0 CITY OF VERNON PUBLIC UTILITIES
4305 S SANTA FE AVE.
VERNON, CALIFORNIA 90058
Version: 65.0
Effective Date: 6/18/2024 7/1/2025
Wildfire
Mitigation
Plan
1 Contents
Executive Summary ....................................................................................................................i Wildfire Safety Advisory Board Recommendations .............................................................i
1. Executive Summary...........................................................................................................1
2. Introduction.......................................................................................................................1
2.1. Policy Statement .........................................................................................................2
2.2. Organization of the Wildfire Mitigation Plan.............................................................2
2.3. City of Vernon..............................................................................................................2
2.4. Vernon Public Utilities Profile.....................................................................................3
2.5. Generation and Distribution Facilities........................................................................3
2.6. Wildfire Risk Assessment............................................................................................3
3. Objectives..........................................................................................................................4
4. Roles and Responsibilities ................................................................................................4
4.1. Wildfire Prevention .....................................................................................................4
4.2. Wildfire Response and Recovery................................................................................5
4.3. Standardized Emergency Management System........................................................5
5. Wildfire Risks and Drivers.................................................................................................6
5.1. Design, Construction, Operation, and Maintenance.................................................6
5.2. Topographic and Climatological Risk Factors ............................................................6
6. Enterprise-wide Safety Risks ............................................................................................6
7. Wildfire Preventative Strategies ......................................................................................7
8. Vegetation Management..................................................................................................7
9. Inspections ........................................................................................................................9
10. De-energization Protocols..............................................................................................10
10.1. Reclosing Policy .........................................................................................................10
10.2. De-energization.........................................................................................................10
11. Customer Notification Procedure ............................................................................. 1111
12. Restoration of Service.....................................................................................................11
13. Evaluation Metrics ..................................................................................................... 1313
13.1. Metrics and Assumptions for Measuring Plan Performance ............................. 1313
14. Impact of Metrics on Plan ......................................................................................... 1515
15. Monitoring and Auditing the Plan............................................................................. 1515 2 15.1. Identifying and Correcting Deficiencies in the Plan............................................ 1515
15.2. Monitoring the Effectiveness of Inspections...................................................... 1515
16. Independent Evaluator.............................................................................................. 1515
17. Acronym Glossary ...................................................................................................... 1616
APPENDIX
A. Independent Evaluation of Vernon Plan........................................................ 16 i
Reference Guide
Vernon Public Utilities (VPU) is dedicated to providing safe, reliable electric services to the residents and businesses in City of Vernon at competitive prices.
While VPU’s service territory and operations do not include or abut high wildfire threat areas, VPU remains committed to evaluating hazards that may affect the reliability and safety of the City of Vernon. This WMP describes the activities that VPU is taking to mitigate the threat of power-line ignited wildfires, including its various programs, policies and procedures. This plan will be reviewed and evaluated by its City Council on an annual basis.
Utility Overview and Context
The California Wildfire Safety Advisory Board (WSAB) issued the Guidance Advisory Opinion for the 2023 Wildfire Mitigation Plans of Electric Publicly Owned Utilities and Rural Electric Cooperatives (“2023 WSAB Guidance Advisory Opinion”) on November 16, 2022. VPU provides this document to the WSAB in order to respond to the recommendations included in the 2023 WSAB Guidance Advisory Opinion. VPU will provide a narrative response and/or a cross reference to the location in VPU’s Wildfire Mitigation Plan (WMP) where the topic is addressed.
Where the recommendation is not applicable to VPU, the response will provide a brief description supporting this conclusion.
