2026-2028 San Francisco Public Utilities Commission
Wildfire Mitigation Plan (WMP)
October 13, 2026
Ethan Billigmeier, Wildfire Mitigation Specialist
Hetch Hetchy Water and Power
Water Enterprise
1 Background
• After an amendment to Public Utilities Code (PUC) Section 8387 the SFPUC is required to prepare and submit wildfire mitigation plans to the California Office of Energy Infrastructure Safety (OEIS) Wildfire Safety Advisory Board (WSAB) on biennial basis starting on or before October 2, 2026.
• Now, at least once every four years, the WMP must be
independently evaluated. The last independent evaluation was performed on the 2023 SFPUC WMP.
2 3
• Overhead Dist.: 48.9 miles
• Tier 2: 86.7%
• Tier 3: 8.5%
• Overhead Trans.: 324.4 miles
• Tier 2: 26.1%
• Tier 3: 3%
SFPUC Electrical Lines in the HFTD
4 • 438 poles inspected/3 cross arms
replaced.
• Intrusive inspections on 336 poles/6
poles replaced.
• 273 trees removed along the Right
of Way.
• All 5 substations inspected once a
month.
• Partnership with UC San Diego to
install Starlink satellite internet on
Moccasin Peak camera. Satellite
offers less interruption than a
cabled connection.
2025 Plan Accomplishments
5 • Completed Installation of
Hexion ArmorBuilt
pole
wrap on 297 distribution
poles in the upcountry
HFTD.
• An additional 67 poles will
be wrapped in the Sunol
area HFTD in 2026/27.
Construction: Pole Wrapping in HFTD
6 • 4292 Non-exempt
Equipment Replacement
to reduce the potential for
fire-causing sparks during
electrical fault events.
• Completed assessment
and initiated procurement
process.
Construction: Non-Exempt Equipment
Replacement
7 • Natural Resources and Lands
Management Division
supported CALFIRE to
perform a 52-acre prescribed
burn in the Peninsula
Watershed.
Prescribed burns
2025 Performance Metrics
8 2025 Outcome Metrics
9 10
• “SFPUC expand the
documented VM and line
inspection procedures to
encompass the Water Supply
and Treatment and the Natural
Resources and Lands
Management divisions.”
• “Based on an Independent
Evaluation of SFPUC’s 2026–
2028 WMP, GridSME finds
that the Plan is
comprehensive and satisfies
the requirements of Public
Utilities Code § 8387.”
Independent Evaluator’s Assessment and
Recommendations
DEPARTMENT
Water Enterprise
AGENDA NO.
14 MEETING DATE October 13, 2026
AGENDA ITEM
Public Utilities Commission
City and County of San Francisco
Calendar: Regular Calendar
Contract/Project Manager: Adam Mazurkiewicz
Adopt the 2026–2028 San Francisco Public Utilities Commission (SFPUC) Wildfire Mitigation Plan and Independent Evaluator Report
Summary of Proposed
Commission Action:
Adopt the 2026 –2028 Wildfire Mitigation Plan (WMP) and Independent Evaluator Report and authorize the SFPUC General Manager to file the Wildfire Mitigation Plan and Independent Evaluator Report with the California Office of Energy Infrastructure Safety (OEIS) Wildfire Safety Advisory Board (WSAB) on or before October 2, 2026.
Background: After an amendment to Public Utilities Code (PUC) Section 8387 , the SFPUC is required to prepare and submit wildfire mitigation plans to the California Office of Energy Infrastructure Safety (OEIS) Wildfire Safety Advisory Board (WSAB) on a biennial basis starting on or before October 2, 2026.
The 2026–2028 SFPUC Wildfire Mitigation Plan is the seventh plan presented to the Commission. The previous six plans were adopted on an annual basis by Commission Resolution, most recently in Resolution No. 25-0092.
As required by Public Utilities Code Section 8387, the 2026 –2028 SFPUC Wildfire Mitigation Plan was independently evaluated. The Independent Evaluator assessed the Plan for compliance with applicable statutory requirements and evaluated the
reasonableness and effectiveness of the SFPUC's wildfire mitigation programs and proposed mitigations. The Independent Evaluator Report is included with this agenda item for the Commission's review and consideration.
The 2026 –2028 SFPUC Wildfire Mitigation Plan is the first plan submitted under the biennial filing schedule established by the WSAB and reflects the SFPUC's continued commitment to reducing wildfire risk through system hardening, vegetation management, operational improvements, and continuous refinement of its wildfire mitigation program.
Agenda Title: Adopt the 2026-2029 SFPUC Wildfire Mitigation Plan and Independent Evaluator Report Commission Meeting Date: October 13, 2026
2025 accomplishments include:
• Risk Assessment - SFPUC continued to refine and expand its use of Technosylva’s Wildfire Operations (Professional) to monitor fire weather conditions across both the Sierra Nevada and Bay Area regions.
• Situational Awareness - In 2025, SFPUC worked with UC San Diego to install Starlink satellite internet on the Moccasin Peak ALERTCalifornia cameras. Starlink offers a faster and less interruptible camera live feed. Using Wildfire Operations (Professional)™, the SFPUC maintains an integrated view of weather stations and high-definition cameras hosted through the ALERTCalifornia network . Approximately 80% of our
overhead electrical system is within a camera viewshed, enabling faster detection of wildfire smoke and other
conditions that could negatively impact our operations and prompt timely dispatch of fire personnel.
• Vegetation Management – refined the e-Logger alerting program for unplanned outages so Right of Way staff gets notified when an unplanned outage occurs and can assess whether an outage was vegetation -related. Natural
Resources and Lands Management supported CAL FIRE to
perform 52 acres of control burns in the Peninsula
watershed. A total of 273 trees were trimmed or removed along the SFPUC Right-of-Way.
• Construction, Operations, and Maintenance – Completed installation of fire protection wrap on upcountry distribution poles, bringing the total to 288 wrapped poles . Also, began procuring equipment to replace non -exempt equipment
which will reduce the potential for fire-causing sparks during electrical fault events. 336 distribution poles were tested for rot; 6 poles were replaced due to failed tests; 438 poles were inspected; and, 3 wooden cross arms were replaced with
fiberglass for increased durability.
• Digital Accessibility – The 2026-2028 WMP and Independent Evaluator will be reviewed and modified to ensure
compliance with Americans with Disabilities Act (ADA) digital accessibility requirements before the Plan and the
Independent Evaluator Report will be posted to the
SFPUC.gov webpage.
The SFPUC WMP will continue to mature and will be updated on the biennial schedule established by the WSAB, while the SFPUC continues to implement, monitor, and improve its wildfire mitigation programs on an ongoing basis.
Agenda Title: Adopt the 2026-2029 SFPUC Wildfire Mitigation Plan and Independent Evaluator Report Commission Meeting Date: October 13, 2026
Funding and Costs: Funding Source: Funds for WMP activities, programs, and projects are available from current and future appropriations to Water Enterprise and Hetch Hetchy Water and Power operating and capital budgets.
Environmental
Review:
This action does not constitute a project under the California Environmental Quality Act (CEQA) Guidelines Section 15378 because it will not result in a physical change in the environment.
This action is not an approval of any specific project. Staff will not authorize any work involving ground disturbance (such as vegetation removal) or any other physical changes in the environment until any necessary environmental review has been completed pursuant to the CEQA.
Attachment(s): 1. 2026–2028 SFPUC WMP
2. 2026–2028 SFPUC WMP Independent Evaluator Report
PUBLIC UTILITIES COMMISSION
City and County of San Francisco
RESOLUTION NO.
WHEREAS, Public Utilities Code Section 8387 requires that a local publicly owned utility or electrical cooperative, such as the San Francisco Public Utilities Commission (SFPUC), prepare and submit a Wildfire Mitigation Plan (WMP), following public review and comment, to the California Office of Energy Infrastructure Safety Wildfire Safety Advisory Board (WSAB); and
WHEREAS, WSAB requires SFPUC to file a WMP on a biennial schedule starting on or before October 2, 2026; 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 (CPUC) has designated as High Fire Threat Districts (HFTD); and
WHEREAS, The 2026–2028 SFPUC WMP marks the seventh plan that has been brought before this Commission. The previous six Plans were adopted by Commission Resolution; the last one was adopted in Resolution 25-0092; and
WHEREAS, Staff prepared the 2026 –2028 SFPUC Wildfire Mitigation Plan in accordance with Public Utilities Code Section 8387, as amended by Senate Bill 254 (2023), and the Plan was independently evaluated as required by statute; and
WHEREAS, The Independent Evaluator Report concludes that the 2026 –2028 SFPUC Wildfire Mitigation Plan satisfies the applicable statutory requirements and provides an independent assessment of the Plan's reasonableness and effectiveness; and
WHEREAS, Staff presents to this Commission the 2026 –2028 SFPUC Wildfire Mitigation Plan and the accompanying Independent Evaluator Report; and
WHEREAS, This action does not constitute a project under the California Environmental Quality Act (CEQA) Guidelines Section 15378 because it will not result in a physical change in the environment; and
WHEREAS, This action is not an approval of any specific project and staff will not authorize any work involving ground disturbance (such as vegetation removal) or any other physical changes in the environment until any necessary environmental review has been completed pursuant to the CEQA; and
WHEREAS, Funds for WMP activities, programs, and projects are available from current and future appropriations to Water Enterprise and Hetch Hetchy Water and Power operating and capital budgets; now, therefore, be it,
RESOLVED, That this Commission adopts the 2026 –2028 SFPUC Wildfire Mitigation Plan, receives the Independent Evaluator Report prepared pursuant to Public Utilities Code Section 8387, and authorizes the General Manager, or the General Manager's designee, to submit the Plan and Independent Evaluator Report to the California Office of Energy Infrastructure Safety (OEIS) Wildfire Safety Advisory Board (WSAB) on or before October 2, 2026; and, be it,
FURTHER RESOLVED, That this Commission hereby authorizes the General Manager, or the General Manager’s designee, to post the 2026–2028 SFPUC Wildfire Mitigation Plan and Independent Evaluator Report on the SFPUC website and to submit both documents with the WSAB with any nonmaterial changes or modifications, as may be acceptable to the General Manager.
I hereby certify that the foregoing resolution was adopted by the San Francsico Public Utilities Commission at its meeting of October 13, 2026.
Director of Commission Affairs
San Francisco Public Utilities Commission
San Francisco Public Utilities Commission
2026-2028 Wildfire Mitigation Plan
TABLE OF CONTENTS
1. EXECUTIVE SUMMARY ____________________________________________________ 1
2. OBJECTIVES OF THE WILDFIRE MITIGATION PLAN ______________________________ 4
2.1. Minimizing Sources of Ignition __________________________________________________ 4
2.2 Improve Grid Reliability and Resiliency ___________________________________________ 4
2.3 Measuring Plan Effectiveness ___________________________________________________ 5
2.4 Statutory Cross-Reference Table ________________________________________________ 5
2.5 Utility Overview and Context Setting Table _______________________________________ 10
3. OVERARCHING INITIATIVES FOR THE 2026-2028 WMP _________________________ 16
3.1 Wildfire Mitigation Operating and Capital Budgets _________________________________ 16
4. SUMMARY OF 2025 WILDFIRE MITIGATION ACTIVITIES ________________________ 23
4.1 Risk Assessment _____________________________________________________________ 23
4.2 Situational Awareness ________________________________________________________ 23
4.3 Vegetation Management _____________________________________________________ 24
4.4 Construction, Operations, and Maintenance ______________________________________ 25
5. ROLES AND RESPONSIBILITIES _____________________________________________ 28
5.1 SFPUC Division Responsibilities ________________________________________________ 28
5.2 WMP Adoption Process _______________________________________________________ 30
6. WILDFIRE RISKS AND RISK DRIVERS ________________________________________ 31
6.1 Enterprise-Wide Safety Risks __________________________________________________ 31
6.2 Risks and Risk Drivers Associated with Topographic and Climatological Risk Factors ______ 31
6.3 Risks and Risk Drivers Associated with Design, Construction, Operations, and Maintenance 32
6.4 High Fire Threat District ______________________________________________________ 33
6.5 Changes to CPUC Fire Threat Map ______________________________________________ 37
6.6 Fire Hazard Severity Zone Map _________________________________________________ 37
6.7 Climate Change / Weather Risks ________________________________________________ 39
7. WILDFIRE PREVENTATIVE STRATEGIES ______________________________________ 41
7.1 Situational Awareness ________________________________________________________ 41
7.1.1 Technosylva Wildfire Operations (Professional) / Fire Potential Index (FPI) ______________________ 41
7.1.2 Weather Monitoring __________________________________________________________________ 42
7.1.3 Weather Stations _____________________________________________________________________ 43
7.1.4 ALERTCalifornia Cameras ______________________________________________________________ 45
7.1.5 Air Quality Monitoring_________________________________________________________________ 47
7.2 Design and Construction Standards _____________________________________________ 47
7.3 System Hardening ___________________________________________________________ 48
7.3.1 Replace Wood Poles __________________________________________________________________ 48
7.3.2 Pole Wrap __________________________________________________________________________ 48
7.3.3 Replacement of Non-Exempt Equipment __________________________________________________ 49
7.3.4 Avian Protection _____________________________________________________________________ 49
7.3.5 Overhead to Underground Conversion ___________________________________________________ 49
7.3.6 Alternate Generation Source ___________________________________________________________ 50
7.4 Vegetation Management _____________________________________________________ 50
7.4.1 Annual Vegetation Management Work Plan _______________________________________________ 53
7.4.2 Vegetation Inspections for Transmission Lines _____________________________________________ 53
7.4.3 Vegetation Inspections for Distribution Lines ______________________________________________ 54
7.4.4 Vegetation Inspections for Substations, Switchyards, Powerhouses, and Habitable Structures _______ 54
7.4.5 PRC § 4292 Firebreak Clearance Requirements _____________________________________________ 55
7.4.6 Herbicide Use ________________________________________________________________________ 56
7.4.7 Satellite Vegetation Monitoring _________________________________________________________ 56
7.4.8 Vegetation Management Dashboard _____________________________________________________ 56
7.4.9 Defensible Space Inspections ___________________________________________________________ 59
7.4.10 Integrated Vegetation Management (IVM) _______________________________________________ 59
7.4.11 Vegetation Management Contracts _____________________________________________________ 59
7.4.12 Quality Assurance / Quality Control (QA/QC) _____________________________________________ 63
7.5 Overhead Asset Inspections ___________________________________________________ 63
7.5.1 Asset Management System _____________________________________________________________ 63
7.5.2 Transmission Inspections and Maintenance _______________________________________________ 65
7.5.3 Hot or Cold Wash_____________________________________________________________________ 65
7.5.4 Distribution Inspections and Maintenance ________________________________________________ 66
7.5.5 Drone Inspections ____________________________________________________________________ 67
7.6 Powerhouse / Substation / Switchyard Inspections and Maintenance _________________ 67
7.7 Workforce Training __________________________________________________________ 68
7.7.1 Basic Fire Training ____________________________________________________________________ 69
7.7.2 VM Training _________________________________________________________________________ 69
7.8 Recloser Policy ______________________________________________________________ 69
7.9 Operational / Emergency Response Procedure ____________________________________ 70
7.10 Standardized Emergency Management System ____________________________________ 70
7.11 De-energization for Public Safety _______________________________________________ 71
7.11.1 Impacts on Public Safety ______________________________________________________________ 74
7.11.2 Customer Notification Protocols________________________________________________________ 74
7.11.3 Restoration of Service ________________________________________________________________ 74
8. STAKEHOLDER OUTREACH AND ENGAGEMENT _______________________________ 76
8.1 Coordination with Critical Infrastructure Sectors __________________________________ 76
8.1.1 Water and Wastewater Systems Sectors __________________________________________________ 76
8.1.2 Communications Sector _______________________________________________________________ 76
8.1.3 Healthcare and Public Health Sectors _____________________________________________________ 76
8.2 Fire Agency (First Responder) Collaboration ______________________________________ 76
8.3 California Municipal Utilities Association (CMUA) Collaboration ______________________ 78
8.4 Mutual Assistance Agreements ________________________________________________ 78
9. EVALUATING THE PERFORMANCE OF THE PLAN ______________________________ 80
9.1 Metrics and Assumptions for Measuring Plan Performance __________________________ 80
9.2 Impact of Metrics on Plan _____________________________________________________ 80
9.3 Monitoring and Auditing the Plan ______________________________________________ 81
9.4 Monitoring the Effectiveness of the Plan _________________________________________ 81
9.5 Corrective Action Program ____________________________________________________ 82
10. INDEPENDENT EVALUATOR REPORT ________________________________________ 83
Acronyms
AFDR Adjective Fire Danger Rating
AGM Assistant General Manager
AI Artificial Intelligence
ANSI American National Standards Institute
AVMWP Annual Vegetation Management Work Plan
BES Bulk Electric System
BLM Bureau of Land Management
BMP Best Management Practice
CAISO California Independent System Operator
CALFIRE California Department of Forestry and Fire Protection CCA Community Choice Aggregator
CCAA Candidate Conservation Agreement with Assurances
CCSF City and County of San Francisco
CEQA California Environmental Quality Act
Commission San Francisco Public Utilities Commission (SFPUC) CM Corrective Maintenance
CMMS Computerized Maintenance Management System - SFPUC uses Maximo (IBM™) as the enterprise CMMS
CPUC California Public Utilities Commission
CUEA California Utilities Emergency Association
DVMP Distribution Vegetation Management Plan
e-Logger Electronic Log used by Hetch Hetchy Water to collect, store, and distribute real-time data
ESF Emergency Support Functions
ESO Electrical Safety Orders, State of California
ESRI Environmental Systems Research Institute, Inc. - A geographic information system software company
FAC-003 NERC Reliability Standard: Transmission Vegetation Management Program
FHSZ Fire Hazard Severity Zone
FPI Fire Potential Index
FY Fiscal Year
GO CPUC General Order
HFT / HFTD High Fire Threat / High Fire Threat District HHWP Hetch Hetchy Water and Power
HHW
Hetch Hetchy Water - This Division of Hetch Hetchy Water and Power is managed by the Water Enterprise, commonly referred to as Hetch Hetchy Water and Power (HHWP)
HHZ High Hazard Zone
HRRR NOAA's High-Resolution Rapid Refresh Model
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 Electrical Code
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
NRLMD Natural Resources and Lands Management, a division of the Water Enterprise
NWS National Weather Service
OEIS
Office of Energy Infrastructure Safety (or Energy Safety) – Ensures electrical utilities are taking effective actions to reduce utility -related wildfire risk
OH Overhead
PAL Project Activity Level
PG&E Pacific Gas & Electric
PIO Public Information Officer
Plan Wildfire Mitigation Plan (WMP)
PM Preventative Maintenance
POU Publicly Owned Utility
PRC Public Resources Code
PSPS Public Safety Power Shutoff
PUC Public Utilities Code
QA/QC Quality Assurance/Quality Control
QEW Qualified Electrical Worker
RAWS Remote Automatic Weather Station – Provides local weather data used primarily in fire management
RFW
Red Flag Warning – Issued by the National Weather Service when warm temperatures, very low humidity, and strong 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
UCSD University of California San Diego
USFS United States Forest Service
VM Vegetation Management
WMP Wildfire Mitigation Plan
WSAB Wildfire Safety Advisory Board
WSTD Water Supply & Treatment, a division of the Water Enterprise
LIST OF FIGURES
1 SFPUC Organization
2 CPUC HFTD Map
3 SFPUC Electrical Assets and HFTDs
4 CALFIRE SRA FHSZ Map
5 Weather Stations
6 ALERTCalifornia Cameras
7 Air Quality Monitors
8 Example Distribution ROW
9 PRC § 4292 Firebreak Clearance Requirements
10 Vegetation Management Dashboard
11 2025 NRLMD Prescribed Burn Area
12 Previous NRLMD/CALFIRE Prescribed Burn Areas
13 HHW Line Crew Hot Washing
14 Drone Photo of a Distribution Pole
15 CALFIRE Firehawk Helicopter
16 Performance Metrics Trends Since 2019
LIST OF TABLES
1 PUC § 8387 Statutory Requirements
2 Context Setting Table
3 Distribution System Hardening
4 Plan Activities Roles and Responsibilities
5 Maximo Workflow
6 Infrared Inspections
Cover photo courtesy of Troy Harris, Transmission Line
Supervisor – Hetch Hetchy Water and Power.
