 2010 Wildland-Urban Interface of the Conterminous United States, available at https://www.fs.usda.gov/nrs/pubs/rmap/rmap_nrs8.pdf
13 Utility Name
San Francisco Public Utilities Commission
All line lengths are defined as circuit miles
Prevailing Wind Directions
& Speeds by Season
Generally, the coast range has higher average wind speeds throughout the year, which are typically west, with strong east wind events in the winter. The Central Valley typically has lower average wind speeds, with a predominantly west direction. The mountain region has moderate average wind speeds, also typically west, with very strong east (Mono) wind events in the winter. In the table below, winter is considered from October-April and summer from May- September.
Average Max
Region Season Wind
Speed
(mph)
Direction Wind
Speed
(mph)
Direction
Coast
Range
Winter 30 W 60 E
Summer 20 W 30 W
Central
Valley
Winter 10 W 20 E
Summer 5 W 10 W
Sierra
Nevada
Foothills
Winter 15 W 70 E
Summer 15 W 20 W
Miles of Owned Lines
Underground and/or
Overhead
Overhead Dist.: 57.8 miles
Overhead Trans.: 162.5 miles
Underground Dist.: 4.0 miles
Underground Trans.: 0 miles
Explanatory Note 1 - Methodology for Measuring “Miles”: [e.g., circuit miles, line miles.] Circuit Miles
Explanatory Note 2 – Description of Unique Ownership Circumstances:
The following distribution lines are where the SFPUC interconnects to PG&E lines from SFPUC facilities. Bay Area region: San Andreas Lake Line, Pilarcitos Line, Sawyer Camp Line, Crystal Springs Line, Pulgas Line. Central Valley region: San Joaquin Valve House and Tesla Portal Line.
Overhead Distribution Lines as % of Total Distribution System
14 Utility Name
San Francisco Public Utilities Commission
All line lengths are defined as circuit miles
Percent of Owned Lines in
CPUC High Fire Threat
Districts (percentages
reflect overhead line
length).
(Inside and Outside Service Territory)
Tier 2 Distribution: 75%
Tier 3 Distribution: 6%
Non-HFTD: 19%
Overhead Transmission Lines as % of Total
Transmission System
(Inside and Outside Service Territory)
Tier 2 Transmission: 26%
Tier 3 Transmission: 2%
Non-HFTD: 72%
Explanatory Note 4 – Additional Relevant Context: [e.g., explain any difference from data reported in WMP due to different numerator used for this form] Customers have ever lost
service due to an IOU
Public Safety Power Shutoff
Event (PSPS)?
Yes
Yes, SFPUC-owned, and operated facilities have been impacted. However, PG&E PSPS events do not interrupt the SFPUC’s ability to supply power and water services. The SFPUC has backup generators for water treatment plants.
The purpose of the SFPUC’s power transmission line system is to deliver generation produced by the HHWP Project to the electric grid. The SFPUC transmission lines also feed one of two SFPUC water treatment plants. In the event the SFPUC had to de-energize the transmission lines that feed this water treatment plant, the portion of the transmission system outside of the HFTD would still be back fed from the electrical grid (PG&E).
Customers have ever been
notified of a potential loss of
service due to a forecasted
IOU PSPS event?
Yes
The SFPUC interconnects to PG&E lines as described above in the unique ownership circumstances section. The SFPUC is notified by PG&E before a PSPS event. The SFPUC has been assigned a PG&E representative. Both the SFPUC and PG&E have shared area contact representatives.
Has developed protocols to
pre-emptively shut-off
electricity in response to
elevated wildfire risks?
Yes
See Section 5.11
Has previously preemptively
shut off electricity in
response to elevated
wildfire risk?
Yes, refer to Section 5.11 for de-energization protocols.
If yes, then provide the following data for the calendar year 2022:
Number of shut-off events: 0
Customer Accounts that lost service for >10 minutes: 0
For prior response, average duration before service restored: N/A
15 1.1.1 Statutory Cross-Reference Table
Our Plan complies with the PUC § 8387 statutory requirements listed in Table 2. Table 2 also provides a reference to where the requirement is described in the Plan (Plan Section).
Table 2 – PUC § 8387 Statutory Requirements Checklist
PUC 8387
Code Compliance Requirements and Corresponding Plan Sections Plan Section
(a) Each local publicly owned electric utility and electrical cooperative shall construct, maintain, and operate its electrical lines and equipment in a manner that will minimize the risk of wildfire posed by those electrical lines and equipment.
All
(b)(1) The local publicly owned electric utility or electrical cooperative shall, before January 1, 2020, and annually thereafter, prepare a wildfire mitigation plan. After January 1, 2020, a local publicly owned electric utility or electrical cooperative shall prepare a wildfire mitigation plan annually and shall submit the plan to the California Wildfire Safety Advisory Board on or before July 1 of that calendar year. Each local publicly owned electric utility and electrical cooperative shall update its plan annually and submit the update to the California Wildfire Safety Advisory Board by July 1 of each year.
At least once every three years, the submission shall be a comprehensive revision of the plan.
1.2 &
1.4 (b)(2) The wildfire mitigation plan shall consider as necessary, at minimum, all of the following:
(b)(2)(A) An accounting of the responsibilities of persons responsible for executing the plan.
3 (b)(2)(B) The objectives of the wildfire mitigation plan. 2 (b)(2)(C) A description of the preventative strategies and programs to be adopted by the local publicly owned electric utility or electrical cooperative to minimize the risk of its electrical lines and equipment causing catastrophic wildfires, including consideration of dynamic climate change risks.
5 16
PUC 8387
Code Compliance Requirements and Corresponding Plan Sections Plan Section
(b)(2)(D) A description of the metrics the local publicly owned electric utility or electrical cooperative plans to use to evaluate the wildfire mitigation plan’s performance and the assumptions that underlie the use of those metrics.
7.3 (b)(2)(E) A discussion of how the application of previously identified metrics to previous wildfire mitigation plan performances has informed the wildfire mitigation plan.
7 (b)(2)(F) Protocols for disabling reclosers and deenergizing portions of the electrical distribution system that consider the associated impacts on public safety, as well as protocols related to mitigating the public safety impacts of those protocols, including impacts on critical first responders and on health and communication infrastructure.
5.9 &
5.11 (b)(2)(G) Appropriate and feasible procedures for notifying a customer who may be impacted by the de-energizing of electrical lines. The procedures shall direct notification to all public safety offices, critical first responders, health care facilities, and operators of telecommunications infrastructure with premises within the footprint of potential de-energization for a given event.
5.11.2 (b)(2)(H) Plans for vegetation management. 5.4
(b)(2)(I) Plans for inspections of the local publicly owned electric utility’s or electrical cooperative’s electrical infrastructure.
5.5 (b)(2)(J) A list that identifies describes, and prioritizes all wildfire risks, and drivers for those risks, throughout the local publicly owned electric utility’s or electrical cooperative’s service territory. The list shall include, but not be limited, to both of the following:
4 (b) (2)(J)(i) Risks and risk drivers associated with design, construction, operation, and maintenance of the local publicly owned electric utility’s or electrical cooperative’s equipment and facilities.
4.3 (b)(2)(J)(ii) Particular risks and risk drivers associated with topographic and climatological risk factors throughout the different parts of the local publicly owned electric utility’s or electrical cooperative’s service territory.
4.2 17
PUC 8387
Code Compliance Requirements and Corresponding Plan Sections Plan Section
(b)(2)(K) Identification of any geographic area in the local publicly owned electric utility’s or electrical cooperative’s service territory that is a higher wildfire threat than is identified in a commission fire threat map, and identification of where the commission should expand a high-fire threat district based on new information or changes to the environment.
4.4 (b)(2)(L) A methodology for identifying and presenting enterprise-wide safety risk and wildfire-related risk.
4.1 (b)(2)(M) A statement of how the local publicly owned electric utility or electrical cooperative will restore service after a wildfire.
5.11.3 (b)(2)(N) A description of the processes and procedures the local publicly owned electric utility or electrical cooperative shall use to do all of the following:
(b)(2)(N)(i) Monitor and audit the implementation of the wildfire mitigation plan. 7.5 (b)(2)(N)(ii) Identify any deficiencies in the wildfire mitigation plan or its implementation and correct those deficiencies.
7.6 (b)(2)(N)(iii) Monitor and audit the effectiveness of electrical line and equipment inspections, including inspections performed by contractors, that are carried out under the plan, other applicable statutes, or commission rules.
7.7 (3) The local publicly owned electric utility or electrical cooperative shall, on or before January 1, 2020, and not less than annually thereafter, present its wildfire mitigation plan in an appropriately noticed public meeting. The local publicly owned electric utility or electrical cooperative shall accept comments on its wildfire mitigation plan from the public, other local and state agencies, and interested parties, and shall verify that the wildfire mitigation plan complies will all applicable rules, regulations, and standards, as appropriate.
1.2 18
PUC 8387
Code Compliance Requirements and Corresponding Plan Sections Plan Section
(3)(c) (c) The local publicly owned electric utility or electrical cooperative shall contract with a qualified independent evaluator with experience in assessing the safe operation of electrical infrastructure to review and assess the comprehensiveness of its wildfire mitigation plan.
The independent evaluator shall issue a report that shall be made available on the internet website of the local publicly owned electric utility or electrical cooperative and shall present the report at a public meeting of the local publicly owned electric utility’s or electrical cooperative’s governing board.
8 1.2 Process for Utility Adoption and Submittal of Annual WMP and Opportunities for Public Comment
This Plan, at minimum, meets the requirements of PUC § 8387 for POUs. The public can comment on the WMP during a scheduled SFPUC Commission meeting, in which the Commission will review the WMP. The SFPUC Commission Secretary publishes all upcoming Commission agendas to the sfpuc.org website a week before the Commission meeting date. Additionally, each agenda item has time set aside for public comment. The SFPUC Commission and staff will consider all public comments for inclusion in the final version of the Plan. The meeting agenda includes a link to watch the meetings live and a public comment call-in number to ensure the public has an opportunity to comment on agenda items. The final approved WMP will be submitted to the WSAB and posted to the SFPUC website, which also includes prior years' WMPs and the independent evaluator (IE) report(s). The SFPUC had our initial WMP reviewed by an IE in 2020 and posted the IE Report on the SFPUC website. The SFPUC will have an IE review the 2023 Plan and the IE report will be posted to the SFPUC external-facing website accessible to the public.
1.3 Wi ldfire Mitigation Funding
HHWP’s Operating Budget for Fiscal Years (FY) 2022-23 & 2023-24 includes
19 funding for wildfire mitigation initiatives and activities including vegetation management and tree-removal contracts, LiDAR flights to help gather and analyze data for potential threats to select overhead transmission and distribution system areas, and funding for software and wildfire-related equipment.
Concurrent with the Operating Budget, is the FY 2022- 23 & 2023-24 Capital Budget and Ten-Year Capital Plan. HHWP’s Capital Budget for FY 2022-23 & 2023-24 and Ten-Year Capital Plan includes investments in infrastructure projects intended to reduce the risk of wildfire as summarized below:
HHW-Renewal & Replacement (R&R) Wildfire Mitigation (Power) - This project funds wildfire mitigation vegetation management projects, including fuel breaks and Integrated Vegetation Management (IVM) projects to protect assets classified as “Power” only. The project does not fund annual vegetation management plans. Total Approved Budget: $11,916,227.
HHW- R&R Power Distribution Line High-Risk Fire Reduction – This project funds inspections, condition assessments, studies, designs, renewal and replacement, and construction of new microgeneration assets. Total Approved Budget: $4,976,976.
The full “FY 2022- 2023 & FY 2023- 2024 Adopted Budget” report is available on the SFPUC website
5. 1.4 Description of Where WMP Information Can be Found on the SFPUC Website
The approved SFPUC WMP and IE reports are posted on the SFPUC public-facing website6. At this site, the public can also view the previous year’s SFPUC WMPs and IE report(s).
5 https://sfpuc.org/about-us/reports/operating-and-capital-budgets 6 https://www.sfpuc.org/about-us/policies-plans/wildfire-mitigation-plan
20 1.5 Purpose of the Wildfire Mitigation Plan
This Plan provides a comprehensive overview of the SFPUC programs and initiatives to minimize the risk that SFPUC electrical assets are the origin or contributing source of a catastrophic wildfire. Additionally, it is the goal of the SFPUC to maintain compliance with our statutory obligation as specified in California PUC § 8387(a) which requires each local publicly owned electric utility and electrical cooperative to:
“Construct, maintain, and operate its electrical lines and equipment in a manner that will minimize the risk of wildfire posed by those electrical lines and equipment. After January 1, 2020, each POU shall prepare a wildfire mitigation plan annually and shall submit the plan to the California Wildfire Safety Advisory Board (WSAB) on or before July 1 of that calendar year.
Each POU shall update its plan annually and submit the update to the WSAB by July 1 of each year. At least once every three years, the submission shall be a comprehensive revision of the plan”.
The SFPUC’s primary objectives outlined in this WMP are to support our plan to construct, maintain, and operate our electrical facilities in a manner that minimizes the risk that SFPUC-owned and operated equipment is the origin or contributing source for a catastrophic wildfire; and to provide for a more resilient and reliable grid.
The SFPUC has complied with the statutory obligation regarding the annual submission of our WMP as required by PUC § 8387(b)(1) and now submits our 2023 WMP to the WSAB. This 2023 comprehensive Plan revision includes a narrative on how the Plan has matured over the past three years (2020-2023), Plan updates, and Plan revisions to the SFPUC initiatives and programs, a brief forecast of how the SFPUC plans to mature our wildfire mitigation programs for this next 2023-2025 Plan updates, and an IE assessment and report on the Plan. This Plan is subject to public review and comments before final Plan approval by the SFPUC Commission.
21 1.6 Organization of the Wildfire Mitigation Plan
This Plan includes the following elements:
Section 1 – Executive Summary / Introduction
Section 2 – Objectives of the Wildfire Mitigation Plan
Section 3 – Roles and responsibilities
Section 4 – Wildfire Risk and Risk Drivers
Section 5 – Wildfire Preventative Strategies
Section 6 – Stakeholder Outreach and Engagement
Section 7 – Evaluating Performance of the Plan
Section 8 – Independent Evaluator
1.7 Summary of Wildfire Mitigation Activities from 2020–2022
1.7.1 Risk Assessment
In 2022, our most significant advancement in understanding and evaluating wildfire risk within our areas of operation was to procure Technosylva’s Wildfire Analyst™7 (Wildfire Analyst™) application. Technosylva is a leading provider of “advanced Geographic Information System (GIS) - enabled software solutions for wildfire protection planning and operational response, as well as firefighter and public safety”. Technosylva is used by CAL FIRE, the CPUC, and most of California’s investor-owned utilities (IOU). The Wildfire Analyst™ performs a risk analysis on each SFPUC asset and generates a daily Fire Potential Index (FPI) rating for that asset. Additionally, it generates four different consequence risk metrics if an ignition were to occur at a specific asset. The four consequence risk metrics are (1) Fire Size Potential, (2) Population Impacted, (3) Buildings Threatened, and (4) Estimated Number of Buildings Destroyed. Hetch Hetchy Water (HHW) will be working to integrate this tool as a pilot project in the third quarter of 2023 to support the field operation's daily work schedules and inform
7 https://technosylva.com/products/wildfire-analyst/
22 personnel of areas of risk and if any operating restrictions should be implemented.
Once the tool is operationalized within HHW, staff will work to implement this for the Natural Resources and Lands Management (NRLM) and Water Supply and Treatment Division (WSTD) of the SFPUC Water Enterprise (WE).
The Wildfire Analyst™ application is explained in detail in Section 5.1.1.
1.7.2 Situational Awareness
From 2020-2022, we continued to improve our situational awareness capabilities.
We installed one SFPUC-owned weather station to monitor wind, air temperature, and relative humidity near a distribution line segment in the Tier 2 HFTD. We also collaborated closely with PG&E to gain access to their weather stations that are situated near SFPUC assets. These weather stations combined provide us the ability to monitor weather conditions near our assets throughout the entire area where SFPUC-owned and operated assets are located.
Using Wildfire Analyst™, we now have access to an integrated view of weather stations and High-Definition cameras. Many of these cameras point in the direction of our assets and will help in quickly identifying hazardous conditions that could impact our operations. Additionally, we now have access to real-time active fire incident information for fires that could threaten our assets. The application will also overlay alerts from the National Weather Service, such as Extreme Fire Danger, Extreme Wind Warnings, Red Flag Warnings, and Excessive Heat Warnings on the base map.