Table 1: Context-Setting Information
Utility Name Vernon Public Utilities (VPU)
Service Territory Size 5.2 square miles
Owned Assets ☐ Transmission ☒Distribution ☒Generation
Number of Customers
Served
2,000 customer accounts
Population Within Service
Territory
150 222 people
Customer Class Makeup
Number of Accounts Share of Total Load (MWh)
4% Residential;
5% Government;
0% Agricultural;
64% Small/Medium Business,
Commercial;
26% Industrial
3% Residential;
5% Government;
0% Agricultural;
64% Small/Medium Business,
Commercial;
28% Industrial
Service Territory 0% Agriculture
0% Barren/Other
ii
Location/Topography1 0% Conifer Forest
0% Conifer Woodland
0% Desert
0% Hardwood Forest
0% Hardwood Woodland
0% Herbaceous
0% Shrub
100% Urban
0% Water
Service Territory
Wildland Urban Interface2
(based on total area)
0% Wildland Urban Interface;
0% Wildland Urban Intermix;
Percent of Service
Territory in CPUC High Fire
Threat Districts (based on
total area)
Tier 2: 0%
Tier 3: 0%
Prevailing Wind Directions
& Speeds by Season
The windier part of the year lasts for 6 months, from November to May, with average wind speeds of more than 6.9 miles per hour. The windiest day of the year is December 31, with an average hourly wind speed of 8.6 miles per hour.
The calmer time of year lasts for 6 months, from May to November. The calmest day of the year is August 10, with an average hourly wind speed of
5.3 miles per hour.
The wind is most often from the west for 5 months, from February to July, with a peak percentage of 47% on May 23. The wind is most often from the north for 4 months, from October to February, with a peak percentage of 36% on January 1.
Miles of Owned Lines
Underground and/or
Overhead
Overhead Dist.: 145 miles
Overhead Trans.: 0 miles
Underground Dist.: 31 miles
Underground Trans.: 0 miles
Explanatory Note 1 - Methodology for Measuring “Miles”: measured in line miles
Percent of Owned Lines in
CPUC High Fire Threat
Districts
Overhead Distribution Lines as % of Total Distribution System (Inside and Outside Service Territory)
Tier 2: 0%
Tier 3: 0%
Overhead Transmission Lines as % of Total Transmission System (Inside and Outside Service Territory)
Tier 2: 0%
Tier 3: 0%
1 This data shall be based on 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. 2 This data shall be based on 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.fed.us/nrs/pubs/rmap/rmap_nrs8.pdf.
iii
Customers have ever lost
service due to an IOU PSPS
event?
☐ Yes ☒No
Customers have ever been
notified of a potential loss
of service to due to a
forecasted IOU PSPS
event?
☐ Yes ☒No
Has developed protocols
to pre-emptively shut off
electricity in response to
elevated wildfire risks?
☐ Yes ☒No
Has previously preemptively shut off
electricity in response to
elevated wildfire risk?
☐ Yes ☒No
I. Cross Reference to Statutory requirements
WSAB requested that POUs provide a clear roadmap as to where each statutory requirement is addressed within the POU WMP.
Table 2: Cross References to Statutory Requirements
Requirement Statutory Language Location in
WMP
Persons
Responsible
PUC § 8387(b)(2)(A): An accounting of the responsibilities of persons responsible for executing the plan. Section 4
Objectives of
the Plan
PUC § 8387(b)(2)(B): The objectives of the wildfire mitigation plan. Section 3
Preventive
Strategies
PUC § 8387(b)(2)(C): A description of the preventive strategies and programs to be adopted by the local publicly owned
electric utility or electrical cooperative to minimize the risk of its electrical lines and equipment causing catastrophic wildfires, including consideration of dynamic climate change risks.
Section 7
Evaluation
Metrics
PUC § 8387(b)(2)(D): A description of the metrics the local publicly owned electric utility or electrical cooperative plans to use to evaluate the wildfire mitigation plan’s performance and the assumptions that underlie the use of those metrics.
Section 13
Impact of
Metrics
PUC § 8387(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.
Section 14
Deenergization
Protocols
PUC § 8387(b)(2)(F): Protocols for disabling reclosers and deenergizing portions of the electrical distribution system that consider the associated impacts on public safety, as well as protocols related to mitigating the public safety impacts of Section 10
iv
those protocols, including impacts on critical first responders and on health and communication infrastructure.
Customer
Notification
Procedures
PUC § 8387(b)(2)(G): Appropriate and feasible procedures for notifying a customer who may be impacted by the
deenergizing of electrical lines. The procedures shall consider the need to notify, as a priority, critical first responders, health care facilities, and operators of telecommunications
infrastructure.