1 1. EXECUTIVE SUMMARY
The San Francisco Public Utilities Commission (SFPUC) 2026 –2028 Wildfire Mitigation Plan (WMP or Plan) describes the programs, practices, and investments SFPUC uses to minimize the risk that its electrical facilities could be the origin or contributing source of a catastrophic wildfire. This Plan is the first submitted under the new schedule established by the Wildfire Safety Advisory Board.1 The Plan reflects SFPUC’s continued commitment to operating a safe, reliable, and resilient electrical system while adapting its wildfire mitigation practices to changing environmental conditions, emerging technologies, lessons learned, and industry best practices.
SFPUC owns and operates hydroelectric generation facilities and approximately 324 circuit miles of overhead transmission lines and 48.9 circuit miles of overhead distribution lines extending from the Sierra Nevada mountains through the Central Valley and into the San Francisco Bay Area. Portions of this infrastructure are in areas designated by the California Public Utilities Commission as Tier 2 and Tier 3 High Fire -Threat Districts.
SFPUC’s wildfire risk varies considerably across this geographically diverse system and is influenced by factors including drought, high temperatures, wind, steep terrain, vegetation type and density, lightning, aging infrastructure, and the location of electrical facilities in fire-prone areas.
SFPUC’s wildfire mitigation strategy emphasizes prevention, situational awareness, system resilience, and preparedness. Key measures include routine inspection and maintenance of transmission and distribution assets; vegetation management; system hardening and replacement of equipment to reduce ignition potential; weather and fire- risk monitoring; workforce training; emergency response coordination; and protocols for recloser operations and de-energization during critical fire weather conditions. Vegetation management remains a cornerstone of the program, supported by annual inspections, hazard-tree removal, Integrated Vegetation Management, satellite vegetation monitoring,
1 See Office of Energy Infrastructure Safety Wildfire Safety Advisory Board, 2026 –2029 Wildfire Mitigation Plan Schedule for Publicly Owned Utilities and Electrical Cooperatives (Dec. 2025).
2 prescribed burning and fuel-reduction activities, and quality assurance and quality control.
SFPUC has also expanded its use of technology to support risk -informed operational decisions. Technosylva Wildfire Operations (Professional)™ provides daily Fire Potential Index ratings across nine geographic zones and forecasts potential wildfire consequences for individual SFPUC assets. The platform integrates weather information, fire incidents, weather stations, and ALERTCalifornia camera feeds to improve situational awareness and inform operational restrictions, inspection priorities, vegetation management, system hardening, and potential de-energization decisions.
During 2025, SFPUC continued routine inspection, maintenance, vegetation management, and operational activities while advancing several wildfire mitigation initiatives. SFPUC expanded its use of Wildfire Operations (Professional) ™, refined vegetation inspection and tracking through ArcGIS Field Maps and satellite imagery, and continued infrastructure- hardening efforts. The Plan reports completion of scheduled distribution and transmission patrol and vegetation inspections during 20 25, including approximately 46 circuit miles of distribution patrol and vegetation inspections and 324 circuit miles of transmission patrol and vegetation inspections.
For the 2026–2028 planning period, SFPUC will continue to mature its wildfire mitigation program while maintaining compliance with California Public Utilities Code (Pub. Util.
Code) § 8387. Priorities include further development of wildfire risk modeling capabilities, continued use of performance metrics to evaluate program effectiveness, and evaluation and prioritization of system -hardening opportunities. Planned and ongoing investm ents include transmission life- extension and distribution- upgrade programs, vegetation and fuel-reduction projects, replacement of non-exempt electrical equipment, pole protection, backup generation, and targeted conversion of overhead distribution facilities to underground facilities where appropriate.
SFPUC evaluates the effectiveness of these efforts through performance and outcome metrics and uses the results to refine future mitigation activities. The Plan reports that wildfire-related risk indicators have generally improved over the past seven years , including reductions in wire- down events and de- energization events and no reportable
3 ignitions in High Fire -Threat District areas from 2022 through 2025. The largest contributor to improving the risk indicators is vegetation management . SFPUC will continue monitoring Plan implementation, including vegetation management, evaluating new technologies and industry practices, and using performance data to guide future investments and operational decisions.
Through this Plan, SFPUC continues a risk -informed and continuously improving approach to wildfire mitigation that combines established utility practices with enhanced technology, vegetation management, infrastructure investment, emergency preparedness, and coordination with fire agencies and other stakeholders. These efforts are intended to reduce wildfire ignition potential w hile maintaining the reliability and resilience of the electrical infrastructure that supports SFPUC’s water and power operations.
4 2. OBJECTIVES OF THE WILDFIRE MITIGATION PLAN
This Plan provides a comprehensive overview of the SFPUC programs and initiatives that seek to minimize the risk that SFPUC electrical assets will be the origin or contributing source for a catastrophic wildfire. It is the goal of the SFPUC to maintain compliance with our statutory obligation as specified in Pub. Util. Code § 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.”
2.1. Minimizing Sources of Ignition
The first objective continues to be inspecti ons, maintenance, and replacement of our physical assets, to minimize the risk of SFPUC electrical 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 hardening, increased situational awareness capabilities by adding more strategically placed weather stations, 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 imple ment 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 the industry’s best practices and new technologies that could help reduce the likelihood of a disruption in service due to planned
5 or unplanned events and expedite grid recovery efforts following a significant event, such as wildfire.
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 and make Plan modifications , as necessary, to improve the safety, reliability, and resilience 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.
2.4 Statutory Cross-Reference Table
Our Plan complies with P ub. Util. Code § 8387 statutory requirements listed in Table 1 .
The table also provides a reference to where the requirements are described in the Plan (Plan Section column).
Table 1 – Pub. Util. Code § 8387 Statutory Requirements PUC Code 8387 Compliance Requirements 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, prepare a wildfire
mitigation plan. After January 1, 2026,
a local publicly owned electric utility or
electrical cooperative shall prepare a
1 6
PUC Code 8387 Compliance Requirements Plan Section
wildfire mitigation plan and shall submit
the plan to the California Wildfire
Safety Advisory Board at least once
every four years on a schedule
determined by the California Wildfire
Safety Advisory Board
(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.
5 (b)(2)(B)
The objectives of the wildfire mitigation
plan.
2.0 (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.
7 (b)(2)(D)
A description of the metrics the local
publicly owned electric utility or
electrical cooperative plans to use to
measure and track the implementation
of the plan and the assumptions that
underlie the use of those metrics.
9.1 (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.
9.2 (b)(2)(F)
Protocols for disabling reclosers and
deenergizing portions of the electrical
distribution system that consider the
7.8, 7.11, and 8.1
7 PUC Code 8387 Compliance Requirements Plan Section
associated impacts on public safety,
and protocols related to mitigating the
public safety impacts of those
protocols, including impacts on critical
first responders and on health and
communication infrastructure.
(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.
7.11.2 (b)(2)(H) Plans for vegetation management. 7.4
(b)(2)(I)
Plans for inspections of the local
publicly owned electric utility’s or
electrical cooperative’s electrical
infrastructure.
7.5 and 7.6
(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:
6 (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.
6.3 (b)(2)(J)(ii)
Particular risks and risk drivers
associated with topographic and
6.2 8
PUC Code 8387 Compliance Requirements Plan Section
climatological risk factors throughout
the different parts of the local publicly
owned electric utility’s or electrical
cooperative’s service territory.
(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.
6.4 and 6.5
(b)(2)(L)
A methodology for identifying and
presenting enterprise-wide safety risk
and wildfire-related risk.
6.1 (b)(2)(M)
A statement of how the local publicly
owned electric utility or electrical
cooperative will restore service after a
wildfire.
7.11.3 (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.
9.3 (b)(2)(N)(ii)
Identify any deficiencies in the wildfire
mitigation plan or its implementation
and correct those deficiencies.
9.4 (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
7.4.12 9
PUC Code 8387 Compliance Requirements Plan Section
rules.
(3)
In each year it is required to submit a
plan, the local publicly owned electric
utility or electrical cooperative shall
present its wildfire mitigation plan in an
appropriately noticed public meeting.
The local publicly owned electric utility
or electrical cooperative shall accept
comments on its wildfire mitigation plan
from the public, other local and state
agencies, and interested parties, and
shall verify that the wildfire mitigation
plan complies with all applicable rules,
regulations, and standards, as
appropriate.
5.2 (3)(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.
10 10
2.5 Utility Overview 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 CleanPowerSF Community Choice Aggregation (CCA) program 2 and serves CCSF municipal load and other retail customers through Hetch Hetchy Power , another division of the SFPUC.
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 Hetch Hetchy Water (HHW), Water Supply & Treatment Division (WSTD), and Natural Resources and Lands Management Division (NRLMD) (Figure 1). HHW, WSTD, and NRLM D have defined responsibilities for managing and maintaining the electrical assets , and land on which they reside, which are described in this Plan. The Water Enterprise is responsible for the development, execution, and oversight of this WMP.
HHW is responsible for managing, operating, and maintaining the Hetch Hetchy Water and Power (HHWP) Project. The HHWP Project consists of four hydroelectric powerhouses (generator facilities). HHWP transmits this power through SFPUC -owned and operated 230 kV and 115 kV transmission lines to the Bulk Electric System3 (BES).
A portion of the transmission facilities are within Pacific Gas & Electric’s (PG&E) and Modesto Irrigation District’s (MID) service territories. A detailed breakdown of overhead lines in the HFTD is included in Table 2.
WSTD is responsible for managing, operating, and maintaining the Bay Area portion of the system which includes water storage, treatment, water transmission facilities, a switchyard, and power distribution assets in Alameda and San Mateo counties. The SFPUC owns the watersheds above reservoirs in Alameda and San Mateo counties.
2 https://www.cleanpowersf.org/
3 https://nercipedia.com/glossary/bulk-electric-system/
11 NRLMD is responsible for managing, operating, and maintaining Bay Area lands and watersheds. NRLMD does not operate and maintain electrical assets; however, they do perform vegetation management around the distribution poles and overhead lines in Alameda and San Mateo counties.
12 Figure 1 – SFPUC Organization
13 Table 2 – 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 hydro-generation and transmission provider. The SFPUC has no defined “service territory” with boundaries like a traditional utility serving distribution load.
Owned Assets Generation, Transmission, and Distribution Number of Customers
Served
Five customer accounts served from a distribution line in Tier 2 HFTD, and one served off the transmission in 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
Service Territory
Location/Topography
4 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
Interface5 (based on
total area)
1% Wildland Urban Interface
1% Wildland Urban Intermix
The percentages above refer to overhead transmission and distribution circuit miles.
4 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. 5 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.
14 Prevailing Wind
Directions & Speeds by
Season
Generally, the coast range has higher average wind speeds throughout the year, which are typically from the west, with strong east wind events in the winter. The Central Valley typically has lower average wind speeds, with a predominantly westerly direction. The mountain region has moderate average wind speeds, also typically westerly, with very strong easterly (Mono) wind events in the winter. In the table below, winter is considered from October-April and summer from May to September.
Average Max
Region Season Wind
Speed
(mph)
Direction Wind
Speed
(mph)
Direction
Coast
Range
Winter 30 W 60 E
Coast
Range
Summer 20 W 30 W
Central
Valley
Winter 10 W 20 E
Central
Valley
Summer 5 W 10 W
Sierra
Nevada
Foothills
Winter 15 W 70 E
Sierra
Nevada
Foothills
Summer 15 W 20 W
Miles of Owned Lines
Underground and/or
Overhead
6 Overhead Dist.: 48.9 miles / 1,300 Distribution Poles Overhead Trans.: 324.4 miles / 834 Transmission Poles/Structures Underground Dist.: 5.3 miles
Underground Trans.: 0 miles
Explanatory Note 1 - Methodology for Measuring “Miles”: Circuit Miles Explanatory Note 2 – Description of Unique Ownership Circumstances:
The following SFPUC distribution lines are supplied from PG&E lines to serve SFPUC facilities. Bay Area region: San Andreas Lake Line (4.16 kV), Pilarcitos Line (4.16 kV), Sawyer Camp Line (4.16 kV), Crystal Springs Line (7.2 kV), Pulgas Line (4.16 kV). Central Valley region: Tesla Portal Line (12
6 In early 2025, we recalculated our overhead line mileage. All mileage is now listed as circuit miles.
15 kV).
Percent of Owned Lines
in CPUC High Fire
Threat Districts
(percentages reflect
overhead line length).
Overhead Distribution Lines as % of Total Distribution System (Inside and Outside Service Territory):
Tier 2: 86.7%
Tier 3: 8.5%
Non-HFTD: 4.8%
Overhead Transmission Lines as % of Total Transmission System (Inside and Outside Service Territory):
Tier 2: 26.1%
Tier 3: 2%
Non-HFTD: 71.9%
Explanatory Note 3 – Additional Relevant Context: [e.g., explain any difference from data reported in WMP due to different numerator used for this form]. We periodically review and update our GIS layers, which results in more accurate representations of the actual circuit miles.
Have SFPUC customers
ever lost service due to
an IOU PSPS event?
No. If yes, then provide the following data for the calendar year 2025:
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
Have SFPUC customers
ever been notified of a
potential loss of service
due to a forecast IOU
PSPS event?
No.
SFPUC has developed
protocols to pre-emptively
shut off electricity in
response to elevated
wildfire risks?
Yes. Our de-energization protocols are explained in Section 7.11 SFPUC has previously
preemptively shut off
electricity in response to
elevated wildfire risk?
Yes prior to 2025.
Calendar year 2025: 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.