1.7.3 Vegetation Management
In 2022, the Vegetation Management Right of Way (VM ROW) Department implemented a data collection system for tracking vegetation trends. This includes the use of a dashboard to track vegetation inspection progress as well as the tree type and trim required (Figure 12). Using the internal E-Logger system, HHW has begun tracking trends in power disruptions caused by vegetation. This allows the
23 division to make better decisions regarding vegetation management based on historical outage information. LiveEO will also be providing us with a satellite analysis of our electrical lines concerning vegetation. More detail on the LiveEO product is provided in Section 5.4.8. The ROW Department is planning on using that data to assure compliance, identify areas of potential tree work, and inform future trim needs.
1.7.4 Construction, Operations, and Maintenance
In 2020-2022, HHW initiated the following capital improvement projects related to wildfire mitigation:
Moccasin Fire Mitigation Project - This project rehabilitated the Priest Reservoir area after the 2020 Moccasin Fire, which consumed over 2,500 acres including approximately 50 acres within the Priest Reservoir basin. The project removed hazard trees, constructed silt fencing, installed waddles, placed straw, and spread hydro-seed/mulch. The project also rehabilitated access roads servicing the reservoir to improve drainage and reduce cross-slope erosion. The project was completed in October 2020.
A project to upgrade the Fire Suppression System in two HHW powerhouses located in the HFTD is currently in the planning stage. In the 2023-2025 Plan updates, we will provide progress reports on the status of this project.
1.7.5 Wildfire Mitigation and Recovery Analyst Position In 2020, HHW established the Wildfire Mitigation & Recovery Analyst (WMRA) position to oversee the overall development and maintenance of the SFPUC WMP.
The WMRA is the lead of an internal SFPUC team that has responsibility for reviewing the ongoing status of our wildfire mitigation programs and monitoring the effectiveness of the Plan. This team meets monthly, or as required. The WMRA is also the primary SFPUC liaison with the California Municipal Utilities Association (CMUA) for all wildfire mitigation discussions.
24 1.7.6 Planned Initiatives for the 2023–2025 WMPs
The 2023-2025 SFPUC WMP programs and initiatives are built upon leveraging the successes and lessons learned during the 2020-2022 Plan updates. Our primary goal continues to be to construct, operate, and maintain a safe and resilient electrical grid and continue to minimize the risk that our assets are not the origin or contributing source for a catastrophic wildfire.
Our primary initiatives during the 2023-2025 Plans are to:
1. Maintain compliance with PUC § 8387 and continue to mature our wildfire mitigation initiatives.
2. Complete the implementation and operationalize the Wildfire Analyst™ risk modeling software.
3. Leverage the Wildfire Analyst™ risk analysis tools to develop a more comprehensive risk-informed wildfire mitigation program.
4. Continue to track metrics to inform the SFPUC on how the WMP programs and initiatives are performing.
5. Evaluate and assign priorities to system hardening options and create implementation time frames.
25 2. OBJECTIVES OF THE WILDFIRE MITIGATION PLAN
This Plan details the initiatives and programs the SFPUC is undertaking or evaluating to reduce the risk of SFPUC assets being the origin or contributing source for catastrophic wildfires. This comprehensive Plan revision continues to build upon the 2020-2022 WMP programs and initiatives focusing on three primary objectives as listed below. Additionally, it is the goal of the SFPUC to maintain compliance with our statutory obligation as specified in PUC § 8387(a).
2.1 Minimizing Sources of Ignition
The first objective is to continue to evaluate prudent and cost-effective improvements to our physical assets, operations, and training to minimize the risk of SFPUC assets being the origin or contributing source for a catastrophic wildfire.
Programs being evaluated or currently implemented include, but are not limited to, evaluating strategic system hardenings, such as increased situational awareness capabilities by adding more strategically placed weather stations and leveraging the existing California network of high-definition mountaintop cameras: evaluating enhanced vegetation management opportunities; and proactive de-energization of lines during critical fire weather conditions. We will continue to evaluate wildfire risk reduction tools, processes, and utility best practices, and implement them over time through Plan evaluation and metric analysis.
2.2 Improve Grid Reliability and Resiliency
The second objective of the SFPUC’s wildfire mitigation programs and initiatives is to improve the reliability and resiliency of the SFPUC-owned and operated electric facilities. In addition to reducing wildfire ignition risks, programs such as grid hardening, and enhanced vegetation management provide additional benefits such as improved reliability and resiliency. We will continue to assess industry best practices and new technologies that could help reduce the likelihood of a disruption in service due to planned or unplanned events and expedite grid recovery efforts following a significant event, such as a wildfire.
26 2.3 Measuring Plan Effectiveness
The third objective of the SFPUC’s wildfire mitigation programs and initiatives is to measure the effectiveness and performance of the programs and initiatives as described in this Plan. We will monitor the performance of our Plan, such as a continued decline in equipment failures or vegetation contacts and make Plan modifications as necessary to improve the safety, reliability, and resiliency of the SFPUC system. This Plan will also help determine if more cost-effective measures could produce the same or better results to reduce the risk of SFPUC electrical assets being the origin or contributing source of a catastrophic wildfire.
27 3. ROLES AND RESPONSIBILITIES
3.1 POU Organizational Chart and Specific Responsibilities.
This section identifies the SFPUC management staff responsible for the development, approval, and implementation of this Plan and lists, in Figure 3, the operating departments accountable for carrying out the various activities described in the Plan.
During the 2020-2022 Plan updates HHW assigned a WMRA position to oversee the overall development and maintenance of the Plan. The WMRA is the lead of an internal SFPUC team that has responsibility for reviewing and monitoring the progress of the SFPUC wildfire mitigation programs and monitoring the effectiveness of the Plan. This team meets monthly, or as required. The WMRA is also the primary SFPUC liaison with the CMUA for all wildfire mitigation discussions. • The SFPUC Commission has the responsibility for approving this Plan. • The SFPUC Assistant General Manager (AGM) of the Water Enterprise has overall accountability for developing and implementing the Plan.
Figure 3 – SFPUC Organizational Chart
28 Table 3 – Plan Activities Roles and Responsibilities
Activity
HHW Division: All SFPUC
Transmission Facilities; and
Distribution Facilities Located
within Tuolumne, Stanislaus,
Mariposa, and San Joaquin
Counties
WSTD and NRLM Divisions:
Distribution Facilities Located in
Alameda and San Mateo
Counties
Transmission Line Vegetation
Clearance Inspections
HHW Right of Way Manager; and
Vegetation Manager N/A
Distribution Line Vegetation
Clearance Inspections
HHW Right of Way Manager; and
Vegetation Manager
NRLM and Peninsula Area
Manager
Vegetation Management and
Removal
HHW Operations and Maintenance
Manager NRLM Manager
Transmission Asset Inspections
Transmission Line Maintenance
HHW Power Generation &
Transmission Manager N/A
Distribution Asset Inspections HHW Power Generation &
Transmission Manager
HHW Power Generation &
Transmission Manager
Distribution Line Operations and
Maintenance Inspections
HHW Power Generation &
Transmission Manager
WSTD Maintenance Section
Manager and HHW Power
Generation & Transmission
Manager
Substation Inspections Recloser
Policy and De-energization
HHW Operations and Maintenance
Manager
HHW Operations and Maintenance
Manager
Plan Coordination and Updates WMRA
Plan Review
HHW Division Manager; CCSF City
Attorney’s Office; and SFPUC
Assistant General Manager of
Water
NRLM Division Manager, WSTD
Division Manager, CCSF City
Attorney’s Office; and SFPUC
Assistant General Manager of
Water
Plan Approval SFPUC Commission SFPUC Commission
SFPUC utility staff have the following responsibilities regarding fire prevention, response, and investigation:
• Conduct work in a manner that will minimize the risk of ignition for a utility-caused wildfire.
• Take all reasonable and practicable actions to prevent and suppress fires resulting from SFPUC electric facilities.
• Coordinate with federal, state, and local fire management personnel to ensure that appropriate preventative measures are in place.
• Immediately report fires, pursuant to specified procedures. • Take corrective action when observing or having been notified that fire protection measures have not been properly installed or maintained. • Ensure compliance with relevant federal, state, and industry-standard
29 requirements.
• Ensure that relevant incident data is appropriately and timely collected when a utility asset was the cause or contributing source for the ignition of the wildfire. • Ensure that evidence is appropriately preserved when a utility asset was the cause or contributing source for the ignition of the wildfire. • Maintain adequate wildfire mitigation training programs for all relevant employees and, if applicable, SFPUC contractors.
3.2 Coordination with Critical Infrastructure Providers The US Cybersecurity & Infrastructure Security Agency states that “There are 16 critical infrastructure sectors whose assets, systems, and networks, whether physical or virtual, are considered so vital to the United States that their incapacitation or destruction would have a debilitating effect on security, national economic security, national public health or safety, or any combination thereof” 8 The SFPUC considers all CIP sectors of critical importance to the safety and health of our SFPUC employees, and communities that could be impacted by an event impacting SFPUC assets. Coordination activities between SFPUC and the following sectors is described in the sections:
• Water and Wastewater Systems sector.
• Communications sector.
• Healthcare and Public Health sector.
3.3 Coordination with Water Utilities/Department
The SFPUC does not provide electric service to any non-SFPUC owned and operated water department customers, nor does it impact any non-SFPUC-owned and operated water facilities. All SFPUC-owned and operated water facilities have redundant power supplies to maintain operations during a planned or unplanned power outage. Internal SFPUC communications during emergencies are described
8 https://www.cisa.gov/critical-infrastructure-sectors
30 in the SFPUC Emergency Operations Plan.
3.4 Coordination with Communication Infrastructure Providers The SFPUC supplies power to two cellular towers owned and operated by an independent wireless provider. During planned or unplanned interruptions of the SFPUC lines that could impact these cellular sites, the SFPUC will communicate with the wireless provider on the expected timing and duration of the outage. Both sites have backup generators to avoid disruption to services during planned and unplanned outages.
3.5 Coordination with Healthcare and Public Health sector / Hospitals Not applicable. The SFPUC does not provide service to any public health facilities.
3.6 Standardized Emergency Management System
The SFPUC has staff that are trained to fulfill certain roles under the Incident Command System (ICS) and can be integrated into an ICS structure. The SFPUC is Standardized Emergency Management System (SEMS) and National Incident Management System (NIMS) compliant and, utilizes the ICS structure to respond to local and regional emergencies.
Currently, the SFPUC does not initiate our ICS structure during Red Flag Warnings.
When critical fire weather is forecasted, the powerhouse control center will dispatch Qualified Electrical Workers to patrol power lines and standby for potential de- energization. The control center stays in constant communication with SFPUC management regarding changing weather conditions to monitor for and execute a de-energization event if those triggers are met.
3.7 Mutual Assistance Agreements
During wildfire events, the SFPUC assigns a Liaison Officer to coordinate with emergency response agencies and local government agencies. If the wildfire is near SFPUC assets, an Incident Command Post or Emergency Operations Center is
31 opened, and an ICS organization is used to manage the operational periods of the event.
The SFPUC is a member of the California Utility Emergency Association (CUEA), which plays a key role in ensuring communications between utilities during emergencies. The SFPUC also participates in the Western Energy Institute’s Western Region Mutual Assistance Agreement, which is a mutual assistance agreement covering utilities across several Western states.
SFPUC
2023 Wildfire Mitigation Plan
32 4. WILDFIRE RISKS AND RISK DRIVERS
The Office of Energy Infrastructure Safety (OEIS) defines risk as “a measure of the anticipated adverse effects from a hazard considering the consequences and frequency of the hazard occurring.”
4.1 Enterprise-Wide Safety Risks
In the 2020-2022 WMPs the SFPUC’s risk evaluation approach leveraged the institutional knowledge of our personnel familiar with the historical events that previously impacted our operations. Our risk reduction approach was designed to meet the requirements of industry-recognized standards (i.e., CPUC GOs, NERC Operating Standards, NESC Codes), and best practices utilized by other utilities with more mature wildfire mitigation programs.
For the 2023-2025 annual WMPs, we plan to develop and formalize our risk evaluation approach to minimize the risk that our assets could be the origin or contributing source for a catastrophic wildfire.
In Q4 of 2022, the SFPUC procured the Wildfire Analyst™ application to support our operations and planning groups as described in Section 5.1.1. The Wildfire Analyst™ will be the foundational tool for identifying risks and predicting potential consequences and will support prioritizing risk reduction measures. The goal is to have this application fully functional and operational by Q4 of 2023.
4.2 R isks and Risk Drivers Associated with Topographic and Climatological Risk Factors
We own electrical assets in higher elevations of the Sierra Nevada Mountain range, through the San Joaquin Valley, and into the lower elevation San Francisco Peninsula region.
Our primary topographic and climatological risk drivers identified for wildfire risk are:
33 • Extended drought,
• Lack of early fall rains,
• Hot temperatures,
• High winds,
• Steep terrain, and
• Vegetation type and density.
4.3 Risks and Risk Drivers Associated with Design, Construction, Operations and Maintenance
The SFPUC does not experience a high volume of risk events that could be the source of ignition for a catastrophic wildfire. HHW tracks planned and unplanned overhead transmission outages through E-Logger. In early 2023, HHW started using E-Logger to track planned and unplanned outages on the HHW distribution lines. We intend to develop a method of tracking planned and unplanned outages for the WSTD distribution lines in late 2023 or early 2024. We will then use this information to track causes and identify and trends throughout the SFPUC system.
The SFPUC has identified vegetation contact as our number one risk. In 2020 and 2021 the SFPUC experienced two separate incidents where a tree fell and contacted SFPUC distribution facilities that resulted in an ignition for a wildfire. The SFPUC conducted a root cause analysis and identified additional risks which resulted in removing other trees (additional detail provided in Section 7.3).
Our maintenance programs contribute to minimizing the risk of equipment failure.
Other programs to improve system reliability and reduce wildfire risk include replacing CAL FIRE non-exempt equipment with CAL FIRE approved exempt equipment, transformer replacement program, and brush clearing to comply with Public Resources Code (PRC) § 4292. These programs and other initiatives are further described in Section 5.
34 4.4 High Fire Threat District
The SFPUC participated in the development of the CPUC’s Fire-Threat Map9 which designates a High-Fire Threat District (HFTD) (Figure 4). The CPUC describes the HFTD as follows:
1. Tier 1 High Hazard Zones (HHZs) on the U.S. Forest Service-CAL FIRE joint map of Tree Mortality HHZs ("Tree Mortality HHZ Map").
a. The Tree Mortality HHZ Map is an off-the-shelf map. Tier 1 HHZs are zones near communities, roads, and utility lines, and are a direct threat to public safety.
2. Tier 2 and Tier 3 fire-threat areas on the CPUC Fire-Threat Map. a. Tier 2 fire-threat areas outline areas where there is an elevated risk (including likelihood and potential impacts on people and property) from utility-related wildfires.
b. Tier 3 fire-threat areas outline areas where there is an extreme risk (including likelihood and potential impacts on people and property) from utility-related wildfires.
In the map development process, the SFPUC reviewed the proposed boundaries of the fire-threat areas and confirmed that, based on local conditions and historical fire data. All our assets are located within the proper fire-threat area (Figure 5).
9 https://www.cpuc.ca.gov/industries-and-topics/wildfires/fire-threat-maps-and-fire-safety-rulemaking
35 Figure 4 – CPUC High Fire-Threat District Map
SFPUC
2023 Wildfire Mitigation Plan
36 Figure 5 – SFPUC Electrical Assets and HFTDs
SFPUC
2023 Wildfire Mitigation Plan
37 4.5 Changes to CPUC Fire Threat Map
The SFPUC has not identified any areas near our electrical assets that are of higher wildfire threat than is identified in the CPUC fire threat map.
For the 2023-2025 Plan updates the SFPUC agrees with the existing CPUC HFTD boundaries and makes no recommendation for expanding or minimizing the current HFTD.