Section 11
Vegetation
Management
PUC § 8387(b)(2)(H): Plans for vegetation management. Section 8 Inspections
PUC § 8387(b)(2)(I): Plans for inspections of the local publicly owned electric utility’s or electrical cooperative’s electrical infrastructure.
Section 9
Prioritization of
Wildfire Risks
PUC § 8387(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:
(i) Risks and risk drivers associated with design, construction, operation, and maintenance of the local publicly owned electric utility’s or electrical cooperative’s equipment and facilities. (ii) Particular risks and risk drivers associated with topographic and climatological risk factors throughout the different parts of the local publicly owned electric utility’s or electrical cooperative’s service territory.
Section 5
CPUC Fire
Threat Map
Adjustments
PUC § 8387(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.
Section 2.3
Section 2.6
Enterprisewide
Risks
PUC § 8387(b)(2)(L): A methodology for identifying and
presenting enterprisewide safety risk and wildfire-related risk. Section 6 Restoration of
Service
PUC § 8387(b)(2)(M): A statement of how the local publicly owned electric utility or electrical cooperative will restore service after a wildfire.
Section 12
Monitor and
Audit
PUC § 8387(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
(i) Monitor and audit the implementation of the wildfire mitigation plan.
(ii) Identify any deficiencies in the wildfire mitigation plan or its implementation, and correct those deficiencies.
Section 15
v
(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.
Qualified
Independent
Evaluator
PUC § 8387(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 Web site of the local publicly owned electric utility or electrical cooperative, and shall present the report at a public meeting of the local publicly owned electric utility’s or electrical cooperative’s governing board.
Section 16
II. WSAB Guidance Advisory Opinion Recommendations
Process for Utility Adoption and Submittal of Annual WMP and Opportunities for Public Comment:
VPU is governed by the Vernon City Council. Accordingly, the 2021 Vernon Public Utilities Wildfire Mitigation Plan was presented to the Vernon City Council on May 18, 2021, and was adopted in Resolution No. 2021-12. Subsequent annual updates and triennial comprehensive revisions shall be publicly presented and approved by minute order of the City Council.
Description of Where WMP Information Can be Found on Utility Website The Vernon Public Utilities Wildfire Mitigation Plan and the independent evaluator’s report will be posted to the City of Vernon’s website under regulatory reports3 and has been presented to Vernon’s City Council at a noticed public meeting.
3 https://www.cityofvernon.org/government/public-utilities/regulatory-reports VERNON WILDFIRE MITIGATION PLAN 20242025 Page 1
1. Executive Summary
1.1. The Vernon Public Utilities Wildfire Mitigation Plan meets applicable California Senate Bill 901, Assembly Bill 1054, and Assembly Bill 111 requirements.
1.2. The City of Vernon is an industrial city of 5.2 square miles, adjacent to Downtown Los Angeles. Wildfire ignition risks are low due to the sparsity of vegetation and fuel sources in Vernon’s industrial environment.
1.3. Vernon is located more than 10 miles from the nearest California Public Utilities Commission (CPUC) High Fire-Threat District Elevated risk area.
1.4. Vernon Public Utilities (VPU) does not own or operate transmission, distribution, or generation facilities in CPUC High Fire-Threat District.
1.5. VPU does not own or operate transmission, distribution, or generation facilities in California Department of Forestry and Fire Protection’s (CAL FIRE) Fire and Resource Assessment Program (FRAP) Fire Threat Map’s designated High or Extreme Wildfire Hazard areas.
1.6. VPU’s Wildfire Mitigation Plan includes required program components such as performance metrics, continuous improvement, and responsible parties.
1.7. VPU will make annual Wildfire Mitigation Plan progress updates to the Vernon City Council and the California Wildfire Safety Advisory Board.