16 3. OVERARCHING INITIATIVES FOR THE 2026-2028 WMP
The 2026-2028 SFPUC WMP programs and initiatives are built upon leveraging the successes and lessons learned from previous Plans. Our primary goal continues to be to construct, operate, and maintain a safe and resilient electrical grid and continue to minimize the risk of our assets being the origin or contributing source for a catastrophic wildfire.
Our primary initiatives for the 2026-2028 Plan are to:
1. Maintain compliance with Pub. Util. Code § 8387 and continue to mature our wildfire mitigation initiatives.
2. Continue to develop improvements to the Wildfire Operations (Professional)™ risk modeling software.
3. Continue to track metrics to inform the SFPUC on how the WMP programs and initiatives are performing.
4. Evaluate and assign priorities to system hardening options and create implementation time frames.
3.1 Wildfire Mitigation Operating and Capital Budgets7
The SFPUC’s Operating and Capital Budgets for Fiscal Years FY 2026-27 and FY 2027- 28 went into effect July 1, 2026. Operating Budgets include continued funding for wildfire mitigation initiatives and activities including vegetation management and tree- removal contracts, satellite imaging 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.
Wildfire mitigation Capital Budget investments are incorporated across the Water, Power, and Joint program classification categories rather than managed as a standalone category8. In addition to a two -year Capital Budget, the SFPUC prepares a 10- Year Capital Plan. The adopted Capital Budget and Capital Plan reflect a long- term
7 Approved operating and capital budgets are published on the SFPUC website. See Operating and Capital Budgets.
8 Projects classified as “Water” are funded 100% by Water customers. Projects classified as “Power” are funded 100% by Power customers. Projects classified as “Joint” are funded 55% by Power customers and 45% by Water customers.
17 commitment, with investments projected throughout the 10-year capital planning period, consistent with ongoing resilience objectives and regulatory requirements. The 10- year Capital Plan is reviewed every two years. Capital Plan updates could adjust project timing and project reprioritization but does not reduce overall program scope.
Line items in the 10-year Capital Plan that represent investments in the Transmission and Distribution systems include Power Transmission Life Extension, Power Distribution Upgrades, Wildfire Mitigation (Power), Wildfire Mitigation (Joint), and O’Shaughnessy Dam Micro-Hydro Generation Units. Descriptions of these projects and budgets are as follows:
• Power Transmission Life Extension:
o Budget: $14.5M over ten years, with an average of $1.45M available per year. This is an ongoing project with continuous funding over the ten-year period.
o Project Description: Deliver capital improvement projects to sustain the reliability of HHWP's electric transmission assets from the generator step- up transformer across transmission lines to the terminal substations and switchyards. HHWP has developed a program to extend the life of these assets prior to wholesale replacement. The program will include inspections, condition assessments, design, environmental evaluations, construction when appropriate to maintain the reliability of the electric transmission system, and development of a business plan for transmission system rebuild.
• Power Distribution Upgrades:
o Budget: $18.5M over ten years, with an average of $1.85M available per year. This is an ongoing project with continuous funding over the ten- year period.
18 o Project Description: Deliver capital improvement projects to maintain the reliability of HHWP's electric distribution lines. HHWP owns and maintains about 40 miles of distribution lines which power operational facilities on the HHWP Project. About 60 percent of the distribution system has exceeded its life expectancy. In addition, new loads to support operations at Moccasin Compound and remote sites (e.g., U ltraviolet systems, Moccasin Fish Hatchery Recirculation System, and new buildings/offices) are taxing the current system, requiring mitigation. This project funds load studies and condition assessments to evaluate current and future needs; replacement of aging facilities; design to meet current/future needs; and procurement of critical spare equipment to ensure reliable 24/7 water and power operations at Moccasin Compound and remote sites.
• Wildfire Mitigation (Power):
o Budget: $3.25M over three years, with an average of $1M available per year. This project has a specific scope with a defined end date.
Project Description: HHWP owns assets in areas designated by the CPUC as "High Fire Threat Zones." HHWP has evaluated prevention, mitigation, and response strategies to mitigate the threat of wildfire. This project will fund wildfire mitigation vegetation management projects, including fuel breaks and Integrated Vegetation M anagement (IVM) projects to protect assets classified as "Power" only.
• Wildfire Mitigation (Joint):
o Budget: $5M over six years, with an average of $850k available per year.
This project has a specific scope with a defined end date.
Project Description: SFPUC owns assets in areas designated by CALFIRE as "High Fire Threat Zones." This project will mitigate the risk posed by uncontrolled wildfire to "Joint" assets by constructing fuel breaks and
19 completing fuels reduction projects near HHWP Project facilities and other “Joint” assets.
• O’Shaughnessy Dam Micro-Hydro Generation Units
o Budget: $3.3M is available during the current ten-year period and will extend into the next iteration of the Capital Plan. The overall project budget is estimated at $16M.
o Project Description: Installation of two (2) micro- hydro generation units inside O'Shaughnessy Dam, supplied by the Instream Flow Release (IFR) pipes in the diversion tunnel upstream of the IFR valves. These units would provide a primary power source for t he estimated 128 kilowatts of total capacity required for O’Shaughnessy Dam operations and O'Shaughnessy Compound, with redundancy to supply camp during any maintenance required on generation units. Installation of these units reduces the SFPUC’s wildland fire risk by allowing for the de-energization or removal of the existing overhead power distribution lines between Camp Mather and O’Shaughnessy Compound. Removal of the overhead lines would reduce annual maintenance costs associated with the overhead power lines and increase dependance on a backup generator system for dam operations when the micro-hydro units were unavailable.
Examples of the Wildfire Mitigation work done under these Capital projects include:
o Transmission Right-of-Way (ROW) Bio Audit : HHWP is in the process of converting electrical transmission right -of-way plant dynamics to more compatible and beneficial species. This will support our wildfire mitigation activities as well as reduce our maintenance requirements. HHWP applied for and received the Candidate Conservation Agreement with Assurances (CCAA) for the monarch butterfly and bumblebee which will require
20 conservation plots to be created and maintained. A bio- audit is being completed under this project to support this activity. (Project is ongoing.)
o Transmission Line Integrated Vegetation Management (IVM) Transmission ROW Hazard Vegetation Removal : Hazard trees pose a risk to HHWP transmission infrastructure. This project will remove fire prone brush species and any hazard fall -in risk potential trees (including immediately outside the ROW) along HHWP t ransmission lines, creating a fire break.
The ROW vegetation will be replanted with low growing native grass and pollinator species. In areas with increased conductor height, the project will re-plant conifer and hardwood trees. (Project is ongoing.)
o Water Quality IVM – Priest Reservoir Vegetation Clearing: This project would clear undesirable woody species; dead, diseased, or otherwise hazardous trees; and foliar herbicides including but not limited to Yellow Star Thistle and Himalayan Blackberry around Priest Reservoir, to create a fire break. Vegetation along roadways and parking areas will be thinned and scaffold branches lifted to ensure adequate access during fire events. The project will include introduction of native vegetation including milkweed, black oak, and ponderosa pines in appropriate areas to promote diversity, pollinator habitat and fire resilience. (Project is ongoing.)
o Distribution ROW : A land review of the distribution system needs to be performed to identify areas where the assets deviate from the Raker Act alignment (The Raker Act is a 1913 U.S. federal law that authorized the construction of the O'Shaughnessy Dam and the creation of the Hetch Hetchy Reservoir within Yosemite National Park ). Next, a n environmental review will be conducted pursuant to the California Environmental Quality Act (CEQA) for all activities that occur to maintain regulatory compliance around the electrical distribution system. These activities include the replacement of aging poles and infrastructure. They also support wildfire mitigation activities including removal of vegetation and targeted application
21 of herbicides on undesirable vegetation, then replanting of compatible and beneficial species. A bio- audit of the electrical distribution system will be conducted to guide the plant conversion from incompatible to compatible.
The bio audit of the distribution ROW will assist in the replanting of species that wi ll thrive along the ROW, increase pollinator habitat, and lower maintenance costs. This audit would analyze soil, invertebrates and vegetation along the distribution system. This activity will also assist in planning and maintaining our conservation plots that are enrolled in the CCAA project, which began in early 2025. The final CEQA report will include any nec essary mitigation for all the activ ities listed above. (Project is ongoing.)
o O’Shaughnessy Compound Backup Generator: SFPUC facilities at O’Shaughnessy Compound include the O’Shaughnessy Dam and spillway controls, water treatment plant, lift station , HHWP office, National Park Service (NPS) housing/law enforcement office, campground, communications systems, security systems, and lighting systems. Electric distribution circuits from Early Intake Switchyard service the Compound.
Power outages on the overhead distribution lines could be caused by fire weather conditions, storm events, down powerlines, and maintenance outages. The outages could impair law enforcement, security, and core infrastructure operations. This project will install a backup generator at the Compound servicing local electrical demand when the overhead distribution circuits are de- energized for maintenance and during extreme weather events. (Project is ongoing.)
o Distribution Power Pole Protection (Pole Wrap): This project added Hexion Pole Wrap to 297 poles along HHWP distribution lines. This wrap provides protection against damage due to wildfire. The HHW portion of the project is completed. WSTD will be wrapping their poles in 2026-27.
22 o Overhead to Underground Conversion Assessment: This project developed a cost estimate to underground Hetch Hetchy Water & Power's and Water Supply & Treatment’s overhead distribution lines and equipment through various ground conditions, terrain, and vegetation densities. This project was an assessment only. (Project is complete.)
o PRC § 4292 Non-Exempt Equipment Replacement: Non-exempt equipment may arc, spark, or fail, causing hot particles to fall to the ground, potentially resulting in an ignition . This project will evaluate the current equipment in service on distribution power poles that are subject to PRC § 42929 in Moccasin, the Cherry Ridge Line and the Mather Line with the intent of installing CALFIRE approved exempt equipment. (Project is ongoing.)
9 PRC § 4292 mandates that any person who owns, controls, operates or maintains electrical transmission or distribution lines on mountainous, forested, brush-covered, or grass-covered land must maintain a firebreak of at least 10 feet in all directions from the outer circumference of poles or towers supporting transmission and distribution equipment. California Public Resources Code (PRC) § 4292.
23 4. SUMMARY OF 2025 WILDFIRE MITIGATION ACTIVITIES
This section provides details on our programs and initiatives conducted in the calendar year 2025 to reduce the risk of a catastrophic fire caused by SFPUC assets.
4.1 Risk Assessment
In 2025, the SFPUC continued refining and expanding its use of Technosylva’s Wildfire Operations (Professional) ™ application, previously referred to as Wildfire Analyst, leveraging it to monitor fire weather conditions that could impact the entire SFPUC overhead electrical system. Technosylva is a recognized leader in advanced GIS-based wildfire planning and emergency response software, used by CALFIRE, the CPUC, and most of California’s investor-owned utilities.
Wildfire Operations (Professional)™ evaluates each SFPUC asset daily, assigning a Fire Potential Index (FPI) rating and predicting the potential consequences if an ignition were to occur . The application models four key consequence metrics: Fire Size Potential, Population Impacted, Buildings Threatened, and Estimated Buildings Destroyed. These data-driven insights enable SFPUC personnel to proactively identify risk conditions and make informed decisions about operational changes, work restrictions, or de-energization to protect communities and critical infrastructure.
The Wildfire Operations (Professional)™ application is explained in detail in Section 7.1.1.
4.2 Situational Awareness
In 2025 SFPUC continued to evaluate and augment its situational awareness capabilities by leveraging the Wildfire Operations (Professional)™ application.
Using Wildfire Operations (Professional) ™, we have an integrated view of weather stations and high- definition cameras hosted through the ALERTCalifornia network .
Approximately 80% of our overhead electrical system is within a camera viewshed, enabling faster detection of ignition, hazardous wildfire smoke, and other conditions that could negatively impact our operations and prompt timely dispatch of fire personnel.
24 Additionally, the platform provides real-time information on active fire incidents that may threaten our assets, allowing us to monitor fire growth more effectively. The application also overlays alerts from the National Weather Service ( NWS), including Extreme Fire Danger, Extreme Wind Warnings, Red Flag Warnings (RFW), and Excessive Heat Warnings—directly onto the base map. In 2025, SFPUC worked with University of California San Diego (UCSD) to install Star link satellite internet on the Moccasin Peak ALERTCalifornia camera. Starlink offers a faster and less interruptible camera live feed.
4.3 Vegetation Management
In 2025, HHW Vegetation Management Right of Way (VM ROW) Department continued to refine the use of ArcGIS Field Maps to accurately track and document tree and vegetation inspections. The Field Map application allows the inspector to plot trees using geographical position system latitudes and longitudes, as well as a customized form for notating tree species, type of treatment (trim, removal, grow -in, etc.), and set a remediation schedule. This information is then used to create work orders for the vegetation management group to perform the specified tree work. Using the data collected in Field Maps, a dashboard is generated to track vegetation inspection progress (see Section 7.4.8 for dashboard screenshot).
Since 2023, SFPUC has utilized satellite-based vegetation monitoring through a contract with LiveEO, receiving updated imagery on an annual basis. This high-resolution data enables enhanced visibility into vegetation conditions, including growth patterns and proximity to electrical conductors. This capability strengthens targeted ground patrols and supports the identification of areas of elevated concern, including those within High Fire Threat Districts (HFTDs). Additional details regarding the SFPUC’s use of LiveEO are provided in Section 7.4.7.
Our internal E -Logger system is managed by the HHW Power System Operators and sends automated alerts to the ROW Manager and Forester when there is an outage detected on our transmission or distribution line(s). The Power System Operators dispatch linemen, a tree crew, and Forester to investigate the cause of the outage. In
25 2025, we refined the summary of findings reports which the Forester completes if the outage is vegetation related. The reports are now accessible via mobile devices so trees or vegetation can be marked with latitude and longitude for tracki ng remediation and auditing. This allows for more informed decisions regarding vegetation management based on historical outage information caused by vegetation contact. This information is also used to inform the outcome metrics.
4.4 Construction, Operations, and Maintenance
In 2025, SFPUC installed Hexion ArmorBuilt™ pole wrap on 297 distribution poles in the HFTD. These poles are in areas where access is limited due to terrain and the line(s) supply power to critical facilities. Pole wrapping is also discussed in Section 7.3.2.
As part of our WMP, we are actively working to replace all non- exempt equipment with exempt equipment as identified in the CALFIRE California Power Line Fire Prevention Field Guide , 2021 Edition. By systematically upgrading non -exempt components to designs that meet current ignition- resistant standards, we are strengthening system reliability while minimizing the potential for equipment-related ignitions. This effort reflects our ongoing commitment to reducing wildfire risk associated with overhead electric al infrastructure, particularly in high fire-threat areas.
To advance this objective, we have placed orders for replacement materials to support two concurrent projects scheduled to begin in 2026 and be completed in 2027 . One project will focus on poles in Tuolumne County. The second will address poles in Alameda County. Table 3 summarizes the details of these projects. The selected equipment incorporates improved insulation, shielding, and wildlife protection features that reduce the likelihood of an ignition.
While we have taken proactive steps to procure these materials, manufacturers are currently experiencing extended production and delivery lead times due to high demand and supply chain constraints. As a result, installation timelines are dependent on material availability. We are closely coordinating with suppliers to track production schedules and prioritize delivery to complete the work. Through this phased approach, we are making
26 measurable progress toward eliminating all non-exempt equipment from our system and further reducing wildfire risk across our system.
Table 3 – Proposed Distribution System Hardening
Project Area Asset Type
Total Quantity
Scheduled for
Replacement
Purpose
Various
Locations
(Tuolumne
County)
Fuses
PRC 4292
Exempt
157 Improve circuit protection
and fault isolation
Fuse
Cutouts
PRC 4292
Exempt
115 Replace aging protective
devices and improve
system reliability
Surge
Arrestors
PRC 4292
Exempt
110 Protect equipment from
voltage surges and reduce
equipment failure risk
Vibration
Dampers
568 Reduce conductor
vibration and mechanical
fatigue caused by wind
Avian 121 Prevent wildlife contact
27 Project Area Asset Type
Total Quantity
Scheduled for
Replacement
Purpose
Protection with energized equipment
Anti-Perch
Devices
95 Reduce bird activity on
energized equipment to
prevent faults
Sunol (Alameda
County)
Fuses
PRC 4292
Exempt
28 Improve circuit protection
and fault isolation
Surge
Arrestors
PRC 4292
Exempt
21 Protect equipment from
voltage surges and reduce
equipment failure risk
28 5. ROLES AND RESPONSIBILITIES
5.1 SFPUC Division Responsibilities
This section identifies the SFPUC management staff responsible for the development, approval, and implementation of this Plan and lists, in Table 4, the operating divisions accountable for carrying out the various activities described in the Plan.
The HHW Fire Mitigation Specialist is the lead of the SFPUC's Wildfire Mitigation Planning Group (WMPG) comprised of managers and field staff from HHW, NRLMD, and WSTD.