4.6 Climate Change/ Weather Risks
The National Oceanic and Atmospheric Administration10 (NOAA) describes climate change as, “Any significant change in the measures of climate for extended periods of time, usually over decades or longer. This includes major, long-term changes in temperature, precipitation, humidity, ocean heat, wind patterns, sea level, sea ice extent, and other factors, and how these changes affect life on Earth.” NOAA also states that “Global temperatures rose about 1.98°F (1.1°C) from 1901 to 2020, but climate change refers to more than an increase in temperature. It also includes sea level rise, changes in weather patterns like drought and flooding, and much more. Things that we depend upon and value — water, energy, transportation, wildlife, agriculture, ecosystems, and human health — are experiencing the effects of a changing climate.”
The SFPUC Climate Change Collaboration and Coordination Committee (C5) was established in 2018 to develop, coordinate, and communicate a comprehensive and consistent approach to mitigating and adapting to climate change. The SFPUC continues to evaluate climate studies and findings of the C5 to assess potential impacts to areas and our electrical assets in the HFTD.
The C5 membership includes representatives from most departments within the
10 https://www.noaa.gov/explainers/what-s-difference-between-climate-and-weather
38 SFPUC. The committee meets bi-monthly11 to develop a strategy to ensure climate change threats and impacts are considered and addressed in utility operations, capital programs, and long-term planning. C5 has created a climate change policy that establishes the following goals:
1. Reduce greenhouse gas emissions in alignment with City-wide climate change goals.
2. Assess vulnerability and adapt to ensure long-term resilience.
3. Evaluate climate change and its impact on the level of service goals.
4. Respond to the threats and impacts of climate change to address the disproportionate effects on environmental justice and low-income communities.
5. Protect and enhance the resilience and health of watershed ecosystems and lands affected by climate change and SFPUC activities.
6. Include climate adaptation and mitigation in capital planning and project selection criteria.
7. Communicate transparently and proactively with stakeholders on climate change and the SFPUC’s adaptation and mitigation strategies.
8. Integrate climate change response across SFPUC divisions and City and County Programs and Policies.
9. Report annually and track the implementation of this policy.
4.7 Extended Drought
The SFPUC’s service territory has experienced extended periods of drought over the years. A state of emergency due to severe drought conditions was declared by the Governor of California in 2021. Drought in combination with dryness and other factors can create an ideal situation for the ignition and rapid spread of wildfires.
This changed in late 2022 and early 2023 when there was record rain and snow accumulation. In March 2023 California Governor Newsom signed Executive Order N-5-23 which reduced some of the water use restrictions put in place during the
11 https://sfpuc.org/sites/default/f iles/about-us/commission/2021-10-29-Climate-Change-Workshop- v01.pdf
39 original emergency proclamation in 2021. The SFPUC is evaluating the impacts of the increased rainfall and snowpack on vegetation growth and wildfire risk.
40 5. WILDFIRE PREVENTATIVE STRATEGIES
5.1 Situational Awareness
We made significant advancements in the 2020-2022 Plan updates to enhance our ability to monitor forecasted and real-time weather conditions. This section describes the various programs we continue to develop for situational awareness.
5.1.1 Technosylva Wildfire Analyst™ / Fire Potential Index (FPI) In 2022, our most significant advancement in understanding and evaluating wildfire risk within our areas of operation was the procurement of Technosylva’s Wildfire Analyst™ application. Technosylva is a leading provider of “advanced GIS-enabled software solutions for wildfire protection planning and operational response, as well as firefighter and public safety.” Technosylva is used by CAL FIRE, the CPUC, and all of California’s investor-owned utilities (IOU). The Wildfire Analyst™ performs a risk analysis on each individual SFPUC asset and produces a Fire Potential Index (FPI) rating for that asset. Additionally, the Wildfire Analyst™ produces four different consequence risk metrics if an ignition were to occur at a specific asset. The four consequence risk metrics are (1) Fire Size Potential, (2) Population Impacted, (3) Buildings Threatened, and (4) Estimated Number of Buildings Destroyed. This tool, in conjunction with existing critical fire weather monitoring tools, will initially be used to support HHW field operations’ daily work schedules and inform personnel of areas of risk and if any operating restrictions should be implemented. As HHW pilots this change in operating procedures, it will be implemented by NRLM and WSTD to inform their daily operations.
PG&E supported the SFPUC in the implementation of the Wildfire Analyst™ risk model. PG&E gave permission to the SFPUC and Technosylva to use the PG&E FPI algorithms to develop the SFPUC risk indexes. All the SFPUC electrical assets are within the PG&E service territory. The benefit of PG&E sharing their FPI data is that using the same data sources will allow the SFPUC to have an FPI model consistent with the PG&E FPI model which has been tested and validated.
41 5.1.2 Weather Monitoring
During the 2020-2022 Plan updates, the SFPUC used publicly available weather data including weather forecasts to support real-time operating decisions. HHW obtains wind speed conditions using forecast models from NOAA’s High-Resolution Rapid Refresh (HRRR), generating average and peak wind forecasts for the next 24- hour operating period. The automated process generates an hourly email with the forecast and is sent to HHW operations managers. Wind and weather data is reviewed daily and used to support operational strategies for the HHW overhead electrical lines to determine if any operational restrictions or if lines should be de- energization for public safety.
NRLM/WSTD monitor weather through the National Weather Service (NWS), NOAA, and other publicly available weather services. This information is used to determine any operational restrictions for NRLM and WSTD field staff. Weather conditions are distributed to staff through the Millbrae dispatch center via i-INFO12.
HHW and NRLM/WSTD staff use publicly available weather forecasts and monitor fuel (vegetation) conditions by accessing publicly available information provided by the NWS, USFS’s daily Project Activity Level
13 (PAL) rating, Bureau of Land
Management, NOAA, and CAL FIRE. SFPUC staff monitor the NWS for Red Flag Warnings.
In 2022 the SFPUC acquired the Wildfire Analyst™ as our primary situational awareness tool and risk modeling application. The Wildfire Analyst™ is in development with an implementation date of Q3 of 2023. In 2023 we will continue to collect weather information from the current HRRR model until the Wildfire Analyst™ functionality is validated and approved for full implementation.
12 https://dashboard.i-info.com/
13 Project Activity Level is a decision support tool designed to help fire and timber resource managers establish the level of industrial precaution for the following day. This tool utilizes outputs from the National Fire Danger Rating System (NFDRS).
42 5.1.3 Weather Stations
During the 2020-2022 Plan updates, the HHW upgraded one of our weather stations in the HFTD with a wind sensor, air temperature, and relative humidity sensor for increased situational awareness. With the implementation of the Wildfire Analyst™ the SFPUC will also have access to approximately 325 PG&E or privately owned weather stations providing, at minimum, temperature, relative humidity, and wind speed readings. These weather stations are situated near SFPUC assets and up to a 25-mile buffer from those assets. Figure 6 shows a graphic of the weather station data now available to the SFPUC through the Wildfire Analyst™ application.
SFPUC
2023 Wildfire Mitigation Plan
43 Figure 6 – Weather Stations
SFPUC
2023 Wildfire Mitigation Plan
44 5.1.4 Wildfire Cameras
During the 2020-2022 Plan updates we partnered with PG&E and a communications provider to install two high-definition cameras on SFPUC towers located within the HFTD. PG&E purchased the cameras, and the communications company provides the communications infrastructure for viewing imagery on the ALERTWildfire website14. With the implementation of the Wildfire Analyst™, we have access to approximately 110 cameras providing viewsheds of areas in proximity to SFPUC assets. Figure 7 displays the cameras and live feeds available to the SFPUC in the Wildfire Analyst™ application.
In December 2020, the SFPUC began the process to install additional cameras near SFPUC assets. The locations will include Poopenaut Peak near the O’Shaughnessy Dam site in Yosemite National Park, Burnout Ridge near Cherry Lake, and Intake Ridge near Kirkwood Powerhouse. These areas are in Tier 2 and 3 HFTDs where the SFPUC operates overhead lines. The increased monitoring of the area will enhance our situational awareness, and these cameras will be added to the Wildfire Analyst™ application. The licensing process for these sites is complex due to different land ownership rights and review processes. We continue to coordinate with the various land management agencies for final approval to install the cameras.
14 https://www.alertwildfire.org/
SFPUC
2023 Wildfire Mitigation Plan
45 Figure 7 – Wildfire Cameras
SFPUC
2023 Wildfire Mitigation Plan
46 5.1.5 Air Quality Monitoring
Air quality is monitored for staff safety, especially when nearby wildfire smoke or other known air quality pollutants are present. We use services such as PurpleAir.com which accesses air quality index monitors in all SFPUC regions.
Additionally, the Wildfire Analyst™ product also has an air quality alert module, which can be used to supplement other data sources (Figure 8).
Figure 8 – Air Quality Monitors
5.1.6 Fire Mitigation / Suppression Equipment
The SFPUC FY 2020-2021 & 2021-2022 Adopted Budget included funding to purchase fire mitigation/suppression equipment needing replacement or new equipment where a gap had been identified in the SFPUC fleet. Purchase requisitions were submitted for the following equipment,
1. O ne (1) Kubota L6060HSTC 4X4 tractor,
2. O ne (1) DJI Matrice 300 RTK Combo Plus drone,
47 3. O ne (1) LiAIR V70 LiDAR mapping system with LiGeoreference software to be attached to the Matrice 300 RTK drone, and
4. O ne (1) Ford 550 Altec bucket truck.
The equipment was added to our fleet in Q4, 2022.
In Q2 of 2022, we purchased a commercial-grade drone with a 45-megapixel camera capable of 30x optical zoom. The drone was received in Q4 of 2022. This equipment will be used ground surveys and inspections of SFPUC water and power assets when they are inaccessible by vehicles due to snow accumulation or road damage. We are currently exploring the purchase of a LiDAR and thermal imaging camera which can be applied to wildfire mitigation programs such as vegetation management and electrical asset inspections. As the FY 2023-24 and 2024-25 budgets are developed SFUC will provide an update in the 2024 Plan regarding future equipment purchases to enhance the drone’s wildfire mitigation capabilities.
During the filing of the 2022 SFPUC WMP, the following fire mitigation and suppression equipment approved in the FY 2021-2022 budget was ordered (Figure 9). The SFPUC continues to work with the vendors to secure delivery dates which are delayed due to supply-chain interruptions caused by COVID-19. • One (1) Peterbilt 584 water truck with a 3600-gallon tank • One (1) Volvo ECRF58F excavator with Raptor 30G mulcher Figure 9 – Fire Suppression Equipment
48 5.2 Design and Construction Standards
The SFPUC meets or exceeds the requirements of GOs 95, 128, 165, 174, NERC Reliability Standard FAC-003-4, and applicable National Electric Safety Codes (NESC) to construct, maintain, and operate a safe, reliable, and resilient grid. The SFPUC has effective legacy programs for construction, inspections and maintenance of transmission, distribution, generation, and substation assets within the HFTD and taking corrective action within specified timeframes for all issues that require remediation.
For the 2023-2025 Plan updates, the SFPUC plans to leverage the Wildfire Analyst™ risk modeling application to support more risk-informed decisions for the construction and maintenance of our electrical assets. The SFPUC plans to formalize these programs based on data gathered from the use of the Wildfire Analyst™ and will provide a progress report in the 2024 WMP update.
5.2.1 System Hardening
During the 2020 – 2023 Plan updates, the SFPUC initiated assessments and studies for the following system hardening options:
• Increasing the number of stand-by generators
• Installation of fast-reacting protective relays
• Replacement of Existing Copper Conductor with Aluminum • Replacement of PRC § 4292 Non-Exempt Equipment
• Removal of Overhead Lines
o Overhead to Underground Conversion
o Micro-Hydro
Table 4 lists each of the above stated options and an analysis of the level of effort, risk reduction, actions the implementation would resolve, and secondary issues that would be mitigated or would need to be addressed before construction begins. The narrative includes additional information on each of these options as well as the next steps to be accomplished over the 2023 – 2025 Plan updates.
49 Table 4 – SFPUC Wildfire Mitigation Strategies
Strategy Public Safety
Risk Actions Secondary Issues
Status Quo Reduced
De-Energize 22.9kV
circuits during high-risk
weather conditions
Activate standby
generators at selected
Comm Sites & up-
country dams
Operating cost to send line crew to
operate switch and observe for fire
watch.
Operating cost of line crew to
patrol lines before re-energizing.
Shortest
Path to
reduce
wildfire risk
Additional
Reduction
De-Energize 22.9kV
circuits during high-risk
weather conditions
Same as above
Increase number of
standby generators at
Comm Sites & up-
country dams—OSH
Compound Standby
Generator Project
(underway), Poopenaut
Pass Comm Site
Standby Generator
(new). Increase fuel
storage for increased
generator run-time at all
locations.
Increases maintenance costs to
auto-test and perform preventative
maintenance on larger standby
generator fleet.
Increases fuel costs and demand
for red diesel and propane.
Install fast-reacting
protective relays to
sense and open circuits
faster.
Risk reduction dependent on
existing power protection
infrastructure and may require
electric protection system
upgrades not yet scoped.
Moderate
Path to
reduce
wildfire risk
Moderate
Reduction
Install PRC 4292-
exempt equipment
Eliminates vegetation removal
beneath equipment
Replace conductors
with Aluminum
Increased risk to cross-arm and
pole breakage
May include
actions
above
Underground existing
22.9kV overhead
conductors.
Multiple pull boxes to be field
located
Pole/pad mounted
switches/disconnects still required
Must maintain vegetation above
ROW underground ducts.
Running ducts under road surface
increases lengths and # of pull
boxes.
Longest
Path to
reduce
wildfire risk
Significant
Reduction
Install distributed
generation at critical
sites, e.g.,
solar/batteries,
industrial battery banks,
Increases maintenance costs on
distributed generation assets.
50 micro-hydro
AND de-energize
22.9kV overhead
distribution during lower
fire risk periods
May include
actions
above
Install distributed
generation at critical
sites, e.g.,
solar/batteries,
industrial battery banks,
micro-hydro (Cherry
Valley Dam &/or
O’Shaughnessy Dam)
AND decommission
existing 22.9kV
overhead distribution
lines
Increases maintenance costs on
distributed generation assets.
Decommissioning (removal) of
overhead lines.
Reduced Operations &
Maintenance costs due to
decommissioned lines.
SFPUC facilities at Poopenaut
Pass, Burnout Ridge, Intake Radio
Site, Cherry/Eleanor Pump Station,
Granite Portal Valve house, OSH
Compound, Cherry Camp/Pump
will require new dedicated power
supply.
CCSF Camp Mather will require
new dedicated power supply.
3rd Party sites at NPS Kiosk and
Evergreen will require new
dedicated power supply
ROW maintenance still required for
fiber/wire overhead communication
cables.
5.2.2 Replace Wood Poles
We are not considering a programmatic replacement of wood poles with ductile or steel poles within the 2023-2025 Plan updates.
5.2.3 Replace Overhead #6AWG Copper Conductor
During the 2020-2022 Plan updates, HHW conducted an audit of copper conductor installed on our distribution lines. We identified 13.6 circuit miles of copper conductor the HFTD. The topography of these areas varied from a mixture of coniferous forest, oak woodland, and granite with little vegetation.
We have no history of risk events caused by a failure of copper wire. A cost benefit analysis was conducted to determine if HHW would move forward with a mitigation project. The cost to undertake a stand-alone project to replace copper wire would be significant due to additional system upgrades which would be required and many areas where work would be performed in rugged terrain.
51 Based on this information and analysis, HHW leadership elected to not move forward with a stand-alone copper conductor replacement project; however, the copper conductors will be replaced with aluminum as the equipment otherwise requires replacement or upgrades.
5.2.4 Replacement of Non-Exempt Equipment
Approximately 15 percent of SFPUC distribution poles, including those located in non-HFTD areas, support non-exempt equipment defined by PRC § 4292 and CAL FIRE’s California Power Line Fire Prevention Field Guide.
We will continue maintaining a firebreak around structures that have non-exempt equipment in both the HFTD and non-HFTD. This firebreak consists of clearing not less than a 10-foot radius from the outer circumference of the pole or tower pending the replacement of non-exempt equipment with exempt equipment.
HHW contracted with a firm to complete a load study on distribution assets to identify at-risk facilities, such as overloaded transformers, undersized fuses, etc.
HHW has reviewed the results of the study and has begun looking at procuring replacement equipment, such as PRC § 4292 exempt non-expulsion fuses.
5.2.5 Avian Protection
We do not currently have a formal avian protection program, but we do install bird guards on facilities believed to be at risk of bird contact or another animal contact.
During the 2023-2025 Plan updates, we will provide an update on our avian protection program.