2. Introduction
Over the last few years, California has seen some of its most devastating and destructive wildfires. Climate Change is recognized as a contributing factor (long hot spells, low moisture, etc.). In response, Senate Bill (SB) 901 authored by Senator Dodd, was enacted in 2018. SB 901 requires every electric utility to prepare a wildfire mitigation plan (WMP) and annually present the plan to its governing body. SB 901 amended Public Utilities Code (PUC) section 8387. Section 8387 generally requires every publicly owned utility to construct, maintain, and operate its electrical facilities to minimize the risk of wildfire posed by those facilities. As further required by Assembly Bill (AB) 1054 enacted in 2019, the WMP shall be submitted to the California Wildfire Safety Advisory Board for review and advisory opinion annually by July 1. At least once every three years, the submittal must be a comprehensive revision of the WMP.
This document outlines Vernon Public Utilities’ activities in accordance with these requirements.
VERNON WILDFIRE MITIGATION PLAN 20242025 Page 2
2.1. Policy Statement
Vernon Public Utilities' overarching goal is to provide safe, reliable, and economic electric service to its local community. In order to meet this goal, VPU constructs, maintains, and operates its electrical lines and equipment in a manner that minimizes the risk of catastrophic wildfire posed by its electrical lines and equipment.
2.2. Organization of the Wildfire Mitigation Plan
This Wildfire Mitigation Plan includes the following elements:
• Objectives of the plan;
• Roles and responsibilities for carrying out the plan; • Identification of key wildfire risks and risk drivers; • Description of wildfire prevention, mitigation, and response strategies and programs;
• Metrics for evaluating the performance of the plan and identifying areas for improvement; and
• Review and validation of the plan.
2.3. City of Vernon
The City of Vernon is an industrial city
of 5.2 square miles located several
miles to the southeast of Downtown
Los Angeles in Southern California. The
City’s business-friendly environment,
low-cost utilities, and proximity to
ports, trucking and rail transport make
Vernon an ideal location for industrial
uses.
The City of Vernon is located in a
region of Los Angeles County with low
wildfire risk. No part of VPU’s service
territory is located in or near the High
Fire-Threat District, designed in the
California Public Utilities Commission’s
(CPUC) Fire Threat Map. Further, all of
VPU’s service territory is excluded from
the High, Very High, and Extreme
Threat areas of the California Department of Forestry and Fire Protection’s (CAL FIRE) Fire and Resource Assessment Program (FRAP) Fire Threat Map. Based on a review of local VERNON WILDFIRE MITIGATION PLAN 20242025 Page 3
conditions and historical fires, the Vernon Fire Department has determined that VPU’s electrical lines and equipment do not pose a significant risk of wildfire.
Despite this low risk, VPU takes appropriate actions to help its region prevent and respond to the increasing risk of wildfires. In its role as a public agency, VPU closely coordinates with other local safety and emergency officials to help protect against fires and respond to emergencies. In its role as a utility, VPU follows all applicable design, construction, operation, and maintenance requirements that reduce safety risks associated with its system. This Wildfire Mitigation Plan describes the safety-related measures that Vernon Public Utilities follows to reduce its risk of causing wildfires.
2.4. Vernon Public Utilities Profile
Formerly known as Vernon Light and Power and Vernon Gas & Electric, the City of Vernon has consolidated all utility services within the VPU. VPU provides electric, water, natural gas, and fiber optic services.
VPU serves about 2,000 mainly commercial and industrial electric customers with electric sales of approximately 1,128 GWh annually, and peak loads of approximately 184 MW in the summer and 174 MW in the winter.
2.5. Generation and Distribution Facilities
VPU’s electric system includes generation and distribution facilities that are completely located within VPU’s electric service territory in the LA Basin. VPU does not own or operate any transmission facilities. VPU has two generation facilities that are located within VPU service territory. Malburg Generating Station (MGS), a 139 MW combinedcycle natural gas-fired plant and two H. Gonzales units, a combined 10 MW natural gas plant. VPU has 176 miles of distribution lines and 24 miles of 66 kV subtransmission lines.
No overhead distribution lines span over naturally vegetated open space areas.
Therefore, there is no potential for electrical equipment igniting a wildfire. The generation and distribution facilities are located entirely within the CAISO balancing area and are connected to the CAISO through the Southern California Edison (SCE) 220-66 kV Laguna Bell Substation. The Vernon load is supplied and supported by five 66 kV source lines that exit the SCE Laguna Bell 220/66 kV Substation. With the support of Vernon’s local generation, the VPU electric system reliability will most likely not be compromised under a double contingency (N-2) situation, where two 66 kV transmission lines are out of service.