The group's purpose is to review and monitor the progress of the SFPUC wildfire mitigation programs, monitor the effectiveness of the Plan, and coordinate wildfire mitigation projects, activities, and best practices across all SFPUC divisions. The group meets bi-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 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 laws, and regulatory requirements in a continuous effort to reduce the risk of SFPUC assets being the origin or contributing source for a catastrophic wildfire. The Fire Mitigation Specialist is also a primary SFPUC liaison with the California Municipal Utilities Association ( CMUA) and attends the monthly CMUA -hosted Wildfire Preparedness, Response, and Recovery Working Group calls.
• 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.
29 Table 4 – 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 NRLMD 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
NRLMD and Peninsula Area
Manager
Vegetation Management and
Removal
HHW Operations and Maintenance
Manager NRLMD Division 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 Fire Mitigation Specialist Fire Mitigation Specialist Plan Review
HHW Division Manager, NRLMD
Division Manager, WSTD Division
Manager, CCSF City Attorney’s
Office; and SFPUC Assistant
General Manager of Water
HHW Division Manager, NRLMD
Division Manager, WSTD Division
Manager, CCSF City Attorney’s
Office; and SFPUC Assistant
General Manager of Water
Plan Approval SFPUC Commission SFPUC Commission
SFPUC 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.
30 • Ensure compliance with relevant federal, state, and industry-standard requirements.
• Ensure that relevant incident data is appropriately and timely collected when a utility asset is suspected to be the cause or contributing source for the ignition of wildfire.
• Ensure that evidence is appropriately preserved when a utility asset is suspected to be the cause or contributing source for the ignition of wildfire. • Require adequate wildfire mitigation training programs for all relevant SFPUC employees and require SFPUC contractors to implement wildfire mitigation training and procedures.
5.2 WMP Adoption Process
This Plan meets the requirements of P ub. Util. Code § 8387 for POUs.10 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 on its website a week before the Commission meeting date.
11 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 weblink to view the meetings live and a 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 WMPs and independent evaluator (IE) report(s). 12 10 Pub. Util. Code § 8387(b)(3)
11 See https://sfpuc.org/about-us/boards-commissions-committees/sfpuc-commission 12 https://www.sfpuc.gov/about-us/policies-plans/wildfire-mitigation-plan
31 6. 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.”
6.1 Enterprise-Wide Safety Risks
The SFPUC’s risk evaluation approach leverages the institutional knowledge of our personnel familiar with the historical events that previously impacted our operations. Our risk reduction approach is designed to meet the requirements of industry -recognized standards, i.e., CPUC G eneral Orders (GO), North American Electric Reliability Corporation ( NERC) Operating Standards, National Electric Safety Code ( NESC), and best practices utilized by other utilities with more mature wildfire mitigation programs.
The SFPUC has operationalized the use of Technosylva’s Wildfire Operations (Professional)™ application to support our operations and planning groups as described in Section 7.1.1. The Wildfire Operations (Professional) application is now the foundational tool for forecasting and identifying fire weather risk s, forecasting potential consequences of the fire, support ing de-energization decision-making, and support ing prioritization of risk reduction measures.
6.2 Risks and Risk Drivers Associated with Topographic and Climatological Risk Factors
The SFPUC owns electrical assets in the foothills of the Sierra Nevada Mountain range, through the San Joaquin Valley, Coast Range, and into the lower elevation San Francisco Peninsula region.
Our primary topographic and climatological risk drivers identified for wildfire risk are:
• Extended drought,
• Lightning,
32 • Lack of early fall rains,
• Hot temperatures,
• High winds,
• Steep terrain, and
• Vegetation type and density.
6.3 Risks and Risk Drivers Associated with Design, Construction, Operations , and Maintenance
SFPUC's wildfire risk is influenced by decisions made throughout the lifecycle of our electrical infrastructure from initial system design through construction, daily operations, and ongoing maintenance. Each phase presents unique risks and corresponding risk drivers that may affect the likelihood of wildfire ignition or the consequences of a wildfire event. Underst anding these factors enables SFPUC to prioritize mitigation activities, allocate resources effectively, and continuously improve wildfire resilience.
Design-related risks arise from the configuration, location, and engineering of electrical facilities. Design decisions can influence both ignition potential and system resilience over the life of an asset. Primary risk drivers include facilities located within the Tier 2 and 3 HFTDs, aging infrastructure and legacy equipment, use of CALFIRE non- exempt equipment where replacement has not yet occurred, terrain, vegetation density, and environmental constraints affecting facility location, and exposure to high winds, falling trees, and severe weather. The most common risks for overhead lines in the H FTDs include equipment failure, vegetation contact, reduced operational flexibility during RFW events, and increased wildfire exposure because of facilities location (heavily forested or canyon areas).
Construction risks and risk drivers are activities that may temporarily increase wildfire risk through equipment use, ground disturbance, and contractor operators, especially during days where the FPI is Elevated or Extreme. Primary risk driver activities are welding, grinding, cutting, and other spark -producing activities, heavy equipment operating in dry vegetation, construction activities, and access limitations for firefighting resources.
33 SFPUC has excellent system reliability . Most unplanned outages have occurred in the upper elevations during the winter months when snow loads break trees and branches adjacent to the ROW. HHW tracks planned and unplanned overhead transmission and distribution outages through e -Logger. The HHW Moccasin Control Center staff is responsible for monitoring de-energization thresholds and communicating fire weather risk events to WSTD staff for lines operated and maintained by WSTD.
SFPUC has programs and initiatives to address these risks and risk drivers. These programs and initiatives are further described in Section 7.
6.4 High Fire Threat District
SFPUC participated in the development of the CPUC’s Fire- Threat Map 13 which designates a High-Fire Threat District (HFTD) (Figure 2). The CPUC describes the HFTD as follows:
1. Tier 1 High Hazard Zones (HHZs) on the U.S. Forest Service-CALFIRE 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.
As part of the map development process, the SFPUC conducted a thorough review of the proposed fire-threat area boundaries. Based on local conditions and historical fire data,
13 https://www.cpuc.ca.gov/industries-and-topics/wildfires/fire-threat-maps-and-fire-safety-rulemaking
34 we confirmed that all SFPUC assets are appropriately classified within the correct fire- threat areas (Figure 3). The SFPUC continues to rely on the High Fire- Threat District (HFTD) maps and designations to guide wildfire mitigation p olicies and operational practices.
35 Figure 2 – CPUC High Fire-Threat District Map
36 Figure 3 – SFPUC Electrical Assets and HFTDs
37 6.5 Changes to CPUC Fire Threat Map
The CPUC fire threat map accurately reflects the wildfire threat area near SFPUC’s electrical asset. The SFPUC agrees with the existing CPUC HFTD boundaries and makes no recommendation for expanding or minimizing the current HFTD.
6.6 Fire Hazard Severity Zone Map
SFPUC reviewed the CALFIRE Fire Hazard Severity Zone (FHSZ) map (Figure 4). The map provided additional validation on areas of greater fire risk . Analyzing this map in conjunction with the HFTD map provides a better understanding of the areas where the highest risk is. Figure 4 on the next page shows the FHSZ with an approximate overlay of where SFPUC electrical assets are located.
The FHSZ map is designed to plan for wildfire prevention at a community level. Additional information on community preparedness is discussed in Section 8 of this Plan.
38 Figure 4 – CALFIRE SRA FHSZ Map
39 6.7 Climate Change / Weather Risks
The National Oceanic and Atmospheric Administration (NOAA) defines climate change as long-term changes in the characteristics of Earth’s climate system, including shifts in temperature, precipitation, sea level, ocean heat, ice cover, and atmospheric patterns over decades or longer. These changes affect natural systems and human activities worldwide.
NOAA reports that Earth’s average surface temperature has increased by approximately 2°F (about 1°C) since the late 19th century (1850 –1900), with the rate of warming accelerating in recent decades. The 10 warmest years in the global record have all occurred within the past decade, and 2024 was the warmest year observed to date.
Climate change encompasses more than rising temperatures; it also includes sea level rise, shrinking snowpack and sea ice, increasing ocean heat content, and changes in the frequency and intensity of extreme weather events such as droughts, floods, and heat waves. These changes are already affecting critical systems that society depends on, including water resources, energy, transportation, ecosystems, agriculture, and human health.
Climate change has significantly increased the frequency, intensity, and duration of wildfires in California. Rising temperatures, prolonged droughts, and shifting precipitation patterns have created drier conditions, making vegetation more flammable. In higher elevations, reduced snowpack and earlier snowmelt extend the duration of fire seasons, in some cases well into the winter months. Unpredictable wind events, such as Diablo winds, can further accelerate wildfire spread. As climate change continues, wildfire risk in California is expected to increase.
Extended droughts are an ongoing reality for utilities operating in California and will continue to influence decision- making for the SFPUC wildfire mitigation programs and activities. A core mission of the SFPUC is to deliver high- quality drinking water t o San Francisco residents. To support this mission, the SFPUC closely monitors precipitation patterns and snowpack conditions to ensure reliable water supply. Because drought is a natural component of California’s climate variability, the SFPUC recognizes that periods
40 of severe and prolonged drought are often associated with elevated risk of large, catastrophic wildfires. SFPUC will continue collaborating with CMUA and other participating POUs in CMUA’s Climate Change working group to evaluate future risks.
41 7. WILDFIRE PREVENTATIVE STRATEGIES
7.1 Situational Awareness
We continue to make significant advancements to enhance our ability to forecast and monitor real-time weather conditions to make daily operational decisions . This section describes our current situational awareness methods.
7.1.1 Technosylva Wildfire Operations (Professional)™ / Fire Potential Index (FPI) Technosylva Wildfire Operations (Professional) ™ performs a wildfire risk analysis on each SFPUC asset and produces a Fire Potential Index (FPI) rating for that asset. The SFPUC Fire Potential Index (FPI) is a predictive metric utilized to quantify wildfire ignition probability and subsequent fire behavior. Generated daily via the Technosylva Wildfire Operations platform, this zone-specific forecast classifies localized risk into three discrete operational conditions: Normal, Elevated, and Extreme. The underlying algorithm is derived from the Pacific Gas and Electric (PG&E) FPI framework, synthesizing historical fire occurrence data with real -time environmental conditions , including fuel moisture content, relative humidity, wind velocity, and ambient air temperature. The benefit of PG&E sharing its 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.
Operating Condition Description
Normal Large wildfires are not likely
Elevated Large wildfires are possible, should an ignition occur
Extreme Large, damaging wildfires are likely should an ignition occur.
Additionally, the application forecasts 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.
42 SFPUC established a zonal framework that segments the overhead electrical system into nine distinct geographic zones. Each zone was delineated based on a combination of vegetation characteristics, topographic conditions, and proximity to HFTDs.
This methodology enables a more meaningful characterization of wildfire risk drivers across our service territory. Vegetation type informs fuel loading and combustibility, topography influences fire spread potential and wind behavior, and proximity to HFTDs reflects areas of elevated baseline risk as defined by state fire threat modeling.
Using these inputs, zone-specific FPIs are generated and provide a granular, data-driven assessment of relative wildfire risk. This approach supports operational and mitigation strategies, including inspection prioritization, vegetation management, system hardening, and situational awareness protocols.
By moving from a uniform system -wide assessment to a differentiated, zone- based framework, we enhance our ability to proactively manage wildfire risk and allocate resources in a manner that is commensurate with localized conditions.
Wildfire Operations (Professional) ™, in conjunction with existing critical fire weather monitoring tools, will be used to support HHW, NRLMD, and WSTD field operations’ daily work schedules and inform personnel of areas of risk and if any operating restrictions should be implemented. Additionally , Technosylva provides us with an automated daily FPI summary report for each of our nine zones . The reports are generated each day before 6:00 am PST and sent to users on the distribution list for operational planning.
7.1.2 Weather Monitoring
The SFPUC uses Technosylva and publicly available weather forecasts to support real - time operating decisions. In conjunction with Wildfire Operations (Professional)™, HHW obtains wind speed forecasts from NOAA’s High -Resolution Rapid Refresh (HRRR) model, retrieving average and peak wind forecasts for the next 24-hour operating period.
The automated process generates an hourly email with the forecast and sends it 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
43 operational restrictions should be implemented or if lines should be de- energized for public safety.
NRLMD also uses the Technosylva Wildfire Operations (Professional) ™ to monitor weather for the Bay Area and Peninsula regions. This information is used to determine any operational restrictions for NRLM D field staff. Weather forecasts are distributed to staff through the Millbrae dispatch center via i-INFO.14 In addition to Wildfire Operations (Professional)™, HHW and NRLMD staff monitor fuel (vegetation) conditions by accessing publicly available information provided by the NWS, United States Forest Service (USFS), daily Project Activity Level 15 (PAL) rating, Bureau of Land Management (BLM), NOAA, and CALFIRE . SFPUC staff monitor the NWS for Red Flag Warnings.
7.1.3 Weather Stations
In addition to SFPUC-owned weather stations, the Wildfire Operations (Professional)™ application provides us with access to more than 300 publicly available weather stations providing, at minimum, temperature, relative humidity, and wind speed readings. These weather stations are situated near SFPUC assets , with up to a 25-mile buffer zone from those assets. Figure 5 shows a graphic of the weather station data now available to the SFPUC through the Wildfire Operations (Professional)™ application.
14 https://dashboard.i-info.com/
15 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).
44 Figure 5 – Weather Stations
45 7.1.4 ALERTCalifornia Cameras16
The Wildfire Operations (Professional) ™ application has integrated live feeds to more than 100 cameras providing viewsheds of areas in proximity to SFPUC electrical assets.
Figure 6 displays the cameras and live feeds available to the SFPUC in the application.
In previous WMPs, the SFPUC reported on an ongoing project to install three additional ALERTCalifornia cameras at Poopenaut Peak near the O’Shaughnessy Dam site in Yosemite National Park, Burnout Ridge near Cherry Lake, and Intake Ridge near Kirkwood Powerhouse .17 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 Operations (Professional)™ application. The ALERTCalifornia cameras are an important situational awareness tool for HHW. To streamline the licensing and leasing process for these three cameras, HHW has decided to install and operate them internally, rather than going through a third-party vendor. In 2025, we coordinated with UCSD to replace one camera that is connected to the ALERTCalifornia system via Starlink satellite internet. We are continuing to coordinate with UCSD to install the additional stations mentioned above.
16 ALERTCalifornia
17 SFPUC 2024 Wildfire Mitigation Plan, Sec. 5.1.14
46 Figure 6 – ALERTCalifornia Cameras
47 7.1.5 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,18 to view air quality index monitors in all SFPUC regions. Additionally, T he Wildfire Operations (Professional)™ application also has an air quality alert module, which can be used to supplement other data sources (Figure 7).
Figure 7 – Air Quality Monitors
7.2 Design and Construction Standards
The SFPUC uses the requirements of CPUC GOs 95 , 19 165, 20 174, 21 NERC Transmission Vegetation Management Program FAC-003, 22 and applicable NESC guidelines to guide construction and maintenance, and operate a safe, reliable, and resilient grid. The SFPUC has effective programs for construction, inspections, and maintenance of transmission, distribution, generation, and substation assets within the HFTD, and for taking corrective action within specified timeframes for all issues that
18 PurpleAir.com
19 GO 95 – Overhead Electric Line Construction
20 GO 165 – Inspection Cycles for Electric Distribution Facilities 21 GO 174 – Rules for Electric Utility Substations
22 NERC, FAC-003-5 Transmission Vegetation Management Program
48 require remediation.
Our “Overhead Distribution Construction Standards” specify that all new construction shall be built to provide maximum clearances (based on raptor construction principles ), and SFPUC wildfire mitigation requirements to provide phase separation and maximum long-term durability. Additionally, t he standards require that any new construction or corrective maintenance of non- exempt equipment in HFTDs shall have C ALFIRE- approved exempt equipment and infrastructure hardening. Composite cross -arms, pole wrap, and composite poles are considered during the job planning phase.
To support more risk -informed decisions for the construction and maintenance of our electrical assets, the Wildfire Operations (Professional)™ application was used to help inform the updated Overhead Distribution Construction Standards. The lines we have identified that provide power to critical water infrastructure were overlaid with the HFTD boundaries and SFPUC zones to determine the potential wildfire risk. This also informed us where system hardening measures would be of most benefit during replacement.
7.3 System Hardening
To reduce wildfire risk and improve system reliability, SFPUC is implementing a range of system hardening projects. The sections below describe these efforts and their impact.
7.3.1 Replace Wood Poles
The SFPUC has updated its Overhead Distribution Construction Standards to state that when replacing poles in the HFTD, consideration will be given to replacement with composite poles and composite cross-arms.
7.3.2 Pole Wrap
In 2025, HHW installed Hexion ArmorBuilt™ pole wrap on distribution poles. This brings our total to 255 distribution poles wrapped in the Tier 2 HFTD. These poles are in areas where access is limited due to terrain and serve critical facilities which require backup
49 generators if distribution power is lost . Hexion ArmorBuilt™ is “[d]esigned to extend the lifespan of wood utility poles by protecting them from the effects of wildfire and rot.” 23 In 2026, 67 poles in the Sunol area (Tier 2 HFTD) , will be wrapped, adding additional protection to the distribution system.