5.3 Overhead Line Removal
5.3.1 Overhead to Underground Conversion
In September 2020, the SFPUC commissioned a consultant to perform three studies to assess the construction costs of underground three existing overhead electrical distribution lines located in the HFTD. The final analysis shows that the project is
52 physically infeasible in some locations due to terrain and geology (steep canyons and granite); however, for the areas where undergrounding is shown as physically feasible, the SFPUC will evaluate and determine whether undergrounding these portions has the most cost-benefit versus other system hardening options described in this section of the WMP.
5.3.2 Micro-Hydro (Overhead Line Removal)
During the 2020-2022 Plan updates the SFPUC initiated a study to evaluate the feasibility of placing micro-hydropower generation units at Cherry and O’Shaughnessy Reservoirs to provide power for these remote sites. The overall goal of adding micro-hydro units would be to reduce the SFPUC’s overhead distribution line miles within the HFTD.
During the 2023-2025 Plan updates, the matrix shown in Table 4 will be refined to analyze and assign priorities and implementation timeframes to the various system hardening studies and reports that have been generated over the 2020-2022 Plan updates. The SFPUC intends to provide an update in the 2024 WMP that refines this matrix and how the SFPUC is prioritizing system hardening projects.
5.4 Vegetation Management
The SFPUC meets or exceeds the industry standards for vegetation management around transmission lines, distribution lines, and substation facilities, and in compliance with the SFPUC internal Hetch Hetchy Water and Power Transmission Vegetation Management Program plan (TVMP Revision 5.2). For transmission-level facilities, the SFPUC complies with North American Electric Reliability Corporation (NERC) FAC-003-4, where applicable. For both transmission and distribution level facilities, the SFPUC meets or exceeds the following standards:
• California PRC § 4291
• California PRC § 4292
• California PRC § 4293
53 • C PUC GO 95 Rule 35
• C PUC GO 95 Appendix E Guidelines to the Rule 35
• CPUC GO 174
• CAL FIRE’S Power Line Fire Prevention Field Guide – 2021 These VM standards require significantly increased clearances in the HFTD. The recommended “time-of-trimming” guidelines in CPUC GO 95 do not establish a mandatory standard for vegetation clearances but provide helpful guidance to utilities. We use specific knowledge of tree growth rates and tree species to determine the appropriate time-of-trimming clearance in each circumstance. These VM standards significantly increase the vegetation clearances required within the HFTD.
Figure 10 – Distribution ROW
54 The SFPUC performs VM with two groups: 1) the HHW group, inspects and maintains vegetation on the HHWP Project from O’Shaughnessy Dam to Newark; and 2) the NRLM group inspects and maintains vegetation in proximity to distribution facilities in and around the Bay Area region.
At HHW a certified arborist with the following certifications, International Society of Arboriculture (ISA) Certified Arborist, ISA Certified Utility Arborist, and ISA Tree Risk Assessment Qualified (TRAQ) completes the inspections. The HHW Right-of-Way (ROW) VM labor crew is made up of one laborer supervisor, one operating engineer, one certified arborist, and five laborers.
The NRLM VM crew comprised three arborists and three to five seasonal watershed workers responsible for the Alameda and Peninsula Watershed. Two registered professional foresters support the work (one for the Alameda Watershed and one for the Peninsula Watershed).
5.4.1 Annual Vegetation Management Work Plan
Vegetation Management work across the ROW is planned and scheduled annually.
All VM activities are listed and described in the Annual Vegetation Management Work Plan (AVMWP) to ensure VM work is conducted timely. The annual work plan is reviewed quarterly and modified as needed in response to changing conditions or findings from vegetation inspections. The work plan identifies the facilities inspected the previous year, proposed work, and completed work. The SFPUC uses Maximo to generate VM work orders. Maximo (IBM™) is a computerized asset and maintenance management system (CMMS) for managing our programmatic maintenance and repair program. Preventative maintenance work orders for detailed transmission and distribution line inspections and substation inspections are managed through Maximo.
5.4.2 Vegetation Inspections / Transmission Lines
A detailed ground inspection (patrol) of all vegetation near 230kV transmission lines,
55 both in the HFTD and non-HFTD, is performed annually. Inspection details, including the name of the inspector and date and line section, are documented in ArcGIS Field Maps, and noted on the HHW AVMWP. These ground inspections identify all conditions where vegetation may encroach within the Minimum Vegetation Clearance Distance (MVCD) for energized facilities before the next scheduled predictive control treatment. Attention is given to visual assessments of trees within the strike zone of energized facilities to identify tree defects that could cause a tree, or parts of a tree, to fall directly onto overhead high-voltage conductors. Individual trees undergo additional inspections of a detailed 360-degree visual evaluation to determine the presence, significance, and severity of tree defects and risks.
In 2020, the SFPUC updated the HHW 115kV Transmission Vegetation Management Plan (115kV VMP) to mitigate further the potential of SFPUC equipment being the origin or contributing source of ignition for a catastrophic wildfire. The 115kV VMP provides detailed program objectives with clearly assigned roles and responsibilities for HHW staff. In December 2022, the 115kV VMP received final signatures and was given an official internal operations and maintenance policy number.
Like the 230kV, the 115kV TVMP follows the AVMWP. The HHW ROW Manager creates the AVMWP and identifies the facilities managed and any proposed work forecasted, with start and completion dates.
The SFPUC will inspect the 115kV transmission system annually for vegetation clearances. Inspection details, including the name of the inspector and date and line section, are documented in ArcGIS Field Maps, and noted on the HHW AVMWP.
Additional corrective maintenance observed during the daily course of work by the Line Crew, Vegetation Management Crew, and Watershed Keepers will be submitted to the Asset Management work group for a corrective maintenance work order.
Table 5 illustrates that 25-vegetation corrective maintenance work orders were issued in 2022, and all have been completed. The most common corrective
56 maintenance identified in 2022 was the trimming or removal of trees near transmission lines and towers. The HHW ROW group has been working to increase communication of permitting requirements for orchard owners near the transmission ROW to reduce grow-in problems and the removal of orchard owner crops.
Table 5 – Vegetation Corrective Maintenance Work Orders for 230kV/115kV Year Number of Work Orders Total Completed
2019 41 41
2020 16 16
2021 22 22
2022 25 25
5.4.3 Vegetation Inspections / Distribution Lines
All vegetation patrols in proximity to distribution lines within the HFTD meet or exceed the requirements of CPUC GO 95. The HHW distribution lines are patrolled and inspected on the ground and aerially annually for vegetation clearances. The HHW arborist perform the ground inspections. The aerial inspections include the line crew (Qualified Electrical Worker – QEW) and the ROW Vegetation Management crew. The inspections serve dual purposes: (1) to allow the line crew to inspect the distribution lines and equipment for any corrective line maintenance required, and (2) to allow the arborist and VM crew to inspect for vegetation that may be encroaching within the MVCD which may require corrective maintenance work.
The NRLM certified arborist performs annual inspections of vegetation in proximity to WSTD d
istribution lines in the Alameda and Peninsula Watersheds. The arborist submits any corrective maintenance work order prescriptions for the NRLM tree crews for mitigation.
In 2020, the SFPUC updated the HHW Power Distribution Vegetation Management Plan (Power DVMP) to mitigate further the potential of SFPUC equipment being the
57 origin or contributing source for the ignition of a catastrophic wildfire. The DVMP provides detailed program objectives with clearly assigned roles and responsibilities for HHW staff. In December 2022, the DVMP received final signatures and was given an official internal operations and maintenance policy number.
The Power DVMP further establishes the protocols for the AVMWP. The AVMWP is created by the ROW Manager and identifies the facilities to be managed and any proposed work, with start and completion dates. When work is identified, a work order is created in Maximo and assigned to the appropriate crew.
Inspection details, including the inspector's name and the date and line section, are documented using Maximo and noted on the HHW Vegetation Management AWP.
The HHW Line Crew, Vegetation Management Crew, and Watershed Keepers report additional corrective maintenance observed during daily work to the ROW VM Manager to generate a corrective maintenance work order through Maximo.
Table 6 shows that in 2021, 26 corrective maintenance work orders were issued, and 23 have been completed. The remaining three work orders were completed in early 2022. In 2022, 21 work orders were generated and all have been completed.
The total completed for 2022 includes the three work orders carried over from 2021.
The most common VM corrective maintenance along the distribution lines was tree trimming and removals to ensure compliance with GO 95 Rule 35.
Table 6 – Vegetation Corrective Maintenance Work Orders for Distribution Year Number of Work Orders Total Completed
2019 45 45
2020 43 43
2021 26 23
2022 21 24
58 5.4.4 Vegetation Inspections / Substations. Switchyards, and Powerhouses
The SFPUC performs annual PRC § 4291 defensible space inspections around substations, switchyards, and powerhouses, including jointly operated substations with a neighboring utility. Inspections are tracked through ArcGIS including the type of work required (side trim, top, green removal, hazard side trim, hazard top, hazard removal) as shown in the dashboard (Figure 12).
5.4.5 Fire Break Clearance Requirements
The SFPUC meets the requirements of PRC § 4292. Poles that are identified as having non-exempt equipment (e.g., expulsion fuses and lightning arrestors) have annual preventative maintenance work orders to clear the base of the pole of all flammable materials and vegetation with a 10-foot radial circle down to bare mineral soil as well as removing all limbs and foliage up to a height of eight feet (Figure 11) The SFPUC regularly consults the CAL FIRE California Power Line Fire Prevention Field Guide and maintains an inventory in Maximo of all poles that host both exempt and non-exempt equipment, including equipment types such as cut-outs, switches, and lightning arrestors.
59 Figure 11 – PRC § 4292 Fire Break Clearance Requirements15
15 Image taken from pg. 37 of the CAL FIRE California Power Line Fire Prevention Field Guide 2021 Edition
60 5.4.6 Herbicide Use
Herbicide treatments for the 230kV ROW follow the SFPUC ROW Integrated Vegetation Management Policy, supported by the San Francisco Planning Department's Preliminary Mitigated Negative Declaration for Rights of Way, where the 230kV ROW intersects with Stanislaus, Mariposa, and Tuolumne counties. The use of herbicides on SFPUC property and ROW is strictly controlled by the City and County of San Francisco and San Francisco's Integrated Pest Management Ordinance (Chapter 3 of the San Francisco Environment Code)16.
5.4.7 Light Detection and Ranging (LiDAR)
In FY 2022-23 and 2023-24, we budgeted LiDAR flights to be performed on an alternating schedule with transmission lines flown one year and distribution lines the following year. In 2021, we contracted with a vendor to collect, process, and analyze all transmission lines, providing LiDAR and ortho imagery. We will use the LiDAR data to classify electric transmission line features, vegetation, ground features, and non -vegetation features within a 300-foot right of way. The LiDAR flight was flown again on March 29, 2022, and we are still working with the vendor to process the data. We are delaying the next LiDAR flight, planned for 2023, until we can analyze the data from the 2022 flight.
5.4.8 Satellite Vegetation Monitoring
In 2020, HHW began discussions with LiveEO, a software company that provides artificial intelligence (AI) satellite observation data specific to infrastructure assets, such as overhead electrical lines. We were most interested in the vegetation management capabilities given the increased turn round time for LiDAR data.
LiveEO’s artificial intelligence is applied to satellite data which identifies and locates hazard trees within the SFPUC’s overhead electrical line footprint.
16 https://codelibrary.amlegal.com/codes/san_francisco/latest/sf_environment/0-0-0- 160
61 With the increased number of satellites in orbit, a utility can get a complete overview of tree location and condition in near real-time. Starting in Q4 of 2023, LiveEO will begin providing the SFPUC with annual 3D vegetation mapping and vegetation encroachment analysis, which encompasses grow-ins (horizontal clearance), grow- ins (3D clearance), fall-ins (position), and access to the LiveEO report generation applications. We plan to use this information as a supplement to LiDAR flights; we will also validate the accuracy of information obtained using LiDAR versus satellite imagery using AI.
5.4.9 Vegetation Management Dashboard
In 2021, HHW began a pilot program for tracking vegetation inspections across the 230kV and 115kV transmission systems and the 22kV and 2.4kV distribution systems using an ArcGIS Field Maps collection program. Field Maps can display collected data in a dashboard format. The dashboard (Figure 12) displays data captured in a calendar year (January 1st to December 31st). 2022 is the first year Field Maps was used to capture the entire year of vegetation inspections.
The modules display overall inspection progress by miles for both transmission and distribution and breaks these out further into separate inspection tracking by distribution and transmission, switchyards, substation, and powerhouses. HHW will continue refining this dashboard to analyze important ROW trends including inspections by work priority and count of trees by work type with the goal of reducing high-priority and hazard tree work.
Now that the dashboard has matured and HHW has gained confidence in the data collection process and dashboard output capabilities, HHW will begin working with NRLM to implement this for vegetation management in the Peninsula watershed.
SFPUC
2023 Wildfire Mitigation Plan
62 Figure 12 – Vegetation Management Dashboard
SFPUC
2023 Wildfire Mitigation Plan
63 5.4.10 Integrated Vegetation Management (IVM)
The SFPUC has a ROW IVM Policy that applies to the entire SFPUC 230/115kV transmission ROW and distribution ROW. The IVM is considered the utility industry's best management practice (BMP) by federal and state land management agencies.
5.4.11 Wood and Slash Management
The SFPUC has two master as-needed tree services contracts that cover projects in the Central Valley going east to O’Shaughnessy Dam and projects in the Bay Area and Peninsula areas. The firms under contract hold D49 Tree Service Contractor Licenses and are Licensed Timber Operators (LTOs) with an “A” license or have an LTO available as a subcontractor.
In 2022, the SFPUC awarded seven projects under the Master As-Needed contracts for a total cost of $1,690,400. These projects range from removing brush around watersheds to the removal of hazard trees along the 230kV and 22kV transmission and distribution ROW.
NRLM in partnership with CAL FIRE conducted a 25 Acre prescribed burn on October 4th, 2022, on the Peninsula Watershed. The primary objective of the burn was to reduce brush densities and fuels within the Highway 280 corridor and the wildland urban interface (Figure 13).
The secondary objective is to promote habitat enhancement and reduce brush encroachment in native grasslands. This project area is in a Tier 2 HFTD. This was the first burn of a larger 700-acre fuels reduction project with CAL FIRE, which is planned to take place over the next seven years.
64 Figure 13 – NRLM Prescribed Burn Area
65 5.5 A sset Inspections
The SFPUC meets or exceeds the minimum inspection requirements provided in CPUC GO 165, CPUC GO 95, Rule 18, and CPUC GO 174. Pursuant to these rules, the SFPUC inspects electric facilities as established in the general orders.
5.5.1 Work Order Documentation
The SFPUC documents all inspection results in Maximo including all findings that require remediation. All follow up remediation work is prioritized based on SFPUC personnel assessment and tracked via Maximo until the work order is closed out.
5.5.2 Transmission Inspections and Maintenance
We own and maintain a total of 834 transmission structures. Detailed ground inspections are performed on a five-year cycle. Detailed ground inspections consist of checking the condition of access roads and gates, tower numbers, tower danger signs, tower concrete footings, grounding condition, vegetation surrounding the tower, steel tower members (checking for rust and condition of metal), and powerline tree and limb encroachments.
Aerial patrols of all 834 structures are performed annually by the HHW Line Crew and consist of a visual inspection of tower members and related hardware, dampers, conductors, and insulators. Any defects or deficiencies discovered through these patrols are reported to the Planning work group and a work order to correct the issue is generated through Maximo.
Table 7 shows that 140 inspections were scheduled in 2022, and all but two are complete, which were issued in late 2022. The tower inspections generated 96 corrective maintenance work orders. The transmission system's most common corrective maintenance work orders were removing dirt from around the tower footings, removing orchard encroachments, and fixing gates on tower access roads.
66 During the 2020-2022 Plan updates, the SFPUC line crew identified and documented all splices and bolted connections on the SFPUC transmission lines.
Recurring preventative maintenance work orders were created with a job plan to thermal scan (infrared) transmission line splices, jumpers, insulators, and dead ends. Equipment that is found to be operating at 100 degrees Fahrenheit above ambient temperature is immediately replaced. Transmission lines were broken down into eight segments, with multiple towers in each segment. Each segment has a recurring preventative maintenance work order, and the findings are documented in the work order log in Maximo.