2.6. Wildfire Risk Assessment
In 2018, Vernon Fire Department conducted a risk assessment of wildfires caused by VPU’s overhead electrical lines and equipment, in compliance with Senate Bill 1028 (Hill, 2016). VPU provides electric service to the City of Vernon within the greater Los Angeles VERNON WILDFIRE MITIGATION PLAN 20242025 Page 4
basin. Specifically, VPU's service area is not within or near any wildland-urban interface zones and more than ten miles from the nearest wildland-urban interface area. The assessment includes information from the US Forest Service’s Fire Modeling Institute, and the CAL FIRE Office of the State Fire Marshal. Also considered were Vernon’s historical fire data, geographical location, and local conditions. Based on this information, the determination was made that VPU’s electric equipment and operations do not pose a risk of igniting a fire that could cause any significant wildfire condition.
3. Objectives
The primary objectives of this Wildfire Mitigation Plan are to:
1. Describe VPU’s existing programs, practices, and measures that effectively reduce the probability that VPU’s electric supply system could be the origin or contributing source for the ignition of a wildfire.
To support this goal, VPU regularly evaluates the prudent and cost-effective improvements to its physical assets, operations, and training that can help reduce the risk of equipment-related fires.
2. The secondary objective of this Wildfire Mitigation Plan is to improve the resiliency of the electric grid. As part of the development of this plan, VPU assesses new industry practices and technologies that will reduce the likelihood of an interruption (frequency) in service and improve the restoration (duration) of service.
3. Create a WMP that is consistent with state law and objectives.
4. Roles and Responsibilities
4.1. Wildfire Prevention
VPU staff that have responsibility for wildfire prevention are:
General Manager: Assumes overall responsibility for VPU’s planning and mitigation activities, including maintaining compliance with state and federal safety and operating requirements.
Assistant General Manager: Responsible for emergency preparedness, emergency response, and coordinating recovery after a fire.
Utilities Operations Manager: Responsible for the reliable operation of VPU’s electric distribution system and safety protocols, including the evaluation and installation of new protective equipment to reduce fire risk. Maintain compliance with federal, state and VERNON WILDFIRE MITIGATION PLAN 20242025 Page 5
local fire management personnel to ensure that appropriate preventive measures are in place.
Electric Operations Supervisor: Is primarily responsible for ensuring inspections of electric lines, poles, and equipment, in addition to the performance of operations and maintenance (O&M).
While other individuals, such as linemen, have the responsibility to inspect and report any faulty operations of equipment, the primary responsibility for preventing electricalignited fires and coordinating recovery is the Utilities Operations Manager and Assistant General Manager.
4.2. Wildfire Response and Recovery
VPU is a member of the California Utility Emergency Association, which plays a key role in ensuring communications between utilities and with California Office of Emergency Services (CAL-OES) during emergencies. VPU also participates in the American Public Power Association (APPA) Mutual Assistance Agreement, which is a mutual assistance agreement covering municipal utilities across the United States.
4.3. Standardized Emergency Management System
As a local governmental agency,4 VPU has planning, communication, and coordination obligations pursuant to the California Office of Emergency Services’ Standardized Emergency Management System (SEMS) Regulations,5 adopted in accordance with Government Code section 8607. The SEMS Regulations specify roles, responsibilities, and structures of communications at five different levels: field response, local government, operational area, regional, and state.6 Pursuant to this structure, VPU annually coordinates and communicates with the relevant safety agencies as well as other relevant 4 As defined in Cal. Gov. Code § 8680.2.
5 19 CCR § 2407.
6 Cal. Gov. Code § 2403(b):
(1) “Field response level” commands emergency response personnel and resources to carry out tactical decisions and activities in direct response to an incident or threat. (2) “Local government level” manages and coordinates the overall emergency response and recovery activities within their jurisdiction.
(3) “Operational area level” manages and/or coordinates information, resources, and priorities among local governments within the operational area and serves as the coordination and communication link between the local government level and the regional level.