7.3.3 Replacement of Non-Exempt Equipment
SFPUC is working on replacing non -exempt equipment with exempt equipment on distribution poles, because non-exempt equipment could pose a higher risk for ignition.
We have identified 85 poles that host non-exempt equipment. The first project to replace this equipment in Tier 2 HFTD started in May 2026.
Long lead times for procuring equipment has made timing of construction a challenge.
The work for these projects will be performed by both HHW line crews and contractors.
7.3.4 Avian Protection
In 2023, our Overhead Distribution Construction Standards were updated to include a section addressing raptor-safe construction and wildlife protection. The policy states that bird and ra ptor protection shall be primary consideration in the design of new and reconstructed distribution facilities.
7.3.5 Overhead to Underground Conversion
An HHW project to extend a n existing underground water pipeline to a campground in Yosemite National Park was reassessed in November 2024 to include the conversion of approximately 4,123 feet of existing 22 kV overhead distribution line to underground.
SFPUC completed geotechnical investigations and construction drawings were completed in 2025. Based on these drawings, a construction contract is currently being developed that will go out to bid in fall 2026. The project management team anticipates construction will begin in spring/summer 2027 and be completed in 2028. Undergrounding this overhead line will reduce SFPUC’s wildfire risk profile within a Tier 2 HFTD.
23 armorbuilt-retrofit-sheet.pdf
50 7.3.6 Alternate Generation Source
SFPUC has included a candidate micro -hydropower project in the 10- Year Capital Budget. The project scope includes installing two micro- hydropower generation units within O’Shaughnessy Dam. Once operational, these units will reduce wildfire risk by enabling the de- energization or removal of existing overhead power distribution lines between Camp Mather and the O’Shaughnessy Compound.
Project funding is not expected to be appropriated until Fiscal Year 2034 –35. In the meantime, we are proceeding with the replacement of non- exempt equipment on the existing distribution poles within the project area.
7.4 Vegetation Management
The SFPUC considers vegetation management the keystone of its wildfire mitigation s.
Previous wire down events were primarily from downed trees and branches. Trimming and removal of trees and vegetation has reduced these events and has been cost- effective. SFPUC meets or exceeds the industry standards for vegetation management around transmission lines, distribution lines, and substation facilities, and maintains compliance with the SFPUC internal Hetch Hetchy Water and Power Transmission Vegetation Management Program (TVMP). SFPUC exceeds vegetation management industry standards by removing trees and brush from outside of our RO W to reduce the possibility of these becoming a fire risk, setting vegetation trimming thresholds to account for three or more years of growth, v ersus a reactive trimming that just keeps the vegetation out of the regulated non- compliance zone, which is based on voltage. By utilizing the IVM principles, non-compatible vegetation is selectively thinned or applied with herbicide, which benefits the growth of lower risk tree and brush spec ies.
Transmission-level facilities comply with NERC FAC-003, where applicable.
For vegetation management on both transmission and distribution level facilities, the
51 SFPUC uses the standards in California PRC24 §§§ 4291, 4292, and 429325 as well as in • CPUC GO 95 Rule 3526
• CPUC GO 95 Appendix E Guidelines to Rule 3527
• CALFIRE’s Power Line Fire Prevention Field Guide – 2021 edition28 • American National Standards Institute (ANSI) A30029
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.
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 (see Figure 8) ; and 2) the NRLMD maintains the vegetation around the WSTD facilities and distribution poles and lines in San Mateo and Alameda County.
25 PRC §§§ 4291–93
26 GO 95 – Overhead Electric Line Construction
27 CPUC GO 95 § 3 Rule 35 – Vegetation Management
28 California Power Line Field Prevention Field Guide, 2021 Edition 29 ANSI A300 Tree Care Standards
52 Figure 8 – Example Distribution ROW
The HHW ROW VM labor crew is made up of one Water and Power Maintenance Supervisor, one laborer supervisor, one operating engineer, two certified arborists, and five laborers. A Certified Arborist with certifications from the International Society of Arboriculture (ISA), ISA Certified Utility Arborist, and ISA Tree Risk Assessment Qualified (TRAQ) complete the inspections.
The NRLM D VM crew is comprised of 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).
Additionally, HHW and NRLMD hire 12 to 15 seasonal employees to remove undesirable vegetation around SFPUC facilities and the ROWs. These positions usually start work in early June and end in October.
53 7.4.1 Annual Vegetation Management Work Plan
The A nnual Vegetation Management Work P lan (AV MWP) is created by the ROW Manager and identifies the facilities to be managed and any proposed work, with start and completion dates. VM work across the ROW is planned and scheduled annually. VM activities are listed and described in the Annual Vegetation Management Work Plan (AVMWP) to ensure VM work is conducted as scheduled. The AVMWP 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. HHW and WSTD use Maximo (IBM™) to generate VM work orders. Maximo is a computerized asset and maintenance management system (CMMS) for managing our programmatic maintenance and repair program. Preventative Maintenance (PM) work orders for detailed transmission and distribution line inspections and substation inspections are managed through Maximo. NRLMD uses ArcGIS Field Maps to track vegetation signed up for treatment.
7.4.2 Vegetation Inspections for Transmission Lines
Ground or aerial inspections (patrol) of all vegetation near the 115 kV and 230 kV transmission lines, both in the HFTD and non-HFTD, are 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 inspections identify conditions where vegetation may encroach within the Minimum Vegetation Clearance Distance (MVCD) for energized facilities before the next scheduled predictive control treatment. A ttention 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. These trees undergo additional inspections, including a detailed 360-degree visual evaluation to determine the presence, significance, and severity of tree defects and risks.
The most common corrective maintenance work identified in 2025 were routine topping of almond and walnut trees and hazard tree removals of Ponderosa Pine. A portion of the SFPUC transmission ROW travels through the Central Valley, which is a non -HFTD.
54 HHW inspectors and the ROW Permit Liaison consistently work with the farmers to educate them on maintaining proper planting distance from our transmission ROW. A challenge we face is keeping an updated contact database for all the property owners.
Ownership can change, and often those who plant the orchards may not necessarily be the owner(s). We strive to contact each landowner before any trees need to be trimmed or removed.
7.4.3 Vegetation Inspections for Distribution Lines
The HHW distribution lines are annually patrolled and inspected by ground and air for vegetation clearances. The HHW arborist performs ground inspections. The aerial inspections allow the arborist and VM crew to inspect vegetation that may be encroaching within the MVCD, which may require corrective maintenance work.
The NRLMD-certified arborist performs annual inspections of vegetation in proximity to WSTD distribution lines in the Alameda and Peninsula watersheds. The arborist submits corrective maintenance work order prescriptions to the NRLMD tree crews for mitigation.
Inspection details, including the inspector's name, date, and line section are documented using Maximo, ArcGIS Field Maps, and noted on the HHW AVMWP. The HHW line crew, VM Crew, and Watershed Keepers report additional corrective maintenance items observed during daily work to the ROW VM Manager to generate a corrective maintenance work order through Maximo.
The most common VM corrective maintenance work along the distribution lines in the HFTD was hazard tree removal of Ponderosa Pine to meet the standards in GO 95 Rule
35. 7.4.4 Vegetation Inspections for Substations, Switchyards, Powerhouses, and Habitable Structures
The SFPUC performs annual defensible space inspections around substations, switchyards, powerhouses, and habitable structures in compliance with PRC § 4291 , including jointly operated substations with a neighboring utility. We use a CALFIRE -
55 developed inspection form attached to the inspection work order. Any follow-up work is documented on the inspection work order, and a follow-up work order is created for the vegetation management crew to trim or remove any vegetation that is non-compliant. The powerhouses and switchyards are inspected twice each year , once during the annual overhead conductor inspection and again when they are inspected for PRC § 4291 compliance.
7.4.5 PRC § 4292 Firebreak Clearance Requirements
The SFPUC meets the requirements of PRC § 4292. Poles that are identified as having non-exempt equipment (e.g., expulsion fuses , lightning arrestors, etc.) have annual PM 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 9). The SFPUC 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.
Figure 9 – PRC § 4292 Firebreak Clearance Requirements
56 7.4.6 Herbicide Use
SFPUC applies herbicides on the 230 kV Right -of-Way in Tuolumne and Stanislaus counties; these applications conform with the San Francisco Integrated Pest Management Ordinance30 and the SFPUC’s TVMP. To ensure environmental compliance with State and Federal requirements, all herbicide application activities follow mitigation and monitoring requirements of the California Environmental Quality Act under the Reliable Power Project Mitigated Negative Declaration. All targeted herbicide treatments are performed by a Qualified Applicator in accordance with written recommendations from a California Licensed Pest Control Advisor.
7.4.7 Satellite Vegetation Monitoring
Following a successful pilot project, HHW has continued its contract with LiveEO to provide satellite vegetation imaging services.
HHW uses this data to track trends on growth and future vegetation work needs.
Additionally, HHW shares satellite imagery information with the NRLM D vegetation management team and consults with them on any areas where vegetation may be a concern.
7.4.8 Vegetation Management Dashboard
SFPUC tracks vegetation inspections across its transmission and distribution systems using ArcGIS Field Maps data and Maximo, with results displayed in a dashboard format.
The dashboard displays data captured in a calendar year.
The modules display overall inspection progress by circuit miles for both transmission and distribution and further separate inspection tracking by distribution and transmission, switchyards, substations, and powerhouses. From left to right, Figure 10 shows the total number of trees that have been tracked in the application since 2021 (orange highlight).
The center graph (red highlight) shows the work priority and type. Finally, the right -hand column (green highlight) shows the types of tree species. HHW regularly reviews the
30 Chapter 3: Integrated Pest Management Program, San Francisco Environment Code
57 dashboard to analyze important ROW trends including inspections by work priority and count of trees by work type to reduce high-priority and hazard tree work.
58 Figure 10 – Vegetation Management Dashboard
59 7.4.9 Defensible Space Inspections
HHW performs annual PM 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-foot radius of defensible space.
7.4.10 Integrated Vegetation Management (IVM)
The SFPUC has a ROW IVM Policy that applies to the entire SFPUC 230/115 kV transmission ROW , and the distribution ROW. Federal and state land management agencies consider the IVM used by SFPUC to be the utility industry's best management practice (BMP).
7.4.11 Vegetation Management Contracts
The SFPUC has two master as -needed tree service 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 31 and are Licensed Timber Operators (LTOs)32 with an “A” license or have an LTO available as a subcontractor.
From January 2023 to December 31, 2025, SFPUC contracted 22 projects under the master as-needed agreements for a total cost of $7,059,801. These projects range from removing undesirable brush species and replanting desirable vegetation, to the removal of hazard trees along the transmission and distribution ROW. All 22 projects were completed to satisfactory standards. There are four additional projects planned for bidding in 2026.
In addition to the master as -needed contracts, NRLMD maintains contracts for mowing and mastication. In 2025, 130 acres of mastication and 90 acres of roadside mowing were
31 https://www.contractorsischool.com/learning-resources/c49-tree-and-palm-contractors-license-2024 32 https://www.fire.ca.gov/what-we-do/natural-resource-management/forest-practice/licensed-timber- operators
60 addressed under these contracts. These projects occurred in various locations in Alameda and San Mateo counties, which encompasses areas of Tier 2 and 3 HFTD.
In 2025 , NRLMD continued their partnership with CALFIRE to conduct more than 52 acres of prescribed burning in the Peninsula Watershed (see Figure 11). The primary objective of the burn is to reduce brush densities and fuels within the Highway 280 corridor and the Wildland Urban Interface, manage non-native and invasive weeds in grasslands, and promote habitat enhancement while reducing brush encroachment in native grasslands. The 2025 burn was limited to six acres due to dangerous wind conditions.
NRLMD and CALFIRE intend to revisit the project area in 2026 to complete the additional 45 acres.
Figure 12 shows completed prescribed burn areas that have taken place in previous years. This is the fourth year that CALFIRE and NRLM D have partnered to conduct prescribed burns as part of an overall 700-acre fuels reduction project, which is planned to take place through 2030. The map was not updated in 2025 because the burn was not completed. It will be updated following its completion in 2026.
61 Figure 11 – 2025 NRLMD/CALFIRE Prescribed Burn Area
62 Figure 12 – Previous NRLM/CALFIRE Prescribed Burn Areas
63 7.4.12 Quality Assurance / Quality Control (QA/QC)
HHW performs Quality Assurance / Quality Control (QA/QC) on its VM work for both transmission and distribution facilities. The QA/QC requires 5% of the distribution and transmission system VM work to be audited annually and the findings reported to the ROW manager. The auditor will evaluate the quality of the inspection as well as the VM that was completed. All VM work shall comply with ANSI A300 standards and applicable regulatory requirements. The audit shall document the assets audited, auditor, date, and details of findings. This process aims to identify areas for improvement and facilitate training based on the findings to improve the quality of the DVMP and TVMP.
HHW VM work performed under contract is monitored by our internal Construction Inspectors. At least one inspector is at the job site daily to ensure work is being performed to SFPUC standards, and safety protocols are being followed. A final job walkthrough is required before the project can be deemed complete, and payment is issued.
When VM work is performed in the Peninsula and Alameda watersheds by NRLMD, the Project Manager is onsite at each job to ensure the work is being performed to SFPUC standards and safety pr otocols are being followed. All specifications must be met for payment to be issued to the contractor.
7.5 Overhead Asset Inspections
The SFPUC follows the inspection requirements provided in CPUC GO 16533 and CPUC GO 95 Rule 18.34
7.5.1 Asset Management System
HHWP and WSTD use IBM Maximo as the system of record that connects the electrical asset, the required inspection, the inspection results, and any corrective work that results from the inspection. The two types of work orders (preventative maintenance and corrective) serve different purposes. The basic workflow is, Electrical Asset →
33 GO 165 – Inspection Cycles for Electric Distribution Facilities 34 CPUC GO 95 Rule 18 – Resolution of Safety Hazards Discovered by Utilities
64 Preventive Maintenance (PM) Program → Inspection Work Order → Inspection Results → Deficiency Identified? → Corrective Work Order → Repair/Resolution → Maintenance History. Table 5 below further illustrates this workflow.
TABLE 5 Maximo Workflow
Maximo Function
Preventive Maintenance /
Inspection WO
Corrective WO
Purpose
Perform the required
recurring inspection
Address a problem
identified during an
inspection
Trigger
Established inspection
cycle or PM schedule
A deficiency or condition
requiring corrective action
Typical activity
Inspect pole, conductor,
hardware, equipment,
clearances, condition, etc.
Repair, replace, adjust, or
otherwise mitigate deficient
equipment
Result
Documents that the
inspection occurred
and records findings
Documents how the
identified condition was
resolved
Asset history
Establishes inspection
history
Establishes
repair/corrective-
maintenance history
All transmission, distribution, and substation assets are documented in Maximo with a current count of all primary and secondary distribution poles with height, class, installation date, and installed equipment, including whether the poles support telecom equipment.
65 7.5.2 Transmission Inspections and Maintenance
SFPUC owns and maintains transmission structures/assets , and detailed ground inspections are performed over 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, steel tower members (checking for rust and condition of metal), and powerline tree and limb encroachments.
Additionally, Aerial patrols of all transmission lines and 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. Thermal infrared scans of tower equipment are performed on an annual basis . 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. See Appendix 2 – SFPUC Wildfire Mitigation Metrics for annual detailed transmission tower inspections scheduled and completed, and the corrective maintenance orders generated and completed. The transmission system's most common corrective maintenance work orders were to replace tower numbers and danger signs.
7.5.3 Hot or Cold Wash
The SFPUC conducts annual PM 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 ultimately lead to failure ( Figure 13). The assignment and completion of hot or cold washing work orders are tracked in Maximo. The line crew supervisor verifies the completion of the work orders.
66 7.5.4 Distribution Inspections and Maintenance
The SFPUC meets the inspection requirements of CPUC GO 16535 and GO 95, Rule 1836 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 a SFPUC QEW. During the aerial patrols, the QEW looks at the tops of the poles for rot and damage. Intrusi ve pole inspections are performed on a 10- year cycle. Corrective maintenance work orders are created during the inspection and assigned a priority rank for remediation . See Appendix 2 – SFPUC Wildfire Mitigation Metrics for corrective maintenance performed in 2025.
Figure 13 – HHW Line Crew Hot Washing
35 GO 165 – Inspection Cycles for Electric Distribution Facilities 36 GO 95 Rule 18 – Reporting and Resolution of Safety Hazards Discovered by Utilities
67 7.5.5 Drone Inspections
SFPUC expanded its drone use in 2025 . Drone flights are now being used for a variety of projects for both water and power. The drone camera is capable of 200x zoom, which allows the drone to be flown a safe distance from the overhead conductors. Based on the clarity and detail of the images, the pilot proved to be successful, and we continue to evaluate a routine inspection schedule on specific distribution segments in the HFTD that are difficult to access on foot. We will continue to perform annual helicopter inspections as the drone has limited flight distances based on battery capacity and safety. Figure 14 illustrates the capabilities of drone images.