Table 7 – Transmission Tower Inspections
Year Detailed Inspections
Scheduled/Completed
Corrective Maintenance Work Orders
Scheduled/Completed
Scheduled Complete Scheduled Complete
2019 180 180 49 2717
2020 180 180 28 28
2021 114 114 40 2818
2022 140 140 96 9419
Total 626 (out of 834 Towers)
5.6 Asset Maintenance
Under applicable industry standards, we perform the following asset inspections and maintenance of transmission, distribution, and substation facilities. Preventative maintenance work orders for detailed inspections and corrective work are managed
17 The remaining 22 work orders were completed in 2020, in addition to the 28 reported. 18 The remaining 12 work orders were completed in 2022, in addition to the 96 reported. 19 The two remaining work orders were created in late December 2022. The completion status will be reported in the 2024 WMP update.
67 through Maximo.
5.6.1 Hot or Cold Wash
We conduct annual preventative maintenance by performing hot or cold wash of overhead line towers, insulators, switches, and equipment in substations/switchyards. The purpose of washing is to remove contaminants from the insulators and other associated hardware, which reduces the likelihood of tracking or arcing, which could degrade the equipment and could ultimately lead to failure (Figure 14). The assignment and completion of hot or cold washing work orders is tracked in Maximo. The line crew supervisor verifies the completion of the work orders.
Figure 14 – HHW Line Crew Hot Washing
68 5.6.2 Distribution Inspection and Maintenance
The SFPUC meets or exceeds the minimum inspection requirements of CPUC GO 165 for distribution lines. GO 165 establishes minimum requirements for electrical distribution facilities regarding inspections (patrols, detailed, and intrusive inspections), condition ratings, schedule, remediation of corrective actions, and reporting and record-keeping to ensure safe and reliable electrical service. The SFPUC contracts with a helicopter vendor to patrol distribution lines annually with the SFPUC line crew QEW. During the aerial patrols, the QEW looks at the tops of the poles for rot and damage. Intrusive pole inspections are performed on a 10-year cycle. The SFPUC has four total miles of underground distribution lines located in the Tier 2 HFTD. Corrective maintenance work orders are created during the inspection and assigned a priority. Table 8 shows the number of corrective maintenance work orders issued in 2022 versus the number completed. The SFPUC has inventoried all distribution poles in Maximo.
Table 8 – Corrective Maintenance for Distribution System Year Number of Work Orders Total Completed
2019 4 4
2020 37 37
2021 30 26
2022 14 1220
5.6.3 Powerhouse/Substation/Switchyard Inspections and Maintenance The SFPUC meets or exceeds the requirements of CPUC GO 174, Rules for Electric Utility Substations. The SFPUC performs detailed substation/switchyard inspections monthly (Table 9) and records findings and completion dates in Maximo. Any
20 The two outstanding work orders were issued in late 2022. Completion status will be included in the 2024 WMP update.
69 maintenance or repairs are reported to the Planning team and a corrective maintenance work order is generated in Maximo.
Table 9 – Substation/Switchyard Inspections
2022 Calendar Year Substation/Switchyard Inspections
Month Moccasin Intake Warnerville Calaveras
Jan 1/4/2022 1/13/2022 1/8/2022 1/1/2022
Feb 2/8/2022 2/23/2022 2/5/2022 2/5/2022
Mar 3/15/2022 3/9/2022 3/6/2022 3/1/2022
Apr 4/12/2022 4/8/2022 4/9/2022 4/2/2022
May 5/18/2022 5/6/2022 5/21/2022 5/7/2022
June 6/8/2022 6/9/2022 6/4/2022 6/5/2022
July 7/12/2022 7/8/2022 7/1/2022 7/6/2022
Aug 8/9/2022 8/9/2022 8/7/2022 8/3/2022
Sep 9/14/2022 9/7/2022 9/10/2022 9/7/2022
Oct 10/18/2022 10/7/2022 10/8/2022 10/2/2022
Nov 11/3/2022 11/2/2022 11/5/2022 11/4/2022
Dec 12/13/2022 12/9/2022 12/12/2022 12/2/2022
The SFPUC performs annual infrared inspections on transformers, switches, and circuit breakers in switchyards/substations. Preventative Maintenance work orders are set up in Maximo. Table 10 below shows the asset, equipment, and frequency of infrared inspections.
Table 10 – Infrared Frequencies
Asset Equipment Frequency
Powerhouses Connectors, Switches, and
Circuit Breakers Annual
Powerhouses 13.8kV bus way between GSU
and Switchgear 3 Month
Switchyards/Substations Connectors, Switches, and
Circuit Breakers Annual
Towers Test Shoes, Connectors, and
Splices Annual
Transmission Line Segments Test Shoes, Connectors, and
Splices Annual
Poles Transformers Bi-Monthly
70 5.6.4 Defensible Space Inspections
HHW performs annual preventative maintenance defensible space inspections that conform with PRC § 4291 around buildings and structures. These inspections include areas around substations, switchyards, and powerhouses. Vegetation is removed around facilities to maintain, at minimum, a 100 ft. radius of defensible space.
5.7 Asset Management
During the 2020-2022 Plan updates, the SFPUC began and completed a comprehensive audit to ensure all transmission, distribution, and substations assets are documented in Maximo. This initiative was completed in Q1 of 2023. One of the major accomplishments of this initiative was updating the database with a current count of all primary and secondary distribution poles with height, class, installation date, and installed equipment, including if the poles supported telecom equipment.
5.8 Workforce Training
We have implemented complementary training programs for our workforce to support a safer work environment, ensure continuous improvement, and help reduce the risk that our facilities could be the origin or contributing source for the ignition of a catastrophic wildfire.
5.8.1 Basic Fire Training
Each spring, HHW requires all staff to attend a basic fire training workshop. The training consists of basic fire training regarding minimizing potential fire dangers, practicable actions to suppress fires, the importance of reporting fires, basic fire safety, and the use of fire mitigation and suppression equipment, including hand tools, fire extinguishers, and water pumps. The training is conducted by retired CAL FIRE captains with extensive backgrounds in fire prevention and basic immediate mitigation actions. This training supports the increased fire preparedness and response capabilities of the HHW field staff and other support staff.
71 5.8.2 NRLM/WSTD First Responder Training
NRLM/WSTD host an annual first responder meeting for agencies with emergency response responsibilities in Alameda and Santa Clara counties. The purpose of this meeting is to coordinate emergency communications protocols, share information on upcoming projects, and provide an outlook for the fire season. Representatives include CAL FIRE, Alameda and Santa Clara County Sheriff’s Office, California Highway Patrol, PG&E, East Bay Regional Park District, Fremont and Santa Clara counties Fire Department, and the California Department of Fish and Wildlife.
5.8.3 VM Training
In 2022, COVID-19 disrupted the annual VM refresher training. This training is normally conducted on an annual basis for ROW VM crew(s). The training is scheduled to be updated and reviewed with trainees to discuss all current vegetation clearance regulations per GO 95, Rule 35; PRC §§ 4292 & 4293; and NERC FAC- 003-4 in 2023.
5.9 Recloser Policy
The SFPUC utilizes automatic reclosers for system reliability. Reclosers are used to attempt to automatically restore service following an event that results in the recloser operating. For certain types of risk events, the automatic operation of the recloser could introduce a higher degree of risk for ignition of a wildfire during elevated or extreme fire weather conditions.
During the 2020-2022 Plan updates, the SFPUC procedure was to disable all automatic reclosers when the Adjective Fire Danger Rating condition changes to “high.” The automatic reclose function would remain off until the condition is reporting “Low”, usually following the onset of fall/winter precipitation, and the burn environment is no longer conducive to large wildfires.
When a risk event occurs during periods when reclosing is disabled, field personnel will perform an aerial or ground inspection of the line, from the recloser to the end of
72 the line, prior to restoring service. If a fault (failure) is identified, it will be repaired or made safe before re-energizing the line.
Due to the limited number of SFPUC circuits or circuit segments within the HFTD there are no reliability or customer impacts due to the reclosers being disabled.
In 2023 the SFPUC will continue with the current process for disabling reclosers and will also begin testing and validating the Wildfire Analyst™ risk model ‘s Fire Potential Index (FPI) prediction tool to establish daily operating conditions. The goal is to have the Wildfire Analyst™ FPI fully tested and operational in 2024 and begin using the daily FPI output to inform daily operational decisions including when to disable and enable the automatic reclose function of reclosers.
5.10 Operational / Emergency Response Procedure
The SFPUC has three primary methods for being notified of a system event. When the SFPUC learns of a system event they will dispatch the appropriate field personnel to investigate.
1. Notification via the SFPUC Supervisory Control and Data Acquisition (SCADA) system
a. The Control Center personnel will dispatch the appropriate field personnel to investigate the cause of the SCADA alarm.
2. Notification by personnel when the issue is identified on a patrol a. When an issue of concern that requires immediate attention is identified on a field patrol, the issue will be remediated as follows:
i. Immediate remediation if the issue poses or could pose a threat to public safety, or
73 ii. If the issue does not pose a threat to public safety, it will be reported to the Planning team and a work order will be generated through Maximo to correct the issue.
3. First responder agency
a. The SFPUC will dispatch field personnel anytime they are requested by a first responder agency.
When critical fire weather is forecasted or a RFW is issued by the NWS, the powerhouse control center will dispatch Qualified Electrical Workers (QEW) to patrol power lines and standby for potential de-energization. The control center stays in constant communication with SFPUC management regarding changing weather conditions to monitor for and execute a de-energization event if those triggers are met.
During wildfire events, the SFPUC assigns a Liaison Officer to coordinate with emergency response agencies and local government agencies. If the wildfire is near SFPUC assets, an Incident Command Post or Emergency Operations Center is opened, and an ICS organization is used to manage the operational periods of the event.
5.11 De-energization for Public Safety
During critical fire weather conditions, the SFPUC may, as a measure of last resort, de-energize transmission and/or distribution lines to reduce the risk that SFPUC facilities could be the origin or contributing source for the ignition of a catastrophic wildfire. This strategy has minimal impacts on SFPUC operations, and minimal impacts on the SFPUC’s water delivery operations to the Bay Area, hydro generation operations, interconnected utilities, and the California Independent System Operator (CAISO) grid.
The SFPUC continues to evaluate the de-energization criteria other utilities use in
74 decision-making processes and leverage best practices most applicable to the fire risks associated with SFPUC facilities. The SFPUC currently considers CAL FIRE and USFS fire danger ratings, NWS weather forecasts including Red Flag Warnings, real-time sustained wind speeds and wind gusts, temperature, and relative humidity as inputs for deciding when to de-energize a line for public safety. Additionally, the weather forecast, and fuel information described below, relating to potential fire risk conditions are automatically provided via email notifications to HHW staff as additional inputs to inform decisions to de-energize HHW facilities:
1. Adjective Fire Danger Indices (i.e., ‘Low’ ‘Moderate’, ‘High’, ‘Very High’, and ‘Extreme’) at Mount Elizabeth.
2. Average wind speed and maximum wind gust gridded forecasts. Obtained from High-Resolution Rapid Refresh Model 3-km, hourly resolution, issued once per hour.
When the thresholds specified below are met, an email message is generated automatically and is sent to the HHW Moccasin Control Center mailing list and additional HHW staff. These thresholds are comprised of:
1. Wind thresholds; either of two conditions:
a) Hourly sustained wind speeds greater than 25 mph, or b) Wind gusts greater than 45 mph
2. Adjective Fire Danger Rating of any severity greater than ‘Low’ (i.e., ‘Moderate’, ‘High’, ‘Very High’, or ‘Extreme’).
HHW staff will evaluate the above weather information and based on operating experience and historical system performance, decide if de-energizing electrical facilities for public safety is warranted. If it is decided to de-energize transmission and/or distribution facilities, HHW staff will direct the operations personnel to de- energize determined facilities.
The HHW staff will continue monitoring the critical fire weather conditions. When fire risk conditions improve, they will direct operations personnel to begin the process to
75 re-energize the facilities as outlined in Section 5.11.3 – Restoration of Service.
In 2022, the SFPUC did not de-energize any circuits for public safety. Historical outage dates for de-energization events for public safety are listed in Table 11.
Table 11 – De-Energization Events for Public Safety
Year Name of
Circuit
Dates of
Outages
Number of
Customers
Served by
Circuit
Number of
Customers
Affected
Measures Taken, or
Planned to Be Taken, to
Reduce the Need for
and Impact of Future
de-energization for
safety of Circuit(s)
2020
KPH to OSH
22kV line
6/25/2020 0 0
1. Circuit feeds SFPUC loads
with no customer impacts.
Proactive de-energization is
currently used and preferred
as the primary wildfire risk
mitigation measure.
2. The SFPUC is evaluating
the cost and feasibility of
converting this portion of the
overhead circuit to
underground.
3. The SFPUC is evaluating
the cost and feasibility of
building a remote microgrid
at the load center(s) and
removing the overhead
facilities.
2021
KPH to
OSH 22kV
line
Jan 26-31,
Mar 29-30,
Apr 27-28,
Jul 29-30,
Jul 30-31,
Sep 9-11,
Oct 12-13,
0 0
2022 No Events
PG&E is the source feed to some SFPUC distribution line segments in the Peninsula and Bay Area that provide electrical service to SFPUC-owned and operated facilities. These lines are maintained by WSTD. A PG&E initiated PSPS in the Peninsula and Bay area that are the source feed to SFPUC distribution line segments will impact SFPUC facilities due to a PG&E-initiated PSPS. WSTD coordinates with PG&E before, during, and after a PG&E initiated PSPS event.
76 When PG&E notifies WSTD that a PSPS will be initiated on the source feed to WSTD line segments, WSTD will request HHW line crews to de-energize the WSTD lines, as well as the patrol and re-energization following the PSPS event.
The SFPUC has provided a list of SFPUC-owned critical facilities to PG&E with the associated contact person(s). PG&E and the SFPUC have exchanged company representative contact information for communication during a potential PSPS event.
Several SFPUC staff also have access to the PG&E PSPS Portal and can review pertinent information in real time. SFPUC staff can also participate in coordination calls that occur during an active PG&E PSPS.
Communications with PG&E before, during, and after a PG&E-initiated PSPS have continued to improve over time. The SFPUC is also very proactive and will often contact the PG&E representative before PG&E makes notifications regarding a potential PSPS. The SFPUC has a combination of permanent and mobile temporary backup generators for locations identified as having the potential for being impacted by a PG&E PSPS. The SFPUC communicates with PG&E before a PSPS event and can mobilize temporary generators to those facilities that do not have permanent standby generators.
5.11.1 Impacts on Public Safety
The SFPUC has not identified any impacts on public safety when the SFPUC de- energizes power lines during critical fire weather events.
5.11.2 Customer Notification Protocols
The SFPUC is primarily a generation and transmission provider that transmits SFPUC-generated hydropower over our transmission network and into the CAISO market. Other than the three retail customers, the SFPUC distribution system serves all SFPUC-owned and operated loads (facilities).
77 The SFPUC uses internal notification protocols when critical fire weather conditions are met or forecasted to be met. The HHW control center notifies affected entities by phone and email for both planned and unplanned outages. The SFPUC has three retail customers. Two are connected directly to the distribution system and one is connected to the transmission system. The two customers served off the distribution line are located with the HFTD and have backup generators.
The third customer is in the non-HFTD and is served through the transmission system. The SFPUC collaborates with the stakeholder(s) regarding unplanned power interruptions and potential proactive de-energization events.
5.11.3 Restoration of Service
During a PSPS or de-energization event, SFPUC leadership will continue to monitor critical fire weather conditions throughout the region. When critical fire weather conditions subside, the Division leadership will give an “all clear” to begin the process of returning the lines to service. Staff must conduct an entire line patrol, from the point of de-energization to the end of the line, to ensure the line is safe to energize. Line patrols will be conducted via helicopter, vehicle, or foot, depending on weather conditions and access to facilities. Priority for patrols and restoration will be given to the transmission system first, followed by the distribution system, or as determined by operational needs.
The SFPUC maintains a contract task order with a helicopter service and can call on them to conduct aerial patrols. Using a helicopter for patrols significantly reduces the time required to complete a patrol, provided weather conditions have improved enough for safe flight operations. Following a wildfire, we will restore service when it is safe for staff to access the damaged area(s). The SFPUC will not access burn areas until the agency having jurisdiction (i.e., CAL FIRE, USFS, local fire agency) grants permission to enter the burn area to conduct a damage assessment.