(4) “Regional level” manages and coordinates information and resources among operational areas within the mutual aid region designated pursuant to Government Code §8600 and between the operational areas and the state level. This level along with the state level coordinates overall state agency support for emergency response activities. (5) “State level” manages state resources in response to the emergency needs of the other levels, manages and coordinates mutual aid among the mutual aid regions and between the regional level and state level, and serves as the coordination and communication link with the federal disaster response system.
VERNON WILDFIRE MITIGATION PLAN 20242025 Page 6
local and state agencies. Pursuant to the SEMS structure, VPU participates in annual training exercises with the Vernon Disaster Council. The Council meets quarterly to discuss emergency management protocols, FEMA and SEMS procedures, and lessons learned from disasters around the world. On an annual basis, the City’s Emergency Operating Center is exercised by the Disaster Council as part of an Emergency Drill.
5. Wildfire Risks and Drivers
Pursuant to Public Utilities Code section 8387(b)(2), VPU has determined that it is not necessary to describe Wildfire Risks and Drivers in this Wildfire Mitigation Plan because of the unique characteristics of the service territory and operations of VPU, including lack of wildfire fuel sources, and distance from any designated elevated fire-threat areas.
5.1. Design, Construction, Operation, and Maintenance
Due to the minimal risk of VPU’s electrical supply facilities igniting a wildfire, VPU is not adopting wildfire specific protocols for Wildfire Risks and Drivers Associated with Design, Construction, Operation, and Maintenance. However, VPU meets or exceeds the minimum design and construction requirements provided in CPUC GO 95, which specifies that electric supply systems shall be designed, constructed, and maintained for their intended use with regard given to the conditions under which they are to be operated to enable the furnishing of safe, proper, and adequate service.
5.2. Topographic and Climatological Risk Factors
Due to the minimal risk of VPU’s electrical supply facilities igniting a wildfire, VPU is not adopting wildfire specific protocols for Wildfire Risks and Drivers Associated with Topographic and Climatological Risk Factors.
6. Enterprise-wide Safety Risks
Pursuant to Public Utilities Code section 8387(b)(2), VPU has determined that it is not necessary to describe Enterprise-wide Safety Risks in this Wildfire Mitigation Plan because of the unique characteristics of the service territory and operations of VPU, including lack of wildfire fuel sources, and distance from any designated elevated fire-threat areas.
VERNON WILDFIRE MITIGATION PLAN 20242025 Page 7
7. Wildfire Preventative
Strategies
Pursuant to Public Utilities Code section 8387(b)(2), VPU has determined that it is not necessary to describe Wildfire Preventative Strategies in this Wildfire Mitigation Plan because of the unique characteristics of the service territory and operations of VPU, including lack of wildfire fuel sources, and distance from any designated elevated firethreat areas.
High Fire-Threat District
In coordination with the California Municipal Utilities Association, VPU participated in the development of the CPUC’s Fire-Threat Map,7 which defines a statewide High Fire-Threat District (HFTD).
In the map development process, VPU reviewed the proposed boundaries of the High Fire-Threat District and confirmed that, based on local conditions and historical fire data, all of VPU’s service territory was properly excluded.
Design and Construction Standards
VPU’s electric facilities are designed and constructed to meet or exceed the relevant federal, state, or industry standard. VPU treats CPUC General Orders (GO) 95 and 128 as a key industry standard for design and construction standards for overhead and underground electrical facilities. VPU meets or exceeds all standards in GO 95 and GO 128. Additionally, VPU monitors and follows, as appropriate, the National Electric Safety Code.
8. Vegetation Management
Due to the industrial nature of the City of Vernon, there is very little risk of vegetation igniting a wildfire, or impeding Vernon Public Utilities’ services. VPU’s service territory neither contains nor is adjacent to any wildlands or elevate fire-threat areas and thus, there is no risk of igniting wildfires.
8.1. City of Vernon Urban Forest is comprised of approximately 1,200 trees, which are maintained and are pruned annually by a contracted Urban Forest Management 7 Adopted by CPUC Decision 17-12-024.