Figure 14 – Drone Photo of a Distribution Pole
7.6 Powerhouse / Substation / Switchyard Inspections and Maintenance SFPUC meets the requirements of CPUC GO 174, Rules for Electric Utility Substations.37 The SFPUC performs detailed substation/switchyard inspections monthly (See Appendix
37 CPUC GO 174 – Rules for Electric Utility Substations
68 2 – SFPUC Wildfire Mitigation Metrics ) and records findings and completion dates in Maximo. Any maintenance or repairs are reported to the Planning team, and a corrective maintenance work order is generated in Maximo.
PM work orders are set up in Maximo. Table 6 below shows the assets, equipment, and frequency of infrared inspections.
Table 6 – Infrared Inspections
Asset Equipment Frequency
Powerhouses
Connectors,
Switches, and
Circuit Breakers
Annual
Powerhouses
13.8 kV bus way
between GSU
and Switchgear
3 Month
Switchyards/Sub
stations
Connectors,
Switches, and
Circuit Breakers
Annual
Towers
Test Shoes,
Connectors, and
Splices
Annual
Transmission
Line Segments
Test Shoes,
Connectors, and
Splices
Annual
7.7 Workforce Training
The SFPUC has implemented complementary training programs for our workforce to support a safer work environment, ensure continuous improvement, and help reduce the risk of our facilities being the origin or contributing source for the ignition of a catastrophic wildfire.
69 7.7.1 Basic Fire Training
Each spring, HHW requires 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. This training supports the increased fire preparation and response capabilities of the HHW field staff and other support staff.
7.7.2 VM Training
VM training is conducted on an annual basis for ROW VM crew(s). The training covers all current vegetation clearance regulations per GO 95 Rule 35, PRC §§§ 4291- 93, NERC FAC-003, and herbicide application.
7.8 Recloser Policy
The SFPUC utilizes automatic reclosers for system reliability. Reclosers are used to attempt to automatically restore service following a risk event that results in the recloser operating. For certain types of faults , 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.
The SFPUC will disable all automatic reclosers when the Adjective Fire Danger Rating (AFDR) condition changes to “ High” and the FPI changes to “ Elevated.” The automatic reclose function w ill remain off until the A FDR condition is reporting “Low ,” and the FPI changes to Normal, usually following the onset of fall/winter precipitation.
When a line outage occurs during periods when reclosing is disabled, field personnel will perform an aerial or ground patrol of the line, from the recloser to the end of the line, prior to restoring service. If a fault (failure) is identified, it will be repaired or made safe before re-energizing the line.
70 7.9 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 is identified on a field patrol, the issue will be corrected as follows:
i. Immediate remediation if the issue poses or could pose a threat to public safety or continuity of service
ii. If the issue does not pose a threat to public safety or continuity of service, it will be reported to the Planning team, and a work order will be generated through Maximo to correct the issue based on established remediation timelines.
3. Public Notification.
a. The SFPUC will dispatch field personnel anytime the public alerts us to a potential hazard.
During wildfire events, the SFPUC may assign 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 could be activated, and an ICS organization could be used to manage the operational periods of the event.
7.10 Standardized Emergency Management System
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. The SFPUC has staff that are trained to fulfill certain
71 roles under the ICS and can be integrated into an ICS structure.
The SFPUC does not initiate our ICS structure during RFWs . When critical fire weather forecasts meet or exceed internal thresholds, the Control Center may dispatch QEWs to patrol power lines and stand by for potential de- energization. The Control Center maintains constant communication with SFPUC management regarding changing weather conditions and may execute a de-energization event if those triggers are met.
Our coordination and response to external PSPS events is discussed in the following Section.
7.11 De-energization for Public Safety
During critical fire weather conditions, the SFPUC may 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 does not have significant impacts on the SFPUC’s water delivery operations to the Bay Area since there are hydrogenator bypass systems and the presence of backup generators at critical facilities.
The SFPUC transmission lines are considered gen-ties. As a result, de-energization has no impact the California Independent System Operator (CAISO) grid operations.
The SFPUC distribution lines in the Stanislaus National Forest are in HFTD Tier 2 and provide power to four customers. Bay Area distribution lines are in HFTD Tier 2 and 3 and have interconnections with neighboring utilities providing alternate delivery paths which do not traverse an HFTD. When SFPUC de-energizes distribution or transmission lines for public safety, it has no consequences on first responder, critical health , or communication infrastructure.
The SFPUC continues to evaluate the de- energization criteria other utilities use in decision-making processes and leverage best practices most applicable to the fire risks associated with SFPUC facilities. The SFPUC currently considers the daily FPI, CALFIRE and USFS fire danger ratings, NWS weather forecasts including R FWs, forecasted sustained wind speeds and wind gusts, temperature, and relative humidity (these criteria
72 are also used to generate the daily FPI) 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 SFPUC staff as additional inputs to inform decisions to de-energize SFPUC facilities:
1. Adjective Fire Danger Indices (i.e., “Low,” “Moderate,” “High,” “Very High,” and “Extreme”) from regional Remote Automatic Weather Station(s) (RAWS).
2. Average wind speed and maximum wind gust gridded forecasts , obtained from HRRR Model 3-km; hourly resolution, issued once per hour.
3. Technosylva Wildfire Operations (Professional)™ FPI and Circuit Forecast Tool. o The Circuit Forecast Tool allows SFPUC to run simulated events for different weather thresholds. The Wildfire Operations (Professional) ™ application will then forecast four days out and show which circuits could be impacted, based on the thresholds chosen. We commonly use the thresholds below as a baseline for predicting the need to de-energize distribution circuits.
When the thresholds specified below are forecasted to be met, a n email message is generated automatically and is sent to the HHW Moccasin Control Center mailing list and additional SFPUC 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 Indices of any severity greater than “Low” (i.e., “Moderate,” “High,” “Very High,” or “Extreme”).
SFPUC 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, SFPUC staff will direct the operations personnel to de-energize specific circuit(s).
The HHW staff will continue monitoring the critical fire weather conditions. When fire risk
73 conditions improve, they will direct operations personnel to begin the process to re- energize the circuit(s) as outlined in Section 7.11.3.
SFPUC-initiated de-energization events are tracked as a metric and can be found in Appendix 2 – SFPUC Wildfire Mitigation Metrics . Historical de-energization events can be found in previous year WMPs.38
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 SFPUC lines are maintained by WSTD. A PG&E-initiated PSPS in the Peninsula and Bay area could de-energize the source feed to SFPUC distribution line segments , impacting SFPUC facilities. PG&E coordinates with SFPUC before, during, and after a PG&E - initiated 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 SFPUC have exchanged company representative contact information for communication during a potential PSPS event.
SFPUC staff also have access to the PG&E PSPS Portal and can review pertinent information in real time. SFPUC staff also participate in coordination calls that occur during an active PG&E PSPS. To prevent miscommunication and prepare internally, the SFPUC is very proactive and will often contact the PG&E representative before PG&E makes notifications regarding a potential PSPS.
Based on lessons learned from previous PG&E de-energization events, SFPUC worked with PG&E to identify lines and meters where SFPUC lines interconnect with PG&E lines.
This will help pinpoint which SFPUC lines could be shut off during a PG&E PSPS event and provide more accurate pre-planning and deployment of field staff to patrol lines before and after the event.
The SFPUC has a combination of permanent and mobile backup generators for locations identified as having the potential for being impacted by a PG&E PSPS. SFPUC
38 See SFPUC 2025 Wildfire Mitigation Plan, p.66
74 communicates with PG&E before a PSPS event and can mobilize generators to those facilities that do not have permanent standby generators.
7.11.1 Impacts on Public Safety
The SFPUC has not identified any impact to public safety when the SFPUC de-energizes power lines during critical fire weather events.
7.11.2 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 six retail customers, the SFPUC distribution system serves all SFPUC -owned and operated loads (facilities). Five customers are connected directly to the distribution system, and one is connected to the transmission system. The five customers served by the distribution line are located within HFTD and have backup generators. The sixth customer is in the non-HFTD and is served through the transmission system.
The SFPUC uses internal notification protocols when critical fire weather conditions are met or forecasted to be met. The HHW C ontrol Center notifies affected entities for both planned and unplanned outages.
7.11.3 Restoration of Service
During an IOU PSPS or SFPUC 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. S taff 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, drone, 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
75 required to complete a patrol, provided weather conditions have improved enough for safe flight operations. Following a wildfire event, 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 Authority Having Jurisdiction (i.e., CALFIRE, 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.
76 8. STAKEHOLDER OUTREACH AND ENGAGEMENT
8.1 Coordination with Critical Infrastructure Sectors
• Water and Wastewater Systems sector
• Communications sector
• Healthcare and Public Health sectors
8.1.1 Water and Wastewater Systems Sectors
The SFPUC does not provide electric service to any non- SFPUC-owned and operated water or wastewater department customers, nor does it impact any non- SFPUC-owned and operated water or wastewater 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 in the SFPUC Emergency Operations Plan.
8.1.2 Communications Sector
SFPUC supplies power to two cellular towers owned and operated by an independent cellular provider. During planned or unplanned interruptions of the SFPUC lines that could impact these cellular sites, the SFPUC will communicate with the cellular 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.
8.1.3 Healthcare and Public Health Sectors
The SFPUC does not provide services to any healthcare or public health facilities.
8.2 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 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
77 (SWIFT), a partnership that includes CALFIRE, 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 firebreak 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 CALFIRE to supplement ongoing communication with all first responders, including the county sheriff's office and local fire departments. T he SFPUC watershed lands in these two counties are State Responsibility Areas (SRA), and SFPUC staff are in regular communication with local CALFIRE staff throughout the calendar year.
CALFIRE’s Tuolumne-Calaveras Unit owns and operates a Firehawk helicopter (Figure 15) stationed at Columbia Airport, approximately 22 miles from the SFPUC Moccasin Powerhouse / Switchyard / Control Center. The primary benefit of the Firehawk helicopter is the increased water-carrying capacity of up to 800 gallons. If a wildland fire ignites near SFPUC assets, the Firehawk helicopter could be deployed and arrive within minutes and conduct an initial attack to reduce fire spread potential. Additionally, the National Park Service and USFS have helicopters for firefighting. Having these three agencies near SFPUC assets increases their initial attack capabilities.
78 Figure 15 – CALFIRE Firehawk Helicopter
SFPUC developed a Fire Dipping Strategy procedure that is shared with CALFIRE, Yosemite National Park, and the USFS . The purpose and scope of the procedure is to provide a reservoir dipping strategy that considers protection of water quality and the need for firefighting efforts. Fire response agencies use these SFPUC reservoirs to pull water during fire suppression activities . Because of water quality risks, SFPUC has ensured that partner agencies understand the benefits and risks and require the appropriate staff to be contacted before dipping from SFPUC reservoirs.
8.3 California Municipal Utilities Association (CMUA) Collaboration CMUA hosts a monthly working group call , specific to the development of the WMPs .
SFPUC actively participates in these calls, along with other POUs. These collaborative calls have helped shape the development of the SPFUC WMP and the sharing of resources, best practices, and lessons learned since the inception of the WMPs in 2019.
8.4 Mutual Assistance Agreements
The SFPUC is a member of the California Utilities Emergency Association (CUEA), which
79 plays a key role in ensuring communication between utilities during emergencies and has agreements in place to support utilities requesting mutual assistance.
80 9. EVALUATING THE PERFORMANCE OF THE PLAN
9.1 Metrics and Assumptions for Measuring Plan Performance We track performance and outcome metrics for the transmission and primary distribution system that 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. For this 2026-2028 WMP, we have implemented the performance and outcome metric tables developed by CMUA with input from participating utilities (including the SFPUC). For reference, we have moved all the metrics to appendices that are found at the end of this WMP.
9.2 Impact of Metrics on Plan
The SFPUC will continue to evaluate system performance and identify additional metrics as needed to measure fire risk reduction gained year after year. Figure 16 shows the metrics trends since 2019.
Figure 16 – Performance Metrics Trends Since 2019
81 The performance metrics demonstrate a reduction in wildfire-related risk exposure across SFPUC’s system over the past five years. Reportable ignitions within HFTD areas declined from isolated occurrences in 2020 and 2021 to zero incidents from 2022 to 2025 indicating improved system performance due to enhanced situational awareness capabilities, system hardening, VM, asset inspection and maintenance programs.
While circuit de-energization events peaked in 2021, subsequent years show a significant decline and stabilization. This is due to tree removal projects in Camp Mather and Yosemite National Park that reduced our risk of trees striking power lines. Following the removal of the trees, we re-evaluated our de-energization thresholds, which resulted in a decrease in de- energization events. Similarly, wire -down incidents within HFTD areas trended downward overall, with zero occurrences in 2022 and 2025 . Wire-down events outside HFTD areas remained minimal throughout the reporting period. Collectively, these trends suggest that wildfire mitigation strategies are contributing to reduced ignition potential and improved operational resilience in high-risk areas.
9.3 Monitoring and Auditing the Plan
The SFPUC is committed to operating a safe and reliable power grid while reducing the risk of SFPUC facilities being the source of ignition to a catastrophic wildfire. To achieve this, SFPUC staff continuously monitor projects and metrics outlined in this WMP to identify areas of improvement with the continuous goal of reducing the risk of SFPUC facilities be ing the origin or contributing source of a catastrophic wildfire. Execution of hardening projects, proactive inspection programs, PM programs, and data collected will inform the SFPUC staff of system improvements and areas that need additional attention.
9.4 Monitoring the Effectiveness of the Plan
We are committed to continuous improvement to minimize the risk of SFPUC facilities igniting or contributing to catastrophic wildfires. Through ongoing monitoring and evaluation of the mitigation strategies outlined in this Plan, we actively identify opportunities to strengthen our approach in pursuit of our core mission: delivering safe, reliable water and power to the region.
82 As our WMP has matured, we have refined how we categorize and track mitigation work to improve the accuracy and usefulness of our performance metrics. For example, early Plan evaluations revealed the need to consistently flag all inspections, as well as preventative and corrective maintenance activities that pertain to wildfire mitigation efforts. This enhancement has strengthened our ability to track compliance, ensure work completion, and rely on high- quality data to drive informed decision- making and continuous improvement of both our processes and this Plan.
9.5 Corrective Action Program
The SFPUC is committed to making the Plan effective and robust. We also understand that identifying gaps and areas for improvement in the Plan is a continuous process, learned through experience and monitoring industry best practices. As the WMP continues to mature, we will make changes to our Plan to integrate new policies, strategies, changes in technology, or identify 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 bi - annually and subsequently submitted to the WSAB bi-annually.
83 10. INDEPENDENT EVALUATOR REPORT
PUC § 8387(c) requires the SFPUC to contract with a qualified I ndependent Evaluator (IE) with experience in assessing the safe operation of electrical infrastructure to review and assess the comprehensiveness of this Plan.39
The last IE report was submitted to SFPUC’s Commission in 2023, along with the request for final approval of the 2023 SFPUC WMP. The IE presented his favorable report to the SFPUC at a Commission meeting. The Commission adopted both the WMP and IE Report40.
The SFPUC’s Plan will be reviewed annually by internal stakeholders. The Plan will be evaluated by an IE once every four years. This 2026-2028 Plan has been independently evaluated, and IE recommendations will be implemented and included in the 2029-2031 WMP.
39 Pub. Util. Code § 8387(c)
40 SFPUC Resolution 23-0134
84 Appendix 1 – Revision Log
Section Title Description
Acronyms Updated acronyms list.
List of Figures Updated List of Figures.
List of Tables Updated List of Tables.
All Reorganized sections to improve readability.
1 Executive Summary Updated with new language pursuant to SB 254. 2 Overview of the WMP Moved this section and re-worded for clarity.
2.1.1-2.1.3 Objectives of the WMP Reorganized section and re-worded for clarity.
2.2 Statutory Cross-Reference Table Updated to reflect SB254 changes.
2.3 Utility Overview and Context Setting Updated with 2025 data. Re-worded for clarity. 3 Overarching Initiatives for 2025-
2029 WMP
Updated entire section to include current and
future initiatives. Updated budget section.
4 Summary of 2025 WMP Activities Updated entire section with 2025 project updates. 5 Roles and Responsibilities Moved section towards beginning of WMP and re- worded for clarity.
6 Wildfire Risk and Risk Drivers Updated section with 2025 data. Included Fire Hazard Severity Zone map. Included updated
SFPUC map with HFTD boundaries.
7-7.14.3 Wildfire Prevention Strategies Updated entire section. Updated FPI language.
Updated System Hardening projects for 2025.
Updated Vegetation Management section with
2025 data.
8.2 Fire Agency (First Responder)
Training
Updated with 2025 language.
8.5 Mutual Assistance Agreements Removed participation in Western Energy Institute’s Western Region Mutual Assistance
Agreement.
9.1 Metrics and Assumptions for
Measuring Plan Performance
Updated with 2025 data. Included graph for Plan
performance.
9.2 Impacts of Metrics on Plan Re-worded for clarity and assessment of previous years’ metrics.
10 Independent Evaluator Report Re-worded for clarity.
Appendix 1 Revision Log Updated with changes for 2026 WMP submittal.