Following a full damage assessment, if required, we will perform repairs, and restoration will proceed following established priority and restoration procedures.
78 6. STAKEHOLDER OUTREACH AND ENGAGEMENT
6.1 Fire Agency (First Responder) Collaboration
The SFPUC continues to collaborate with multiple stakeholders to assess areas where there is or could be a risk for a catastrophic wildfire. This work supports our continuous effort to improve wildfire mitigation strategies and enhance fire safety throughout the region. The SFPUC participates as a partner on the USFS Southwest Interface Team (SWIFT)21, a partnership that includes CAL FIRE, BLM, Tuolumne County, and private landowners. SWIFT is a group comprised of a variety of government and external partners that work collaboratively to create fire-adapted communities. SWIFT meets every month and, since 1999, has planned and implemented wildfire protection activities within the 132,000-acre (~206 sq. mi.) area of southern Tuolumne County and western Mariposa County. Additionally, they cooperatively plan and implement strategic fire fuel break systems designed to reduce the threat of loss of life, property, and resources in the southern Tuolumne and western Mariposa County wildland-urban interface.
In Alameda and San Mateo counties, the SFPUC organizes an annual first responder liaison meeting in coordination with CAL FIRE to supplement ongoing communication with all first responders, including the county sheriff's office and local fire departments. The SFPUC watershed lands in these two counties are State Responsibility Areas (SRA), and SFPUC staff are in regular communication with local CAL FIRE staff throughout the calendar year.
The SFPUC continues collaboration with CAL FIRE’s Tuolumne-Calaveras Unit which owns and operates a Firehawk helicopter stationed at the Columbia Airport, approximately 22 miles from the SFPUC Moccasin Powerhouse / Switchyard / Control Center (Figure 15). The primary benefit of the Firehawk helicopter is the increased water carrying capacity of up to 800 gallons and if a wildland fire ignites
21 https://www.fs.usda.gov/detail/stanislaus/home/?cid=stelprd3810191
79 near SFPUC assets, the Firehawk helicopter could be deployed and arrive within minutes and conduct an initial attack to reduce fire spread potential.
Figure 15 – CAL FIRE Firehawk Helicopter
The SFPUC developed a Fire Dipping Strategy procedure that is shared with CAL FIRE, Yosemite National Park, and the USFS. The purpose and scope of the plan are to provide a reservoir dipping strategy that considers both water quality and firefighting efforts. The SFPUC owns and operates drinking water reservoirs for the City of San Francisco and the Bay Area. Fire response agencies use these reservoirs to pull water during fire suppression activities. Because of water quality risks, the SFPUC has ensured that partner agencies understand the benefits and risks and require the appropriate staff to be contacted before dipping from SFPUC reservoirs.
The SFPUC's Wildfire Mitigation Planning Group is led by the WMRA with participation from managers and field staff from HHW, NRLM, and WSTD. The group's purpose is to coordinate wildfire mitigation projects, activities, and best practices across all SFPUC divisions. The group meets monthly, with an agenda prepared before each meeting and the opportunity for each member to provide discussion topics. The SFPUC divisions responsible for performing wildfire mitigation activities cover a significant geographical area. The coordination of work performed
80 by this planning group has proven to be an efficient and effective way to share resources, provide project updates, and coordinate programs to ensure the SFPUC consistently complies with all local, state, federal, and regulatory requirements in a continuous effort to reduce the risk of SFPUC assets being the origin or contributing source for a catastrophic wildfire.
6.2 SFPUC Relationship with PG&E
The SFPUC owns and operates critical water, power, and sewer facilities across multiple counties in Northern California. The SFPUC transmission system has interconnections with the California transmission grid via PG&E’s electrical grid.
PG&E and the SFPUC maintain ongoing dialogue regarding potential PG&E actions that could impact SFPUC facilities.
PG&E continues to support the SFPUC in the implementation of the Wildfire Analyst™ modeling tool. PG&E gave permission to the SFPUC and Technosylva to use the PG&E FPI algorithms to develop the SFPUC risk indices. Since the majority of SFPUC electrical assets are within the PG&E service territory, the benefit of PG&E sharing their FPI data is that using the same data sources will allow the SFPUC to have an FPI model consistent with the PG&E FPI 22 model which has
been tested and validated.
6.3 California Municipal Utilities Association (CMUA) Collaboration The CMUA established six working groups to support the POUs in the development of the WMPs by sharing information and utility best practices in the areas listed below. The SFPUC participated in the working sessions of each work group:
1. Metrics Working Group
2. Vegetation Management Working Group
3. Asset Management Working Group
22 See PG&E’s 2023-2025 WMP Section 8.3.6, Fire Potential Index (Rev 1, dated April 6, 2023). Available at 2023-2025 Wildfire Mitigation Plans (pge.com)
81 4. Grid Design and System Hardening Working Group
5. Risk Modeling Working Group
6. Climate Change Working Data Working Group
82 7. EVALUATING PERFORMANCE OF THE PLAN
7.1 Metrics and Assumptions for Measuring Plan Performance We track the following transmission and primary distribution system metrics to measure the performance and effectiveness of our Plan in reducing the risk of SFPUC facilities being the origin or contributing source for the ignition of a catastrophic wildfire. In 2022, we adopted the outcome and performance metrics recommended by the WSAB. In addition, we analyzed our data going back to 2019.
Outcome and performance metrics are summarized in Table 12.
Table 12 – Outcome and Performance Metrics
Metric Metric Description 2019 2020 2021 2022
Outcome Metrics
1 Vegetation inspections
were completed in an
HFTD (Through a
combination of aerial
and ground
inspections).
Completed Completed Completed Completed
2 Transmission Line
Inspections – aerial Completed Completed Completed Completed 3 Distribution Line
Inspections – aerial Completed Completed Completed Completed Performance Metrics
1 Reportable ignitions in
the HFTD associated
with SFPUC electric
facilities (see Section
9.4)
0 1 1 0
2 Number of times a
circuit or circuit
segment is de-
energized within the
HFTD
1 4 7 0
3 Wire down in HFTD 1 2 1 0
4 Wire down outside
HFTD
0 0 0 0
83 7.2 Metric 1: Fire Ignitions
For purposes of this metric, a fire ignition must meet the following criteria:
1. SFPUC facility was associated with the ignition of the fire.
2. The fire was self-propagating and of a material other than electrical and/or communication facilities.
3. The resulting fire traveled greater than one linear meter from the ignition point.
4. SFPUC has knowledge that the fire occurred.
7.3 Metric 2: Wires Down
The second metric is the number of SFPUC transmission or primary distribution wires down. For purposes of this metric, a wire-down event includes any instance where an electric transmission or primary distribution conductor falls to the ground or onto a foreign object. We differentiate this metric into wires down “inside” and “outside” a HFTD.
7.4 Impact of Metrics on Plan
The SFPUC continues to document and monitor metrics to measure the performance of the WMP to reduce the risk that SFPUC facilities will not be the origin or contributing source of a catastrophic wildfire. The SFPUC will continue to evaluate system performance and identify additional metrics to measure the fire risk reduction gained year after year.
During the 2020-2022 Plan updates, the SFPUC transmission and distribution systems performed exceptionally well and experienced favorable system reliability.
There was one ignition event in 2020 and one in 2021 attributed to SPFUC distribution assets when a tree fell and contacted the lines. Lessons learned from these events resulted in revising the wind speed thresholds, for proactive de- energization of the 22kV distribution lines in the Tier 2 HFTD and the removal of additional danger trees adjacent to the overhead lines. The SFPUC will continue to
84 monitor metrics and evaluate trends that may require a review and possible revision to construction, inspection, and/or maintenance standards. The SFPUC also monitors incidents and root cause analysis at other utilities to determine if the SFPUC is at risk for a similar type of event and put measures in place to minimize the risk of similar events occurring throughout the SFPUC overhead electrical assets.
7.5 Monitoring and Auditing the Plan
The WMRA and SFPUC staff continuously monitor projects and metrics outlined in this WMP to identify areas of improvement and continuous goal to reduce the risk that SFPUC facilities will not be the origin or contributing source of a catastrophic wildfire. Execution of hardening projects, proactive inspection programs, preventative maintenance programs, and data collected will inform the SFPUC staff of system improvements and areas that need additional attention. The SFPUC staff are committed to operating a safe and reliable power grid while reducing the risk of SFPUC facilities being the source of ignition for a catastrophic wildfire.
7.6 Corrective Action Program
We are committed to making our Plan effective and robust. We also understand that identifying gaps and areas for improvement in our Plan is a continuous process, learned through experience and monitoring industry best practices. During the 2020- 2022 Plan updates, we made several changes to our Plan due to new policies, strategies, changes in technology, or identifying previously unidentified risks. We will continue to correct any gaps or deficiencies in a timely manner. Changes will be incorporated into our Plan and submitted to the SFPUC Commission for approval annually, subsequently submitted to the WSAB.
7.7 Monitoring the Effectiveness of the Plan
We strive for continuous improvement to reduce the risk of SFPUC facilities being the origin or contributing source of a catastrophic wildfire. We will continuously
85 monitor and evaluate the wildfire mitigation efforts described in our Plan and pursue improvements in our ongoing goal of providing safe and reliable water and power to the region.
86 8. INDEPENDENT EVALUATOR
PUC § 8387(c) requires the SFPUC to contract with a qualified IE with experience in assessing the safe operation of electrical infrastructure to review and assess the comprehensiveness of this Plan.
For the initial SFPUC 2020 WMP, the SFPUC engaged the services of a local consulting firm to provide an independent evaluation of our 2020 WMP. The local consulting firm employed a former investor-owned utility executive with 40 years of electric operations experience to lead the team to evaluate the SFPUC WMP. The IE team determined that the SFPUC 2020 WMP was comprehensive and met all the requirements of PUC § 8387. The above-mentioned IE also performed the evaluation for this 2023 comprehensive Plan update.
The SFPUC’s Plan is updated annually and will be evaluated by an IE every three years when comprehensive updates to the Plan are made. The IE reviewed this 2023 comprehensive Plan update and presented his report to the SFPUC Commission.
The IE report is submitted to SFPUC’s Commission along with the request for final approval of the SFPUC WMP.
Grid Subject Matter Experts, LLC
145 Parkshore Drive, Suite 140, Folsom, CA 95630
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SAN FRANCISCO PUBLIC
UTILITIES COMMISSION
(SFPUC)
2023 WILDFIRE MITIGATION
PLAN
INDEPENDENT EVALUATION
REPORT
June 1, 2023
Grid Subject Matter Experts, LLC
145 Parkshore Drive, Suite 140, Folsom, CA 95630
(916) 800-4545 | www.gridsme.com
[email protected]
DISCLAIMER
California Public Utilities Code (PUC) § 8387 mandates that local publicly owned electric utilities or electrical cooperatives (herein POU) shall prepare a Wildfire Mitigation Plan (WMP or Plan). Additionally, POUs are required to contract with a qualified independent evaluator (IE) with experience in assessing the safe operation of electrical infrastructure to review and assess the comprehensiveness of its WMP.
The San Francisco Public Utilities Commission (SFPUC or Commission) has requested Grid Subject Matter Experts (“GridSME”) to conduct a review of the SFPUC 2023 WMP and provide an independent evaluation report to ensure it meets the requirements of PUC § 8387. GridSME’s IE review and assessment is based only on SFPUC’s 2023 WMP and evaluates only the comprehensiveness of the Plan as it is written.
The information provided in this report represents GridSME’s IE analysis based only on the information available at the time the review was conducted. GridSME is not responsible for the success or failure of SFPUC’s projects nor any potential ignition resulting therefrom. GridSME makes no representations or warranties expressed or implied regarding the reliability or thoroughness of SFPUC’s WMP. Recipients of the IE report assume all liabilities incurred by themselves, or third parties, resulting from their reliance on the report, or the data, information, and/or assessment contained therein.
Grid Subject Matter Experts, LLC
145 Parkshore Drive, Suite 140, Folsom, CA 95630
(916) 800-4545 | www.gridsme.com
[email protected]
Table of Contents
1.0 Statutory Requirements of the Wildfire Mitigation Plan ........................... 4
2.0 Independent Evaluator Qualifications .................................................. 5
4.0 Introduction: .................................................................................. 6
5.0 SFPUC Company Overview: ............................................................... 7
6.0 Independent Evaluation: ................................................................. 11
6.1 PUC § 8387(b)(2)(A) ................................................................... 11
6.2 PUC § 8387 (b)(2)(B) .................................................................. 13
6.3 PUC § 8387 (b)(2)(C) .................................................................. 13
6.4 PUC § 8387 (b)(2)(D) ................................................................. 17
6.5 PUC § 8387 (b)(2)(E) .................................................................. 18
6.6 PUC § 8387(b)(2)(F) ................................................................... 18
6.7 PUC § 8387(b)(2)(G) .................................................................. 20
6.8 PUC § 8387(b)(2)(H) .................................................................. 21
6.10 PUC § 8387 (b)(2)(J)(i) and (ii) .................................................... 24
6.11 PUC § 8387 (b)(2)(K) .................................................................. 25
6.12 PUC § 8387 (2)(L) ...................................................................... 26
6.13 PUC § 8387 (2)(M) ..................................................................... 27
6.14 PUC § 8387 (2)(N) (i), (ii) and (iii) ................................................ 28
7.0 Summary ..................................................................................... 30
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[email protected]
1.0 Statutory Requirements of the Wildfire Mitigation Plan California Public Utilities Code (PUC) § 8387 requires “Each local publicly owned electric utility and electrical cooperative (herein a POU) shall construct, maintain, and operate its electrical lines and equipment in a manner that will minimize the risk of wildfire posed by those electrical lines and equipment”.
PUC § 8387 requires that after January 1, 2020, “publicly owned electric utility and electrical cooperatives shall prepare a wildfire mitigation plan (WMP or Plan) annually and shall submit the plan to the California Wildfire Safety Advisory Board (WSAB) on or before July 1 of that calendar year.
Each POU shall update its plan annually and submit the update to the WSAB by July 1 of each year. At least once every three years, the submission shall be a comprehensive revision of the plan.
Prior California legislation, codified in PUC § 8387, established the WSAB.
The WSAB consists of an appointed seven-member panel that serves in an advisory role within the California Office of Energy Infrastructure Safety (OEIS)
1. PUC § 326.2(C) requires the WSAB to “Review and
provide comments and advisory opinions to each local publicly owned electric utility and electrical cooperative regarding the content and sufficiency of its wildfire mitigation plan and recommendations on how to mitigate wildfire risk”.
PUC § 8387(3)(c) requires that each POU “shall contract with a qualified independent evaluator (IE) with experience in assessing the safe operation of electrical infrastructure to review and assess the comprehensiveness of
1 https://energysafety.ca.gov/what-we-do/wildfire-safety-advisory-board/
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its wildfire mitigation plan. The IE shall issue a report that shall be made available on the internet website of the local publicly owned electric utility or electrical cooperative and shall present the report at a public meeting of the local publicly owned electric utility or electrical cooperative’s governing board”.
The SFPUC has, each year, complied with its statutory obligation and timely filed its 2020, 2021, and 2022 WMPs, and now files its 2023 WMP to the WSAB.
2.0 Independent Evaluator Qualifications
In accordance with PUC § 8387(3)(c) the SFPUC, a publicly owned utility (POU
), engaged the services of GridSME to conduct an independent evaluation of their 2023 WMP to review and assess the comprehensiveness of their Plan as written. GridSME is a company of about 100 power industry professionals who offer its clients a diverse range of solutions in areas such as engineering, interconnection, compliance, cybersecurity, and operations to help guide them throughout their projects' entire lifecycle. The GridSME team brings over 100 years of combined electric utility system operations experience and is qualified to review and assess the comprehensiveness of SFPUC’s 2023 WMP. The GridSME project team leader is a former investor- owned utility executive with 40 years of experience in electric system operations and had a significant role in developing and executing wildfire mitigation programs at the utility from 2008 until his retirement in 2017. In 2019/2020 the GridSME team provided WMP IE services for five different POUs for the first submittals of the POU WMPs.