VERNON WILDFIRE MITIGATION PLAN 20242025 Page 8
Service company. Tree conditions are managed regularly in an asset management system, and routine maintenance occurs on an annual basis.
8.2. Substations require bare ground for the safe operation of high voltage equipment.
Electric Operators monitor substations, switchyards, and other electric facilities on a daily basis and remove invasive weeds and other vegetation as necessary. This may be accomplished by pulling the vegetation, pruning, or spraying with an herbicide such as glyphosate.
8.3. VPU meets or exceeds the minimum industry standard vegetation management practices. For distribution level facilities, VPU meets: (1) Public Resources Code section 4292; (2) Public Resources Code section 4293; (3) GO 95 Rule 35; and (4) the GO 95 Appendix E Guidelines to Rule 35. These standards require significantly increased clearances in the High Fire-Threat District. The recommended time-oftrim guidelines do not establish a mandatory standard, but instead, provide useful guidance to utilities.
GO 95, Rule 35, Table 1
Case Type of Clearance Trolley
Contact,
Feeder and
Span Wires,
0-5kv
Supply
Conductors
and Supply
Cables, 750 -
22,500 Volts
Supply
Conductors
and Supply
Cables, 22.5 -
300 kV
Supply
Conductors
and Supply
Cables, 300 -
550 kV (mm)
13 Radial clearance of
bare line conductors
from tree branches
or foliage
18 inches 18 inches ¼ Pin Spacing ½ Pin Spacing
14 Radial clearance of
bare line conductors
from vegetation in
the Fire-Threat
District
18 inches 48 inches 48 inches 120 inches
VERNON WILDFIRE MITIGATION PLAN 20242025 Page 9
Appendix E
Guidelines to Rule 35
The radial clearances shown below are recommended minimum clearancesthat should be established, at time of trimming, between the vegetation and the energized conductors and associated live parts where practicable. Reasonable vegetation management practices may make it advantageous for the purposes of public safety or service reliability to obtain greater clearances than those listed below to ensure compliance until the next scheduled maintenance. Each utility may determine and apply additional appropriate clearances beyond clearances listed below, which take into consideration various factors, including: line operating voltage, length of span, line sag, planned maintenance cycles, location of vegetation within the span, species type, experience with particular species, vegetation growth rate and characteristics, vegetation management standards and best practices, local climate, elevation, fire risk, and vegetation trimming requirements that are applicable to State Responsibility Area lands pursuant to Public Resource Code Sections 4102 and 4293.
Voltage of Lines Case 13 Case 14
Radial clearances for any conductor of a line
operating at 2,400 or more volts, but less than
72,000 volts
4 feet 12 feet
Radial clearances for any conductor of a line
operating at 72,000 or more volts, but less than
110,000 volts
6 feet 20 feet
Radial clearances for any conductor of a line
operating at 110,000 or more volts, but less
than 300,000 volts
10 feet 30 feet
Radial clearances for any conductor of a line
operating at 300,000 or more volts
15 feet 30 feet
9. Inspections
VPU meets or exceeds the minimum inspection requirements provided in CPUC GO 165 and CPUC GO 95, Rule 18. Pursuant to these rules, utilities inspect electric facilities in the High Fire-Threat District more frequently than the other areas of its service territory. As described above, VPU currently does not have any overhead powerlines located within, or near the High Fire-Threat District within the CPUC’s Fire-Threat Map but still maintains compliance with the inspection requirements as a best business practice. VPU performs intrusive pole inspections and has a pole replacement priority and schedule program to remove potential pole failure hazards, even though there is no significant native vegetation below VPU’s overhead distribution lines.
VERNON WILDFIRE MITIGATION PLAN 20242025 Page 10
VPU staff uses their knowledge of the specific environmental and geographical conditions of VPU’s service territory to determine if any particular areas require more frequent inspections.
If VPU staff discovers a facility in need of repair that is owned by an entity other than VPU, VPU will issue a notice of repair to the facility owner and work to ensure that necessary repairs are completed promptly.
In accordance with CPUC GO165, VPU annually reports and publicly posts its inspection data to its website under regulatory reports.8 Publicly posted information includes the number of patrols, detailed overhead and underground inspections, and instrusive inspections.