Appendix 2 Metrics Adopted CMUA metrics format and moved all metrics to Appendix 2. Updated metrics with 2025
data.
85 APPENDIX 2 – SFPUC WILDFIRE MITIGATION METRICS
TABLE 1. EXTERNAL WILDFIRE RISK METRICS
Red Flag
Warnings
Number of Red Flag Warning Days in the National Weather Service (NWS) Weather Zone(s) encompassing the Utility’s Service Territory
0 - - - - Days The number of days is applicable to Red Flag Warnings issued within HFTD zones containing overhead transmission and
distribution lines.
Wind
Conditions
Number of High Wind Warning Days in the National Weather Service (NWS) Weather Zone(s) encompassing the Utility’s Service Territory
11 - - - - Days The number of days is applicable to High Wind Warnings issued within HFTD zones containing overhead transmission and
distribution lines.
Notes
• Red Flag Warnings and High Wind Warnings are issued by the National Weather Service (NWS). • Table displays the total number of warning days per calendar year. • Fire Weather Zones monitored (within HFTD) – 220, 221, 508, 509, 510, 511, 512, 590, and 592.
86 TABLE 2. PERFORMANCE METRICS
Notes
• All metrics reflect work performed within and outside the High Fire Threat District (HFTD). • “Scheduled” represents the planned annual work target. • “Completed” represents actual work performed during the calendar year. • Units are reported in circuit miles unless otherwise specified.
Metric Category Progress
Metric
2025
Scheduled
2025
Completed
2026
Scheduled
2026
Completed
2027
Scheduled
2027
Completed
2028
Scheduled
2028
Completed
2029
Scheduled
2029
Completed
Units Comments
Distribution Inspections
Patrol
Inspections
45.9 45.9 - - - - - - - - Circuit Miles Completed through a combination of ground and aerial patrol.
Detailed
Inspections
19 19 - - - - - - - - Work Orders 19 work orders totaling 438 poles inspected resulting in 3 cross arms replaced due to wood rot. Cross arms replacements are fiberglass.
Intrusive
Inspections
17 17 - - - - - - - - Poles 17 work orders totaling 336 poles tested. 6 poles replaced due to failed tests.
Vegetation
Inspections
45.9 45.9 - - - - - - - - Circuit Miles Results of inspections are included in Section 7.4.8 – Vegetation Management Dashboard.
Vegetation
Maintenance
Work Orders
334 334 - - - - - - - - Work Orders Each work order encompasses multiple trees. The vegetation Dashboard in Section
7.4.8 provides the number of trees trimmed or removed.
Transmission Inspections
Patrol
Inspections
324.4 324.4 - - - - - - - - Circuit Miles Completed through a combination of ground and aerial patrol.
Detailed
Inspections
180 180 - - - - - - - - Towers
Vegetation
Inspections
324.4 324.4 - - - - - - - - Circuit Miles
Vegetation
Maintenance
Work Orders
8 8 - - - - - - - - Work Orders Each work order contains multiple trees as they are inspected by span distance (tower to tower). For 2025, 273 trees were trimmed or removed through eight work orders.
Tower Hot Wash* GO 95/165 11 11 - - - - - - - - Work Orders) * These numbers reflect the total number of work orders that were generated to hot wash towers in 2025. Each work order encompasses multiple towers.
Substation/Switchyard
Inspections
GO 128 60 60 Substations/
Switchyards
SFPUC owns and operates 5 substations/switchyards. Each is inspected monthly.
87 TABLE 3. OUTCOME METRICS
Event Category Metric Description 2025 2026 2027 2028 2029 Units Comments Outage Events –
Distribution
Vegetation-Caused 0 - - - - # Outages
Wire Down – Inside HFTD 0 - - - - # Outages
Wire Down – Outside HFTD 0 - - - - #Outages
Preemptive De-
Energizations
0 #Events
Other 5 - - - - # Outages Unplanned outages are tracked in our e-Logger system. Three of the five outage events occurred during winter storms where no probability of wildfire could occur due to snow on the ground. The remaining 2 events were blown fuses but did not cause ignitions.
Unknown 0 # Outages
Outage Events –
Transmission
Vegetation-Caused 0 - - - - # Outages
Wire Down – Inside HFTD41 0 - - - - # Outages
Wire Down – Outside HFTD 0 - - - - # Outages
Preemptive De-
Energizations
0 - - - - # Events
Other 0 - - - - # Outages
Unknown 0 # Outages
Ignitions – Distribution42
Vegetation-Caused 0 # Ignitions
Other 0 # Ignitions
Unknown 1 - - - - # Ignitions On August 5, 2025, at approximately 1500 hours, a vegetation fire was reported near San Antonio Reservoir. Dispatch notifications were initiated and contractors in the San Antonio watershed were directed to evacuate. Upon arrival, access was established for responding agencies and coordinated suppression efforts with CALFIRE and Alameda County Fire successfully halted forward progression in multiple areas, preventing the fire from spreading toward critical infrastructure, including the dam and surrounding roadways. Additional resources contained the fire at approximately 16 acres. Fire watch personnel, supported by CALFIRE and WSTD resources, remained on site overnight to monitor and address any remaining hot spots. The cause is still under investigation.
Ignitions – Transmission
Vegetation-Caused 0 # Ignitions
Other 0 # Ignitions
Unknown 0 # Ignitions
41 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. 42 A fire ignition must meet the following criteria: (1) SFPUC facility was associated with the ignition of the fire. (2) The fi re was self-propagating and of 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.
1 SAN FRANCISCO PUBLIC
UTILITIES COMMISSION
(SFPUC)
2026-2028 WILDFIRE
MITIGATION PLAN
INDEPENDENT EVALUATOR
REPORT
September 1, 2026
DISCLAIMER
California Public Utilities Code (PUC) § 8387 requires local publicly owned electric utilities or electrical cooperatives (herein POU) to prepare a Wildfire Mitigation Plan (WMP or Plan). Additionally, POUs are required to contract with a qualified Independent Evaluator with experience to assess the comprehensiveness of its WMP.
The San Francisco Public Utilities Commission (SFPUC) has requested Grid Subject Matter Experts (GridSME) to conduct a review and provide an Independent Evaluation report of the SFPUC’s 2026-2028 WMP to ensure it meets the requirements of PUC § 8387. GridSME’s Independent Evaluator (IE) review and assessment is based only on SFPUC’s 2026-2028 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 Independent Evaluation 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.
Table of Contents
1.0 Introduction ................................ ................................ ................... 1
2.0 Statutory Requirements for the Wildfire Mitigation Plan .......................... 2
3.0 Independent Evaluation Methodology ................................ .................. 3
4.0 Company Overview ................................ ................................ .......... 5
5.0 GridSME’s Independent Evaluation ................................ ................... 10
6.0 PUC § 8387 Requirements ................................ .............................. 10
6.1 PUC § 8387(b)(2)(A) ................................ ................................ ... 10
6.2 PUC § 8387 (b)(2)(B) ................................ ................................ .. 12
6.3 PUC § 8387 (b)(2)(C) ................................ ................................ .. 13
6.4 PUC § 8387 (b)(2)(D) ................................ ................................ . 15
6.5 PUC § 8387 (b)(2)(E) ................................ ................................ .. 16
6.6 PUC § 8387(b)(2)(F) ................................ ................................ ... 16
6.7 PUC § 8387(b)(2)(G) ................................ ................................ .. 18
6.8 PUC § 8387(b)(2)(H) ................................ ................................ .. 19
6.9 PUC § 8387 (b)(2)(I) ................................ ................................ .. 22
6.10 PUC § 8387 (b)(2)(J)(i) and (ii) ................................ .................... 23
6.11 PUC § 8387 (b)(2)(K) ................................ ................................ .. 25
6.12 PUC § 8387 (2)(L) ................................ ................................ ...... 26
6.13 PUC § 8387 (2)(M) ................................ ................................ ..... 26
6.14 PUC § 8387 (2)(N)(i), (ii) and (iii) ................................ ................. 27
6.15 PUC § 8387 (b)(3) ................................ ................................ ...... 28
6.16 PUC § 8387 (c) ................................ ................................ .......... 29
7.0 Summary ................................ ................................ ..................... 30
1.0 Introduction
The threat of catastrophic wildfires continues to pose a significant risk not only to the State of California, but to the entire western United States and beyond. These fires are fueled in part by changing weather patterns that have resulted in prolonged drought conditions, rising temperatures, and increasingly intense wind events. When an ignition occurs during critical fire weather conditions, it can rapidly escalate into a catastrophic wildfire.
Although wildland fires can originate from many different ignition sources, extreme weather events heighten the risk to utility infrastructure, increasing the likelihood of a fault-related ignition event. While utility-caused wildfires account for fewer than 10 percent of all wildland fire ignitions, some utility-related fires have occurred during extreme fire weather conditions and have resulted in catastrophic outcomes.
California legislation, codified in California Public Utilities Code (PUC) § 8387(a), requires that “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.” In compliance with this statute, the San Francisco Public Utilities Commission’s (SFPUC) Wildfire Mitigation Plan (WMP or Plan) describes in detail the programs, policies, and initiatives implemented to ensure its electrical infrastructure is constructed, maintained, and operated in a manner that minimizes the risk of causing or contributing to a catastrophic wildfire.
To meet the independent evaluation requirements of PUC § 8387, the SFPUC engaged Grid Subject Matter Experts1 (GridSME) to conduct an independent review of its 2026–2028 WMP. The scope of this engagement included an assessment of the Plan’s comprehensiveness as written,
1 https://www.gridsme.com/
2 preparation of a report documenting findings, and presentation of those findings to the SFPUC’s governing board at a publicly noticed meeting.
The GridSME team brings more than 100 years of combined experience in electric utility system operations and wildfire mitigation and is well-qualified to assess the comprehensiveness of utility WMPs. GridSME has previously served as the independent evaluator for five California publicly owned utilities. Based on its review of the SFPUC’s 2026–2028 Wildfire Mitigation Plan, GridSME concludes that the Plan is comprehensive and satisfies all applicable requirements of PUC § 8387.
2.0 Statutory Requirements for the Wildfire Mitigation Plan California Senate Bill 254 (09/19/2025) amended PUC § 8387(b)(1) to read as follows: “After January 1, 2026, a local publicly owned electric utility or electrical cooperative shall prepare a wildfire mitigation plan and shall submit the plan to the California Wildfire Safety Advisory Board2 at least once every four years on a schedule determined by the California Wildfire Safety Advisory Board.” The Wildfire Safety Advisory Board (WSAB) consists of an appointed seven-member panel that serves in an advisory role within the California Office of Energy Infrastructure Safety (OEIS).3 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.”
2 https://energysafety.ca.gov/what-we-do/wildfire-safety-advisory-board/ 3 https://energysafety.ca.gov/
3 3.0 Independent Evaluation Methodology
GridSME conducted a review and evaluation of the SFPUC 2026–2028 WMP, focusing on the Plan as prepared. The review included an assessment of the Plan’s structure, content, and supporting documentation, as well as the development of written comments and recommendations for SFPUC’s consideration. GridSME’s final evaluation examines the Plan’s overall comprehensiveness and consistency with statutory requirements, including its compliance with the 17 elements specified in California PUC § 8387 (See Table 1). In addition, the evaluation considers the extent to which the Plan incorporates guidance, recommendations, and prior advisory opinions issued by the WSAB, and guidance by the California Municipal Utilities Association (CMUA).
Table 1 – CPUC § 8387 Statutory Requirements
PUC
Code 8387
Compliance Requirements and Corresponding Plan Sections (a) Each local publicly owned electric utility and electrical cooperative shall construct, maintain, and operate its electrical lines and equipment in a manner that will minimize the risk of wildfire posed by those electrical lines and equipment.
(b) (1) The local publicly owned electric utility or electrical cooperative shall, before January 1, 2020, prepare a wildfire mitigation plan. After January 1, 2026, a local publicly owned electric utility or electrical cooperative shall prepare a wildfire mitigation plan and shall submit the plan to the California Wildfire Safety Advisory Board at least once every four years on a schedule determined by the California Wildfire Safety Advisory Board (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.
(b)(2)(B) The objectives of the wildfire mitigation plan. (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
4 the risk of its electrical lines and equipment causing catastrophic wildfires, including consideration of dynamic climate change risks. (b)(2)(D) A description of the metrics the local publicly owned electric utility or electrical cooperative plans to use to measure and track the implementation of the plan and the assumptions that underlie the use of those metrics.
(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.
(b)(2)(F) Protocols for disabling reclosers and deenergizing portions of the electrical distribution system that consider the associated impacts on public safety, and protocols related to mitigating the public safety impacts of those protocols, including impacts on critical first responders and on health and communication infrastructure.
(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. (b)(2)(H) Plans for vegetation management.
(b)(2)(I) Plans for inspections of the local publicly owned electric utility’s or electrical cooperative’s electrical infrastructure.
(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. (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.
5 (b)(2)(L) A methodology for identifying and presenting enterprise-wide safety risk and wildfire-related risk.
(b)(2)(M) A statement of how the local publicly owned electric utility or electrical cooperative will restore service after a wildfire.
(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. (b)(2)(N)(ii) Identify any deficiencies in the wildfire mitigation plan or its implementation and correct those deficiencies.
(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. (3) In each year it is required to submit a plan, the local publicly owned electric utility or electrical cooperative shall present its wildfire mitigation plan in an appropriately noticed public meeting. The local publicly owned electric utility or electrical cooperative shall accept comments on its wildfire mitigation plan from the public, other local and state agencies, and interested parties, and shall verify that the wildfire mitigation plan complies with all applicable rules, regulations, and standards, as appropriate. (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.
4.0 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 electricity customers, and power to some residents and businesses of San Francisco through the CleanPowerSF program. The SPFUC’s mission is to provide its customers
6 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 its care.4
The SFPUC is comprised of six business functions, or enterprises, including the Water Enterprise. The Water Enterprise has six divisions, including Hetch Hetchy Water (HHW), Water Supply & Treatment Division (WSTD), and Natural Resources and Lands Management (NRLMD) (Figure 1).
HHW, WSTD, and NRLMD have defined responsibilities for managing and maintaining the electrical assets, and land on which they reside, which are described in this Plan. The Water Enterprise is responsible for the development, execution, and oversight of this WMP.
4 “SFPUC About Us,” San Francisco Public Utilities Commission: Our Mission. See https://www.sfwater.org/index.aspx?page=161
7 Figure 1 – SFPUC Organizational Structure
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, water transmission facilities, a switchyard, and power distribution assets in Alameda and San Mateo counties. The SFPUC owns the watersheds above reservoirs in Alameda and San Mateo counties.
8 NRLMD is responsible for managing, operating, and maintaining Bay Area lands and watersheds. NRLMD does not operate and maintain electrical assets; however, they do perform vegetation management around the distribution poles and overhead lines in Alameda County and the Peninsula Watershed.
SFPUC owns, maintains, and operates approximately 324 circuit miles of overhead transmission lines, and approximately 49 circuit miles of overhead distribution lines (see Figure 2 below). The power transmission and distribution facilities are within PG&E’s service territory, where PG&E is the energy provider. SFPUC 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 SFPUC-owned transmission, or from the CA grid, to power SFPUC Water Enterprise operations. Approximately 28% of SFPUC’s transmission facilities and 95% of its overhead 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 areas are:
1. Tier 1, High Hazard Zone – Zones which are in direct proximity to communities, roads, and utility lines, and are 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.
Figure 1 – SFPUC's Electric Service Areas
5.0 GridSME’s Independent Evaluation
The SFPUC’s 2026–2028 WMP builds upon the successes and lessons learned from the 2023–2025 WMP’s and is designed to maintain compliance with the 17 elements required under California PUC § 8387. In developing the 2026–2028 WMP, the SFPUC also considered recommendations provided through WSAB Advisory Opinions, guidance issued by the CMUA, and recommendations from the IE. Each of the 17 requirements (elements) of PUC § 8387 is presented separately below. For each element, the IE provides a high‑level assessment of the Plan, including its comprehensiveness, evaluation of compliance, and, if applicable, recommendations for consideration in future WMP updates.
6.0 PUC § 8387 Requirements
See Table 1.
6.1 PUC § 8387(b)(2)(A)
Requirement: An accounting of the responsibilities of persons responsible for executing the plan.
Assessment:
The SFPUC WMP provides a very detailed organizational chart of all divisions of the SFPUC under the leadership of the General Manager (see Figure 1 in WMP). Additionally, a list of personnel positions is provided, listing those who are responsible and/or accountable for development, approval, and implementation of this Plan (see Table 2 below). The SFPUC Commission has responsibility for Plan approval. The SFPUC Assistant General Manager of Water has overall accountability for the development and implementation of the WMP and delegates responsibilities to section
11 leadership who have specific responsibilities for the various wildfire mitigation programs such as vegetation management, substation inspections, line inspections, line construction, etc.
The SFPUC’s Fire Mitigation Specialist oversees the overall development and maintenance of the SFPUC WMP. The Fire Mitigation Specialist 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 the Plan. This team meets monthly, or as required. The Fire Mitigation Specialist is also the primary SFPUC liaison with the CMUA for all wildfire mitigation discussions and monitors all WSAB communications and quarterly meetings.