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3.0 Independent Evaluation Methodology
GridSME’s review and evaluation of the SFPUC 2023 Plan consisted of reviewing the written Plan and providing comments and recommendations for SFPUC’s consideration prior to finalizing the 2023 Plan. GridSME’s final review and evaluation of SFPUC’s 2023 WMP assesses the Plan’s comprehensiveness to ensure it satisfies each of the required 17 elements of PUC § 8387 and considers the guidance and recommendations issued by the WSAB in previous advisory opinions. Per the WSAB Guidance Advisory Opinion for the 2023 WMP of POUs2, they state their reviews are performed in the context of the following elements:
Figure 1 / WSAB List of Statutory Responsibilities
4.0 Introduction:
Over the past several years the threat of catastrophic wildfires has significantly increased, not only in the state of California, but the entire western United States. These fires are fueled in part by changing
2 https://energysafety.ca.gov/wp-content/uploads/wsab-wmp-pou-guidance-advisory-opinion-adopted.pdf
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weather patterns that have contributed to extended drought conditions, hotter temperatures, and more intense conditions, which could result in a catastrophic wildfire. Although there are many different sources of ignition for wildland fires these types of weather events increase the threat to utility infrastructure which could result in a risk event (fault) and could lead to an ignition of a fire. Origin and Cause investigations by fire authorities have concluded that utility electrical infrastructure has previously been the origin or contributing source for the ignition of a fire.
SFPUC’s 2023 WMP details the wildfire mitigation programs and initiatives undertaken by the company to construct, maintain, and operate its electrical lines and equipment in a manner that will minimize the risk of wildfire posed by those electrical lines and equipment.
5.0 SFPUC Company Overview:
The SFPUC is a department of the City and County of San Francisco (CCSF).
The SFPUC provides retail drinking water and wastewater services to the City of San Francisco, wholesale water to three Bay Area counties, green hydroelectric and solar power to Hetch Hetchy electric customers, and power to some residents and businesses of San Francisco through the CleanPowerSF program. The SPFUC’s mission is to provide their customers with high quality, efficient, and reliable water, power, and sewer services in a manner that is inclusive of environmental and community interests, and that sustains the resources entrusted to their care.
3 3 “SFPUC About Us,” San Francisco Public Utilities Commission: Our Mission. See https://www.sfwater.org/index.aspx?page=161.
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The SFPUC is comprised of six business functions, or enterprises, including the Water Enterprise (see WMP Figure 3). The Water Enterprise is comprised of six divisions, including Hetch Hetchy Water (HHW), Water Supply & Treatment (WST), and Natural Resources and Lands Management (NRLM).
Each division is overseen by an Assistant General Manager who has responsibilities for managing and maintaining the electrical assets within their area of responsibility and as described in this Plan.
The HHW department has responsibility for the development, execution, and oversight of the SFPUC WMP, with support from NLRM and WST. In 2022 the SFPUC established the Wildfire Mitigation and Recovery Analyst (WMRA) position, reporting under the HHW division, and was given responsibility for direct oversight of the SFPUC WMP.
Hetch Hetchy Water and Power (HHWP) operates the HHWP Project. The HHWP operates and maintains a system of assets including water storage and conveyance systems, power generation facilities, power transmission and distribution systems, roads, bridges, and other ancillary facilities. The assets making up these systems start at the Hetch Hetchy Reservoir located in Yosemite National Park and span to the communities of Sunol and Newark in Alameda County, including the counties of Tuolumne, Stanislaus, San Joaquin, and San Mateo. HHW produces hydroelectric generation and transmits the power over the SFPUC-owned and operated transmission and distribution lines to the California electric grid. Additionally, Water Supply & Treatment (WST), a division of the SFPUC, operates and maintains overhead distribution lines in Alameda and San Mateo counties.
The SFPUC owns, maintains, and operates approximately 163 miles of 230 and 115 kV transmission lines, and distributes electricity at 22 and 2.4 kV
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through approximately 58 miles of overhead distribution lines (see Figure 2).
The power transmission and distribution facilities are within PG&E’s service territory, where PG&E is the energy provider. SFPUC’s transmission facilities are designed to carry energy from SFPUC-owned hydroelectric plants to the grid. SFPUC distribution facilities are designed to take energy from either the SFPUC-owned transmission system or from the grid to power SFPUC Water Enterprise operations. Approximately 54 miles of SFPUC’s transmission facilities and 52.3 miles of distribution facilities are located within the CPUC- designated High Fire Threat District (HFTD) Tier 2 or Tier 3. The HFTD is comprised of a High Hazard Zone and two high fire-threat areas where there is an increased risk for utility-associated wildfires.
The three fire-threat areas are:
1. Tier 1, High Hazard Zone – Is in direct proximity to communities, roads, and utility lines, and is a direct threat to public safety.
2. Tier 2 fire-threat area - Depicts areas where there is an elevated risk (including likelihood and potential impacts on people and property) from utility-associated wildfires.
3. Tier 3 fire-threat area - Depicts areas where there is an extreme risk (including likelihood and potential impacts on people and property) from utility-associated wildfires.
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Figure 2 - SFPUC's Electric Service Territory
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6.0 Independent Evaluation:
The SFPUC conducted a comprehensive review of its WMP and submits it 2023-2025 WMP as required by statute. The SFPUC’s 2023 WMP builds upon the successes and learnings from the 2020-2022 WMP to maintain compliance with the seventeen (17) elements required in PUC § 8387. The SFPUC additionally considered recommendations and advisory opinions provided by the WSAB and recommendations by the IE for inclusion in the 2023 WMP.
The SFPUC WMP is built upon three primary objectives aimed at minimizing the risk of SFPUC’s electrical facilities being the origin or contributing source for the ignition of a catastrophic wildfire. They are:
1. Minimize electrical sources of ignition,
2. Improve resiliency of the electric grid, and
3. Evaluate the Plan's performance and effectiveness.
Each of the 17 requirements (elements) of PUC § 8387 is listed separately below followed by comments/recommendations provided by the IE.
For the IE evaluation of the SFPUC 2023, WMP GridSME’s primary point of contact was the WMRA in the HHWP division. The IE noted that wildfire mitigation programs and initiatives are well-defined in the WMP for the HHWP division.
6.1 PUC § 8387(b)(2)(A)
Requirement:
An accounting of the responsibilities of persons responsible for executing the plan.
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Assessment:
WMP Section 5.1, POU Org Chart and Specific Responsibilities, describe personnel who are responsible and/or accountable for the development, approval, and implementation of this Plan. The Commission has responsibility for Plan approval. The SFPUC Assistant General Manager of Water Enterprise has overall accountability for the development and implementation of this WMP and delegates responsibilities to division leadership (HHWP, NLRM, and WST) who have specific responsibilities for the various wildfire mitigation programs such as vegetation management, substation inspections, line inspections, line construction, etc.
During the 2020-2022 WMP cycle, the SFPUC assigned a Wildfire Mitigation & Recovery Analyst (WMRA) position to oversee the overall development and maintenance of the SFPUC WMP. The WMRA is the lead of an internal SFPUC team that has responsibility for reviewing the ongoing status of the SFPUC wildfire mitigation programs and monitoring the effectiveness of their Plan.
This team, with representation from HHWP, NLRM, and WST, meets monthly, or as required. The WMRA is also the primary SFPUC liaison with the CMUA for all wildfire mitigation discussions, including participating in the six CMUA WMP working groups.
Comments / Recommendations:
The SFPUC organization chart and the Roles and Responsibilities table are well-defined. The IE commends the SFPUC for establishing the Wildfire Mitigation & Recovery Analyst (WMRA) position to oversee the overall development and maintenance of the SFPUC WMP.
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6.2 PUC § 8387 (b)(2)(B)
Requirement:
The objectives of the wildfire mitigation plan.
Assessment:
Section 4.0, Objectives of the Wildfire Mitigation Plan, describe the three primary objectives of the SFPUC WMP. All wildfire mitigation programs and initiatives described in the SFPUC 2023 WMP are designed to minimize the risk of SFPUC electrical assets being the origin or contributing source for the ignition of a catastrophic wildfire. The three primary objectives are:
1. Minimizing sources of ignition,
2. Improve grid reliability and resiliency, and
3. Measuring Plan effectiveness.
Comments / Recommendations:
The SFPUC continues to develop and mature its wildfire mitigation programs and initiatives to meet and improve on its three primary objectives. The 2023-2025 WMP continues to build upon the successes and learnings of the 2020, 2021, and 2022 WMPs. The various mitigation programs listed in the WMP are well-defined and demonstrate how the SFPUC continues to focus on wildfire risk reduction initiatives.
6.3 PUC § 8387 (b)(2)(C)
Requirement:
A description of the preventative strategies and programs to be adopted by the local publicly owned electric utility or electrical cooperative to minimize the risk of its electrical lines and equipment causing catastrophic wildfires, including consideration of dynamic climate change risks.
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Assessment:
WMP Section 7, Wildfire Preventative Strategies, provides a comprehensive list of programs undertaken by SFPUC to minimize the risk of SFPUC electrical facilities being the origin or contributing source for the ignition of a catastrophic wildfire. The SFPUC describes a robust vegetation management program, system hardening projects, transmission and distribution line inspections, substation inspections, and situational awareness tools to forecast critical fire weather conditions.
In 2022, the SFPUC’s most significant advancement in understanding and evaluating wildfire risk within their areas of operation was to procure Technosylva’s Wildfire AnalystTM4 application. Technosylva is a leading provider of “advanced GIS-enabled software solutions for wildfire protection planning and operational response, as well as firefighter and public safety”. Technosylva supports CAL FIRE, the CPUC, and all of California’s investor-owned utilities. It is believed the SFPUC is the first POU, nationwide, to procure and operationalize the use of this state-of-the- art risk modeling software. The Wildfire AnalystTM performs risk analysis on each SFPUC asset and produces a Fire Potential Index (FPI) rating for that asset. Additionally, the Wildfire Analyst
TM produces four different
consequence risk metrics if an ignition were to occur at a specific asset. The risk metrics are (1) Fire Size Potential, (2) Population Impacted, (3) Buildings Threatened, and (4) Estimated Number of Buildings Destroyed.
This tool, in conjunction with existing critical fire weather monitoring tools, is now used to support the SFPUC field operation's daily work schedules and
4 https://technosylva.com/products/wildfire-analyst/
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informs personnel of risk areas and if any operating restrictions should be implemented.
Additionally, the SFPUC must be commended on their communication and collaboration with external partners and neighboring utilities. These partners include Cal Fire, the US Forest Service, the Bureau of Land Management, the National Weather Service, the National Oceanic and Atmospheric Administration, PG&E, and other local, regional, state, and federal agencies.
The SFPUC continues to monitor the work of the SFPUC Climate Change Collaboration and Coordination Committee (C5). The C5 primary objective(s) is to develop, coordinate, and communicate a comprehensive and consistent approach to mitigating and adapting to climate change. The SFPUC looks to leverage the work of the C5 to identify potential risks to SFPUC electrical assets and develop mitigation plans.
Comments / Recommendations:
1. IE comment: In 2019/2020 GridSME was retained by SFPUC as their IE and recommended the SFPUC assess the need for installing additional weather stations within their service territory to monitor weather conditions directly impacting their facilities. In 2020, the SFPUC utilized the National Weather Service weather reports for real- time and forecasted weather information, however, these forecasts may not be specific to areas where the SFPUC has facilitates that could be at risk.
During the 2020-2022 WMP cycle, with the procurement of Technosylva’s Wildfire Analyst
TM application, SFPUC now has access to
over 300 weather stations in close proximity to SFPUC assets. Many of
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these weather stations are owned and operated by PG&E. Additionally the Wildfire AnalystTM provides a 100-hour weather forecast and fire potential index for enhanced situational awareness.
2. IE comment: During the 2020-2022 WMP cycle the SFPUC included Section 3.4, Wildfire Mitigation Funding, which provides a snapshot of the Hetch Hetchy Ten-Year Capital Plan and describes a number of transmission line and substation capital improvement projects.
3. In 2019/2020 the IE recommended the SFPUC evaluate the operating condition criteria, and if necessary, revise them to be consistent across the different SFPUC zones.
a. IE comment: The 2023 SFPUC WMP describes the SFPUC plans to leverage the functionality of the Wildfire AnalystTM application to provide a more granular fire potential index rating and real- time weather information for different SFPUC operational zones.
The IE recommends the SFPUC consider adopting the use of the four operating conditions (Normal, Elevated, Extreme, and Red Flag Warning) recommended by the WSAB in their Advisory Opinion for the POU 2023 WMP.
The Wildfire AnalystTM will produce a daily Fire Potential Index rating for the different SFPUC zones. SFPUC leadership state that in 2023 the HHWP division will conduct a pilot project to formalize the operating condition criteria and operationalize it for use throughout the SFPUC. Upon successful completion of the HHWP pilot project the Wildfire Analyst
TM will be deployed for use
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by NLRM and WST.
4. For the 2023-2025 WMP cycle, the IE recommends the SFPUC provide an update regarding projects, mentioned in the 2020-2022 WMPs, to remove overhead lines in the High Fire Threat District.
6.4 PUC § 8387 (b)(2)(D)
Requirement:
A description of the metrics the local publicly owned electric utility or electrical cooperative plans to use to evaluate the wildfire mitigation plan’s performance and the assumptions that underlie the use of those metrics.
Assessment:
WMP Section 10, Evaluation of the Plan, lists four performance metrics and three outcome metrics used to monitor the performance and effectiveness of the SFPUC Plan. The SFPUC utilizes Maximo (IBMTM) as its enterprise computerized maintenance management system (CMMS) for managing its programmatic maintenance and repair programs. Preventative maintenance work orders for detailed transmission and distribution line inspections and substation inspections are managed through Maximo.
Comments / Recommendations:
The SFPUC has done a good job of defining specific metrics to evaluate the performance of their WMP. The 2023 WMP metrics build upon the metrics listed in the 2020-2022 WMP cycle.
No additional recommendations.
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6.5 PUC § 8387 (b)(2)(E)
Requirement:
A discussion of how the application of previously identified metrics to previous wildfire mitigation plan performances has informed the wildfire mitigation plan.
Assessment:
WMP Section 10.2, Impact of Metrics on the Plan, describes two specific incidents which occurred during the 2020-2022 WMP cycle, which resulted in an ignition attributed to SFPUC assets. Both incidents were the result of a tree failure contacting and downing SFPUC distribution lines. Upon investigation to identify the root cause of the tree failure the SFPUC determined other trees could fail with potentially similar results. The SFPUC took immediate action and removed identified trees to mitigate the risk of future similar tree failures near SFPUC electrical assets.
Comments / Recommendations:
The 2023 WMP metrics build upon the metrics listed in the 2020-2022 WMP cycle. The IE recommends the SFPUC continue to explore what other metrics should be tracked to inform them of WMP progress or areas needing improvement.
6.6 PUC § 8387(b)(2)(F)
Requirement:
Protocols for disabling reclosers and de-energizing portions of the electrical distribution system that consider the associated impacts on public safety, as well as protocols related to mitigating the public safety impacts of those protocols, including impacts on critical first responders and health and communication infrastructure.
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Assessment:
WMP Section 7.8, Recloser Policy, describes SFPUC’s protocols for disabling line reclosers on all of their transmission and distribution circuits when the Stanislaus National Forest changes the fire danger condition from Low to Moderate. This section also describes the line restoration procedures following an unplanned interruption while the reclosing function is disabled.
WMP Section 7.10, Public Safety Power Shutoff / De-energization, describes the SFPUC protocols for de-energizing transmission or distribution lines for public safety during critical fire weather conditions. In 2021 the SFPUC de- energized one line segment seven different times as shown in SFPUC WMP Table 10.
The SFPUC retail customers connected directly to their facilities located within a Tier 2 HFTD have a portable generator and experience no adverse impacts due to a utility power interruption. All other SFPUC-owned and operated critical load has backup generation and does not experience any operational impacts.
WMP Section 5.2, Coordination with Critical Infrastructure Providers, has identified one privately owned and operated cellular site supplied by the SFPUC line. During a de-energization event impacting the cellular site, the SFPUC will communicate with the customer. The site is equipped with a backup generator and does not experience any downtime during a utility power interruption.
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Comments / Recommendations:
The IE recommends the SFPUC leverage the fire potential index and other fire consequence risk models of the Wildfire AnalystTM to refine the criteria or triggers for disabling reclosers and de-energizing overhead line(s).
The SFPUC leadership reports that, in 2023, the HHWP division will be conducting a pilot project on operationalizing the Wildfire AnalystTM. Upon successful completion of the HHWP pilot project the Wildfire AnalystTM will be deployed for use by NLRM and WST.
6.7 PUC § 8387(b)(2)(G)
Requirement:
Appropriate and feasible procedures for notifying a customer who may be impacted by the de-energizing of electrical lines. The procedures shall direct notification to all public safety offices, critical first responders, health care facilities, and operators of telecommunications infrastructure with premises within the footprint of potential de-energization for a given event.
Assessment:
WMP Section 8.5 Customer Communications, describes the SFPUC procedure for communicating with stakeholders regarding potential service interruptions. The SFPUC provides retail electric service to a lodging facility which is located in the Stanislaus National Forest. This customer maintains a backup generator at their facility and experiences no operational impacts when there is an interruption in service. The SFPUC meets with this customer to provide them an overview of the SFPUC operational protocols,
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and potential impacts to them and will communicate with this customer if a service interruption is imminent.
See WMP section 4.6 for communication protocols with communication provider(s). The SFPUC has identified one wireless antenna supplied from their lines, however, the site has a backup generator and experiences no interruption in service during an SFPUC line outage.
The SFPUC does not provide electric service to any public safety offices, critical first responders, or healthcare facilities.
Comments / Recommendations:
The IE recommends the SFPUC conduct a more detailed audit to confirm there is no other commercial load supplied by the SFPUC assets.
6.8 PUC § 8387(b)(2)(H)
Requirement:
Plans for vegetation management.
Assessment:
WMP Section 7.3, Vegetation Management, describes in detail the SFPUC vegetation management (VM) inspection and maintenance programs, including substations, to meet or exceed the minimum industry standard VM practices as required by CPUC General Order 95, NERC Standard FAC-003-4, California Public Resource Codes §§ 4292 and 4293, and the California Power Line Fire Prevention Field Guide. The SFPUC also maintains very detailed internal company procedures and guidelines for VM programs. They are (1) Hetch Hetchy Water and Power (HHW) Transmission Vegetation Management Program, (2) HHW 115kV Transmission Vegetation
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Management Plan, (3) Right of Way Integrated Vegetation Management (IVM) Policy, and (4) HHW Power Distribution Vegetation Management Plan.
The use of herbicides on SFPUC property and ROW is strictly controlled by the City and County of San Francisco and San Francisco's Integrated Pest Management Ordinance (Chapter 3 of the San Francisco Environment Code).
During the 2020-2022 WMP cycle, the SFPUC hired a Right of Way (ROW) Manager, with VM experience at a California investor-owned utility. The ROW Manager has responsibility for overseeing all VM programs and VM crews.
VM crews perform work with registered professional foresters, and arborists with the following certifications, International Society of Arboriculture (ISA) Certified Arborist, ISA Certified Utility Arborist, and ISA Tree Risk Assessment Qualified (TRAQ).
Additionally, during the 2020-2022 WMP cycle the SFPUC built a “Vegetation Inspection Dashboard” (Figure 3) to track the percentage of inspections completed during the year. This dashboard is accessible to leadership to continuously track the progress of the VM program.
Figure 3 / Vegetation Inspection Dashboard
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Comments / Recommendations:
The IE commends the SFPUC for the level of detail provided in outlining the VM programs.
For the 2023-2025 WMP cycle, the IE recommends the SFPUC consider adding the number of scheduled inspections to the vegetation inspection dashboard.
6.9 PUC § 8387 (b)(2)(I)
Requirement:
Plans for inspections of the local publicly owned electric utility’s or electrical cooperative’s electrical infrastructure.
Assessment:
WMP Section 7.4, Asset Inspections, provides an overview of the SFPUC’s transmission and distribution line inspection requirements for facilities within the SFPUC HFTD, including substations, switchyards, and powerhouses. The SFPUC owns, operates, and maintains transmission and distribution lines, and substations, from the Sierra Nevada Mountains across the San Joaquin Valley and west to the South Coast Range Mountains. The SFPUC meets or exceeds the minimum inspection requirements defined in CPUC General Order 95 and 165 for electric distribution and transmission facilities, GO 174 for substations, and PRC § 4291 for defensible space requirements as they apply to substations, switchyards, and powerhouses.
Comments / Recommendations:
The IE commends the SFPUC for the level of detail provided in outlining the asset inspection programs.
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No additional recommendations.
6.10 PUC § 8387 (b)(2)(J)(i) and (ii)
Requirement:
(b)(2)(J) A list that identifies, describes, and prioritizes all wildfire risks, and drivers for those risks, throughout the local publicly owned electric utility’s or electrical cooperative’s service territory. The list shall include, but not be limited, to both of the following:
(b)(2)(J)(i) Risks and risk drivers associated with design, construction, operation, and maintenance of the local publicly owned electric utility’s or electrical cooperative’s equipment and facilities.
(b)(2)(J)(ii) Particular risks and risk drivers associated with topographic and climatological risk factors throughout the different parts of the local publicly owned electric utility’s or electrical cooperative’s service territory.
Assessment:
WMP Section 6, Wildfire Risks and Risk Drivers describes the risks and risk drivers associated with topographic, climatological, design, construction, operation, and maintenance risk factors associated with SFPUC electrical assets within the HFTD.
Although the SFPUC does not have a documented history of fire risk incidents caused by failure of their electrical assets they have identified vegetation contact as a risk driver for a possible wildfire ignition from electrical facilities. In the absence of substantial documented historical data regarding equipment failures, the SFPUC has identified a number of potential risks based on the experience of their long-term employees and has
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instituted various risk reduction programs as described in Section 6.3 of the WMP.
Approximately 35% of the SFPUC’s service territory is within the HFTD, and per SFPUC assessment, poses minimal risk for the ignition of a catastrophic wildfire. SFPUC topographic risks are located on the west side of the Sierra Nevada Mountain range and the South Coast Mountain range. Some of these mountain areas could have dense vegetation and steep terrain. A large portion of the SFPUC service area is in the San Joaquin Valley consisting of flat terrain covered with frequently irrigated crops that pose no risk for a catastrophic wildfire. The climatological risk factors experienced within the SFPUC area of operation are consistent with what is experienced throughout California. Those risks are associated with (1) extended drought conditions, (2) lack of early fall rains, (3) hot temperatures, (4) high winds, (5) steep terrain, and (6) vegetation type and density.
Comments / Recommendations:
The IE recommends that the HHWP, NLRM, and WST Divisions leverage its newly acquired risk modeling tool, Wildfire AnalystTM, to identify areas of higher risk and inform the prioritization of risk reduction programs in those areas.
6.11 PUC § 8387 (b)(2)(K)
Requirement:
Identification of any geographic area in the local publicly owned electric utility’s or electrical cooperative’s service territory that is a higher wildfire threat than is identified in a commission fire threat map, and identification of where the commission should expand a high fire threat district based on new information or changes to the environment.
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Assessment:
WMP Section 6.4.1, Changes to the CPUC Fire Threat Map, states the SFPUC’s agreement with the existing CPUC HFTD boundaries and makes no recommendation for expanding or minimizing the current HFTD boundaries.
Comments / Recommendations:
No further comments or recommendations.
6.12 PUC § 8387 (2)(L)
Requirement:
A methodology for identifying and presenting enterprise-wide safety risk and wildfire-related risk.
Assessment:
WMP Section 6.1, Enterprise-Wide Safety Risks, describes the SFPUC’s enterprise wildfire risk reduction methodology. As the SFPUC continues to build out its enterprise fire-risk mitigation program framework, it will continue to rely on the institutional knowledge of its employees with extensive maintenance and operations experience to inform the company of potential safety and reliability risks. The SFPUC, for the foreseeable future, will continue to de-energize circuit(s) as needed during critical fire weather conditions to reduce the risk of their facilities being the origin or contributing source for the ignition of a wildfire. The SFPUC also closely monitors wildfire incidents impacting other utilities to gain knowledge of trends throughout the industry and how grid improvements/upgrades can be applied at the SFPUC to reduce the risk of similar occurrences.
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Comments / Recommendations:
The SFPUC continues to build a database to record risk events that will inform risk trends and areas of improvement. The IE recommends the SFPUC leverage this information to develop more risk-informed wildfire mitigation programs and initiatives and prioritize those programs to the areas of highest risk for wildfire.
The IE recommends the SFPUC (HHWP, NLRM, WST) utilize the Wildfire Analyst
TM risk modeling tool to provide a more risk-informed analysis of areas near SFPUC assets that could be of higher risk for a catastrophic wildfire than previously identified. The IE also recommends the SFPUC provide an update in their 2024 WMP.
The IE also recommends the SFPUC (HHWP, NLRM, WST) develop a corporate enterprise fire risk management plan to identify, prioritize and support overall risk reduction efforts.
6.13 PUC § 8387 (2)(M)
Requirement:
A statement of how the local publicly owned electric utility or electrical cooperative will restore service after a wildfire.
Assessment:
WMP Section 9, Restoration of Service, describes SFPUC’s procedures for restoring electrical service following a de-energization event or if a line experiences an unplanned (forced) interruption for any reason, including a wildfire. The SFPUC has well-defined standard operating procedures for
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safely restoring service following an interruption or other events that might cause significant infrastructure damage.
For restoration of service after a wildfire, the SFPUC states “Following a wildfire, the SFPUC will restore service when it is safe for staff to access the damaged area(s). The SFPUC will not access burn areas until the agency having jurisdiction (i.e., CAL FIRE, USFS, local fire agency) grants permission to enter the burn area to conduct a damage
assessment. Following a full damage assessment (patrol), if required, the SFPUC will perform repairs, and restoration will proceed following established priority and restoration procedures”.
Comments / Recommendations:
The SFPUC follows utility best practices for service restoration. No further comments or recommendations.
6.14 PUC § 8387 (2)(N) (i), (ii) and (iii)
Requirement:
A description of the processes and procedures the local publicly owned electric utility or electrical cooperative shall use to do all of the following:
(2)(N)(i) Monitor and audit the implementation of the wildfire mitigation plan.
(2)(N)(ii) Identify any deficiencies in the wildfire mitigation plan or its implementation and correct those deficiencies.
2(N)(iii) Monitor and audit the effectiveness of electrical line and equipment inspections, including inspections performed by contractors, that are carried out under the plan, other applicable statutes, or commission rules.
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Assessment:
WMP Section 9, Evaluating Performance of the Plan, describes in detail the methodology employed by the SFPUC for monitoring and auditing the WMP implementation, and monitoring the effectiveness of the various mitigation programs described in their WMP. The SFPUC leadership is responsible for ensuring compliance with SFPUC’s wildfire mitigation programs outlined in their WMP, and the Assistant General Manager of Water has overall accountability for the development and implementation of the Plan. All specific wildfire mitigation program responsibilities are delegated to leadership in HHWP, NLRM, and WST overseeing their respective divisions.
The three metrics listed in the SFPUC 2019 WMP served as the baseline year metrics to assess the Plan performance. The SFPUC has added additional metrics to monitor the WMP performance. The SFPUC has also adopted the WSAB recommendation to list separate metrics by category of Outcome Metrics and Performance Metrics.
The SFPUC power grid is very reliable and does not experience a high number of risk events, which contributes to the limited amount of data available for the Outcome Metrics.
During the 2020-2022 WMP cycle, the HHWP division built tools to monitor and document the relevant data to track the effectiveness of the programs they describe in their WMP. One example is the Vegetation Inspection Dashboard as previously shown in Figure 3 which tracks the daily progress of vegetation management work.
For the 2023-2025 WMP cycle, the IE recommends the Vegetation Inspections Dashboard include data from NLRM and WST.
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During the 2020-2022 WMP cycle, the SFPUC assigned a Wildfire Mitigation & Recovery Analyst (WMRA) position dedicated to overseeing the overall development and maintenance of the SFPUC WMP. The WMRA is the lead of an internal SFPUC team responsible for reviewing and monitoring the progress of the SFPUC wildfire mitigation programs and monitoring the effectiveness of their Plan. This team, with representation from HHWP, NLRM, and WST, meets monthly, or as required. The WMRA is also the primary SFPUC liaison with the CMUA for all wildfire mitigation discussions.
Comments / Recommendations:
1. The SFPUC reports total completed outcome metrics for vegetation and asset inspections. The IE recommends the SFPUC also provide the number of inspections scheduled to the metric table to show the number completed versus the number scheduled.
2. The SFPUC must be commended on continuing to look for opportunities to reduce the risk of their assets being the origin or contributing source for the ignition of fire by documenting relevant data to better inform the effectiveness of their wildfire mitigation initiatives.
7.0 Summary
SFPUC’s primary goal is to construct, maintain, and operate its electrical lines and equipment in a manner that will minimize the risk of wildfire posed by those electrical lines and equipment, and maintain compliance with PUC § 8387.
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145 Parkshore Drive, Suite 140, Folsom, CA 95630
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[email protected]
Following this independent evaluation of the SFPUC’s 2023 WMP, GridSME concludes the Plan is comprehensive and meets the requirements of PUC § 8387.
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619-564-9464
Daniel J. Zaragoza
President & CEO
Zaragoza Consulting, Inc.
Daniel Zaragoza is a retired utility executive with over 40 years of extensive electric operations experience,
specializing in electric transmission and distribution
operations, emergency management, and fire risk
mitigation.
Mr. Zaragoza founded Zaragoza Consulting, Inc., in 2017 and specializes in providing consulting and advisory
services to electric utilities in the area of power distribution and transmission operations, with an emphasis on the
development and management of wildfire mitigation
programs. Most recently Zaragoza has provided wildfire
mitigation consulting, strategy and advisory services to a number of California investor owned utilities (IOU) and publicly owned utilities (POU). He has conducted wildfire mitigation plan reviews and written reports as an Independent Evaluator for POUs, which are submitted to the CA Wildfire Safety Advisory Board. Mr. Zaragoza has been retained by firms such as Luz Del Sur (South America), KPMG, GridSME, Technosylva, AlphaStruxure, Burns & McDonnell, Capstone Fire Management, and Utility Safety Associates to support wildfire mitigation plan development supporting utilities in California, Oregon, and Washington.
Mr. Zaragoza retired from San Diego Gas & Electric, one of Sempra Energy’s regulated California utilities serving 3.6 million customers in San Diego and Southern Orange Counties in April 2017. Prior to Mr. Zaragoza’s retirement he was Director of Emergency Management and was responsible for managing and executing the utility’s response to major emergencies that had the potential to cause severe customer and infrastructure impacts to the gas and electric system in San Diego – the second largest city in the state of California. Zaragoza managed both the Fire Coordination and Meteorological teams to ensure operational decisions were made using data and expertise from weather and fire mitigation experts. As part of the company’s commitment to keeping the communities it serves safe, Zaragoza was instrumental in developing one of the most comprehensive and robust fire risk mitigation programs in the industry designed to improve grid safety, reliability, and resiliency. This included significant strategic investments to fire-harden the power grid, increase situational awareness, update operating protocols, including public safety power shutoffs, and enhance the region’s ability to respond to wildfires.
2 Under his leadership, Zaragoza launched the Meteorology team which continues to play a critical role in identifying mitigating solutions to the challenges of a dramatically changing climate.
Mr. Zaragoza has an extensive background in the electric sector, a rapidly changing industry that is currently undergoing a major transformation as power providers work to meet stringent state sustainability and climate goals. As a former director of electric distribution operations, Zaragoza managed a power grid serving millions of people, pioneered the launch of technologies and programs that would enhance employee and public safety, reliability and help reduce climate and weather-related risks and vulnerabilities, such as wildfire. Under his leadership, SDG&E was recognized as a best- in-class, award-winning reliability program enhancing customer satisfaction.
During his tenure, Zaragoza helped lay the foundation for a more resilient grid by partnering with the public and private sectors, academia and government agencies to accelerate investments in technologies, practices, and policies. Some examples include the development and deployment of America’s largest utility-owned weather network, deploying major capital projects, and working to become the first utility in the nation to obtain FAA approval to test fly Unmanned Aerial Vehicles (drones) in select test areas.
Zaragoza is a current board member of TACIT, and Disaster Tech; is a past board member of the California Utilities Emergency Association (CUEA) and co-chair of its energy committee; and advisory board member for the San Diego Padres Hispanic Community Council. Zaragoza holds a bachelor’s degree in business management from the University of Redlands.
Daniel J. Zaragoza
President & CEO
Zaragoza Consulting, Inc.
2936 Winding Fence Way
Chula Vista, CA 91914
[email protected]
619.564.9464