Comment:
The SFPUC Organizational Chart and Roles and Responsibilities are clearly defined and documented, as shown in Table 2 below. SFPUC personnel have an appropriate understanding of their assigned roles and areas of responsibility. The establishment of a dedicated Fire Mitigation Specialist position provides centralized oversight for the ongoing development, implementation, and maintenance of the WMP.
Table 2 – SFPUC Roles and Responsibilities
Activity
HHW Division: All SFPUC
Transmission Facilities; and
Distribution Facilities Located
within Tuolumne, Stanislaus,
Mariposa, and San Joaquin
Counties
WSTD and NRLMD 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
NRLMD and Peninsula Area
Manager
Vegetation Management and
Removal
HHW Operations and Maintenance
Manager
NRLMD 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
12 Activity
HHW Division: All SFPUC
Transmission Facilities; and
Distribution Facilities Located
within Tuolumne, Stanislaus,
Mariposa, and San Joaquin
Counties
WSTD and NRLMD Divisions:
Distribution Facilities Located in
Alameda and San Mateo
Counties
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 Fire Mitigation Specialist Fire Mitigation Specialist Plan Review HHW Division Manager NRLMD Manager, WSTD Division Manager,
Plan Review CCSF City Attorney’s Office; and
SFPUC Assistant General
Manager of Water
CCSF City Attorney’s Office; and
SFPUC Assistant General
Manager of Water
Plan Approval SFPUC SFPUC
6.2 PUC § 8387 (b)(2)(B)
Requirement: The objectives of the wildfire mitigation plan.
Assessment:
SFPUC WMP Section 2. describes the three primary objectives of the SFPUC WMP that support:
• Minimizing sources of ignition,
• Improving grid reliability and resiliency, and
• Measuring Plan effectiveness.
All wildfire mitigation programs and initiatives described in the SFPUC WMP are designed to construct, maintain, or operate its electrical lines and equipment in a manner that will minimize the risk of SFPUC electrical assets being the origin or contributing source for the ignition of a catastrophic wildfire.
13 Comment:
The SFPUC continues to develop its wildfire mitigation programs and initiatives to meet and improve on its three primary objectives. The 2026- 2028 Plan provides a comprehensive overview of programs that support risk evaluation, operations, vegetation management, asset management, and situational awareness.
Additionally, the 2026-2028 WMP outlines the primary initiatives for this Plan which are to:
• Maintain compliance with Public Utilities Code (PUC) § 8387 and continue to mature our wildfire mitigation initiatives. • Continue to develop improvements to the Wildfire Operations (Professional)™ risk modeling software.
• Continue to track metrics to inform the SFPUC on how the WMP programs and initiatives are performing.
• Evaluate and assign priorities to system hardening options and create implementation time frames.
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.
Assessment:
SFPUC WMP Section 4, Summary of 2025 Wildfire Mitigation Activities, provides a comprehensive overview of major accomplishments achieved during the 2023–2025 WMP cycle across construction, operations, and maintenance programs. These efforts demonstrate the SFPUC’s strong and
14 sustained commitment to employee and public safety, system reliability, and reducing the risk of utility infrastructure being a source of ignition for a wildfire.
Throughout the 2023-2025 WMP cycle, the SFPUC has made significant investments in advanced risk assessment tools, enhanced situational awareness capabilities, continued improvements to its vegetation management programs, and construction, operations, and maintenance programs. Key accomplishments include:
• Installation of Hexion ArmorBuilt™ pole wrap on 190 distribution poles located within the HFTD;
• Continued testing and training of personnel on the full capabilities of Technosylva’s Wildfire Analyst Enterprise (WFA‑E) application – now rebranded as Wildfire Operations (Professional)™ – with the goal of fully operationalizing the platform and continuing to support daily situational awareness and real-time operational decision- making;
• Engagement of LiveEO, a satellite-based vegetation monitoring service that provides high-resolution data and enhanced visibility into vegetation conditions, including growth patterns and proximity to electrical conductors;
• Ongoing replacement of non-exempt equipment throughout the HFTD; and
• Targeted overhead-to-underground conversions in areas with elevated wildfire risk.
In Section 7, Wildfire Prevention Strategies, the SFPUC 2026–2028 WMP outlines a comprehensive roadmap of planned initiatives, including expanded vegetation management programs, system hardening projects, transmission and distribution inspections and maintenance activities,
15 substation inspections, and the continued development and integration of situational awareness tools to further reduce wildfire risk.
Comment:
The SFPUC’s wildfire mitigation strategies and programs continue to mature and strengthen year over year demonstrating a strong and sustained commitment to employee and public safety, system reliability, and reducing the risk of being the source of ignition for a wildfire.
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 measure and track the implementation of the plan and the assumptions that underlie the use of those metrics.
Assessment:
SFPUC WMP Section 9, Evaluating the Performance of the Plan. The SFPUC has adopted the performance and outcome metric tables developed by the CMUA, incorporating input from participating utilities, including the SFPUC, as well as the WSAB (see WMP Appendix 2). Implementation of these standardized metrics will result in the systematic tracking of a significantly expanded set of performance and outcome measures. This enhanced framework will support a more robust and comprehensive evaluation of the SFPUC’s wildfire mitigation programs and their effectiveness in reducing wildfire risk.
Comment:
The SFPUC has done an excellent job defining clear, specific metrics, and through the use of Maximo, they are able to effectively document and track those metrics.
16 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:
Previous WMPs describe specific incidents which resulted in an ignition(s) attributed to SFPUC assets. In each case the SFPUC conducted a root cause analysis and took quick action to reduce the risk of similar occurrences in the future.
Comment:
Although the SFPUC experiences a relatively low frequency of risk events – resulting in limited quantitative historical data – the organization maintains a robust risk management posture. Each identified risk event is systematically investigated, with corrective actions and process enhancements implemented as warranted. This approach reflects SFPUC’s continuous improvement framework and its ongoing commitment to mitigating wildfire-related risks and strengthening operational resilience.
While data is limited, the SFPUC has not had a reportable ignition incident since 2022.
6.6 PUC § 8387(b)(2)(F)
Requirement: 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.
17 Assessment:
SFPUC WMP Section 7.8, Recloser Policy, describes SFPUC’s protocols for disabling line reclosers on 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.
In addition to fire weather condition declarations issued by the U.S.
Forest Service (USFS), the SFPUC also relies on the Wildfire Operations (Professional) platform to support operational decision‑making through four‑day weather and wildfire risk forecasts. These forecasts provide advanced visibility into evolving fire‑weather conditions, enabling proactive planning, coordination, and operational readiness.
The platform also includes circuit‑level forecasting and automated alerting capabilities that allow personnel to establish operational thresholds based on key meteorological parameters, including sustained wind speed, wind gusts, and relative humidity. When predefined thresholds are met or exceeded, the system generates automated alerts for affected circuits. This functionality enables early identification of elevated fire‑weather risk impacting specific infrastructure, supporting timely mitigation actions and improved situational awareness.
Section 7.11, De-energization for Public Safety, describes the SFPUC protocols for de-energizing transmission or distribution lines for public safety during critical fire weather conditions. The SFPUC has only six retail customers connected directly to their facilities. Five customers are located within a Tier 2 HFTD, and one is outside the HFTD. Those customers have a generator and experience no adverse impacts due to a utility power interruption. All other load is internal SFPUC owned and operated facilities that have backup generation and do not experience any operational impacts.
18 Section 8.1, Coordination with Critical Infrastructure Sectors. The SFPUC has identified only two privately owned and operated cellular antennas that could be impacted by a SFPUC De-Energization for Public Safety event. 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.
6.7 PUC § 8387(b)(2)(G)
Requirement: Appropriate and feasible procedures for notifying a customer who may be impacted by the deenergizing 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:
Section 8, Stakeholder Outreach and Engagement, describes the SFPUC procedures for communicating with stakeholders regarding potential service interruptions. The SFPUC provides retail electric service to a lodging facility located in the Stanislaus National Forest, and two communication antennas. These customers maintain a backup generator at their facilities and experience no operational impacts when there is an interruption in service. The SFPUC meets with these customers to provide them with an overview of the SFPUC operational protocols, potential impacts to them, and will communicate with them if an interruption in service is imminent.
19 Additionally, the SFPUC has protocols in place for collaboration and communication with neighboring utilities, fire agencies, CMUA, and the WSAB.
Comment:
SFPUC must be commended on their communication and collaboration with external partners and neighboring utilities. These partners include CAL FIRE, USFS, Bureau of Land Management, Pacific Gas & Electric, and other local, regional, state, and federal agencies.
6.8 PUC § 8387(b)(2)(H)
Requirement: Plans for vegetation management.
Assessment:
The SFPUC implements a comprehensive, risk‑based Vegetation Management (VM) program for its electric transmission, distribution, and substation facilities that meet or exceed applicable minimum industry standards and statutory requirements. SFPUC’s VM program, as described in Section 7.4 of the WMP, is designed to ensure public and worker safety, electric system reliability, and wildfire risk reduction while maintaining environmental stewardship and regulatory compliance.
SFPUC’s VM inspection and maintenance programs are consistent with the requirements of CPUC General Order (GO) 95, NERC Reliability Standard FAC‑003, California Public Resources Code (PRC) §§§ 4291, 4292 and 4293, and CAL FIRE’s California Power Line Fire Prevention Field Guide. Program implementation is overseen by the Right of Way (ROW) Manager and governed by SFPUC internal procedures and plans, including:
• Hetch Hetchy Water and Power (HHW) Transmission Vegetation Management Program
20 • HHW 115 & 230 kV Transmission Vegetation Management Plan • Right of Way (ROW) Integrated Vegetation Management (IVM) Policy
• HHW Power Distribution Vegetation Management Plan
VM crews perform work with registered professional foresters, and with arborists with the following certifications: International Society of Arboriculture (ISA) Certified Arborist, ISA Certified Utility Arborist, and ISA Tree Risk Assessment Qualified (TRAQ).
The SFPUC continues to leverage the internally developed “Vegetation Management Dashboard” to track VM work. (see Figure 3 below).
Figure 2 – Vegetation Management Dashboard
HHW continues to receive data from LiveEO, a software company that provides artificial intelligence (AI)–driven satellite observation data focused on electric infrastructure assets. SFPUC currently leverages LiveEO’s vegetation management capabilities. LiveEO applies its AI models to satellite imagery to identify and locate hazard trees within SFPUC’s overhead electrical line footprint. HHW will use this data to track vegetation growth trends and to help inform future vegetation management work needs.
Comment:
The IE commends the SFPUC for its level of detail in describing the VM programs.
The IE recommends that SFPUC expand the documented VM
procedures to encompass the Water Supply and Treatment and the Natural Resources and Land Management divisions, in addition to the Hetch Hetchy Water division. Expanding the procedures will help ensure consistency, clarity, and uniform implementation of VM practices across all applicable Water Enterprise divisions.
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:
SFPUC WMP Section 7.5, Overhead 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 to the South Coast Range
23 Mountains. The SFPUC asset inspection programs are consistent with the requirements of CPUC GO’s 95 and 165 for electric distribution and transmission facilities, and GO 174 for substations.
Comment:
The IE commends the SFPUC for the level of detail provided in describing the asset inspection programs.
The IE recommends that SFPUC expand the documented line inspection procedures to encompass the Water Supply and Treatment and the Natural Resources and Land Management divisions, in addition to the Hetch Hetchy Water division. Expanding the procedures will help ensure consistency, clarity, and uniform implementation of inspection practices across all applicable Water Enterprise divisions.
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.
24 Assessment:
SFPUC WMP Section 6, Wildfire Risks and Risk Drivers, describes the risks and risk drivers associated with design, construction, operation and maintenance; and topographic and climatological risk factors associated with SFPUC electrical assets within the HFTD.
The SFPUC does not have a high number of risk events, which is the primary factor for the limited data available to draw meaningful conclusions and identify asset risk factors. However, vegetation contact has been identified as their primary risk driver for a wildfire ignition from electrical facilities. SFPUC has identified a number of potential risks based on experience of long-term employees and has instituted various risk reduction programs as described in Section 6.3 of the WMP.
Approximately 35% of the SFPUC service territory is within the HFTD but poses minimal risk for 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 have dense vegetation, however, a large portion of their service territory 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 service territory 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.
Comment:
In 2023 the IE recommended that the SFPUC leverage Technosylva’s Wildfire Operations (Professional) application, to inform the prioritization of risk reduction programs to those areas of highest risk first. In 2025, the
25 SFPUC further refined this risk‑based framework by delineating nine discrete operating zones (see Figure 4 below), facilitating a more granular, daily zone‑specific wildfire risk assessment and enabling targeted application of mitigation strategies.
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.
Assessment:
SFPUC WMP Section 6.5, Changes to the CPUC Fire Threat Map, states the SFPUC agrees with the existing CPUC HFTD boundaries and makes no recommendation for expanding or minimizing the current HFTD.
The Wildfire Operations (Professional) application provides SFPUC with visibility into CPUC HFTD boundaries and neighboring investor‑owned utility wildfire risk area boundaries. This visibility supports validation that SFPUC‑designated high fire risk areas are accurately and appropriately defined.
Figure 3 – SFPUC Operating Zones
26 Additionally, the SFPUC reviewed CAL FIRE’s Fire Hazard Severity Zone (FHSZ) map and concluded there is no additional wildfire threat than what is identified within the HFTD.
6.12 PUC § 8387 (2)(L)
Requirement: A methodology for identifying and presenting enterprise-wide safety risk and wildfire-related risk.
Assessment:
SFPUC WMP Section 6.1, Enterprise-Wide Safety Risks, describes the SFPUC’s enterprise wildfire risk reduction methodology. The SFPUC continues to rely primarily 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 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 avoid similar risks.
Comment:
The adoption of the CMUA- and WSAB-recommended metrics will enhance SFPUC’s ability to consistently track risk events and systematically prioritize risk mitigation actions based on data-driven insights.
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.
27 Assessment:
SFPUC WMP Section 7.11.3, Restoration of Service, describes SFPUC’s procedures for restoring electrical service following a wildfire, a de- energization for public safety event, or if a line experiences an unplanned (forced) interruption for any reason.
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 authority 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, the SFPUC will perform repairs, and restoration will proceed following established priority and restoration procedures.”
The SFPUC has well-defined standard operating procedures for safely restoring service following an interruption, a de-energization for public safety, or other events that might cause significant infrastructure impacts.
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
28 are carried out under the plan, other applicable statutes, or commission rules.
Assessment:
SFPUC WMP Section 9, Evaluating the Performance of the Plan, describes the SFPUC methodology for monitoring, auditing, and evaluating the implementation and effectiveness of its WMP programs. The SFPUC leadership are responsible for ensuring compliance with SFPUC’s wildfire mitigation programs, and the Assistant General Manager of Water has overall accountability for the development and implementation of the Plan.
All specific program responsibilities are delegated to leadership overseeing their respective departments. Additionally, the Fire Mitigation Specialist oversees the overall development and maintenance of the WMP and continuously monitors the ongoing status of the wildfire mitigation programs.
As previously mentioned, the SFPUC continues to have limited data (metrics) to help determine plan effectiveness or identifying plan deficiencies. This is due to the high reliability of its electrical grid.
For the 2026-2028 Plan cycle the SFPUC has adopted the metrics tracking template recommended by both the CMUA and WSAB. This will provide more detailed metrics and support more informed decisions on prioritizing wildfire mitigation programs.
6.15 PUC § 8387 (b)(3)
Requirement: In each year it is required to submit a plan, the local publicly owned electric utility or electrical cooperative shall 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
29 state agencies, and interested parties, and shall verify that the wildfire mitigation plan complies with all applicable rules, regulations, and standards, as appropriate.
Comment:
The SFPUC has consistently maintained full compliance with this requirement. Annually, prior to the WMP filing deadline, the SFPUC made the WMP available for public review and comment both through its website and during a duly noticed public meeting of the SFPUC Commission.
6.16 PUC § 8387 (c)
Requirement: 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.
Comment:
The SFPUC has consistently maintained full compliance with this requirement. In all prior filing years in which an IE report was required, the SFPUC has contracted with GridSME to provide an independent evaluation of their Plan. As previously mentioned, GridSME brings years of experience in the development of Wildfire Mitigation Plans.
The IE is scheduled to present the SFPUC 2026-2028 WMP at a publicly noticed meeting of the Commission on September 8, 2026.
30 7.0 Summary
The SFPUC seeks to comply with California Senate Bill 901 and 254, codified in PUC § 8387, by ensuring that its electrical lines and equipment are constructed, maintained, and operated in a manner that minimizes wildfire risk. Since its initial WMP filing in 2019, SFPUC has demonstrated ongoing and measurable improvements to its Wildfire Mitigation Program.
Based on an Independent Evaluation of SFPUC’s 2026–2028 WMP, GridSME finds that the Plan is comprehensive and satisfies the requirements of Public Utilities Code § 8387.