10. De-energization Protocols
10.1. Reclosing Policy
Due to the low wildfire threat in VPU’s service territory, VPU does not disable re-closers due to anticipated wildfires. VPU does not have a formal procedure identified for disabling re-closers. VPU will continue to assess the wildfire threat and will develop a procedure as needed.
10.2. De-energization
Electrical outages can adversely affect electrical system equipment, customer production and equipment, devices vital to public health and safety such as lighting, traffic signals, wells and chlorinators and can cause disruption to critical communication networks.
Due to Vernon’s low wildfire risk profile, VPU is not adopting wildfire specific protocols for de-energizing any portions of its electric distribution system. VPU will re-evaluate the need to pre-emptively shut off power due to fire-threat conditions in future updates to this Wildfire Mitigation Plan.
8 https://www.cityofvernon.org/government/public-utilities/regulatory-reports VERNON WILDFIRE MITIGATION PLAN 20242025 Page 11
11.Customer Notification
Procedure
While VPU has a low risk of igniting a wildfire, VPU and its customers may be subject to a wildfire threat to a major shared transmission line(s) that impacts the statewide grid or parts of it- creating a resource shortage for the utilities that rely on the resources the line(s) provides.
VPU proactively communicates to customers and key stakeholders through multiple channels about preparing for potential curtailments, and the power restoration process.
VPU recognizes that many entities and individuals are particularly vulnerable during extended power outages and makes every effort to provide up-to-date information to these populations prior to, during, and after an event.
VPU’s Customer Service Center, Key Accounts staff, social media and CityofVernon.org will provide ongoing and available resources for communication and education for the overall customer base.
Key stakeholders, federal, state, and local elected officials, City and County executive staff and first responders are also contacted via a variety of channels and personnel.
VPU has specific personnel assigned to elected officials and agencies, and to critical customers including water and telecommunications utilities, potentially affected by an outage to a major shared transmission line.
Any communications by VPU during an active emergency, such as wildfire, will be in accordance with California’s Standardized Emergency Management System (SEMS) and will be at the direction of the entity responsible for disseminating information about the emergency.
12. Restoration of Service
Due to Vernon’s low wildfire risk profile, VPU is not adopting wildfire specific protocols for restoration of service after de-energizing its electric distribution system.
General Steps to Restoration of Service are:
Patrol. VPU crews patrol the line to look for vegetation in lines and any obvious damage that may prevent safe energization.
VERNON WILDFIRE MITIGATION PLAN 20242025 Page 12
Repair. During patrol, crews look for potential damage to the lines and poles. Where equipment damage is found, additional crews are dispatched with new materials to repair or replace damaged equipment.
Test. Once the lines and poles are safe to operate, crews test the infrastructure by closing the fuse or breaker to re-energize the line segment.
Restore. Power is restored, and the outage communication system provides notification of power restoration to customers.
VERNON WILDFIRE MITIGATION PLAN 20242025 Page 13
13. Evaluation Metrics
This section provides the metrics used to measure the performance of the Plan and outlined programs.
13.1. Metrics and Assumptions for Measuring Plan
Performance
VPU will track three metrics to measure the performance of this Wildfire Mitigation Plan:
(1) number of fire ignitions; (2) wires down within the service territory; and (3) outage caused by trees.
Metric 1: Fire Ignitions
For purposes of this metric, a Fire Ignition is defined as follows:
• VPU facility was associated with the fire;
• The fire was self-propagating and of a material other than electrical and/or communication facilities;
• The resulting fire traveled greater than one linear meter from the ignition point; and • VPU has knowledge that the fire occurred.
In future Wildfire Mitigation Plans, VPU will provide the number of Fire Ignitions that occurred that were less than 5 acres in size. Any fires greater than 5 acres will be individually described.
YEAR Number of Fire Ignitions
2019 0
2020 0
2021 0
2022 0
2023 0
2024 0
Metric 2: Wires Down
The second metric is the number of distribution wires downed within VPU’s service territory. (VPU does not own or operate any transmission lines.) For purposes of this metric, a Wires Down event includes any instance where an electric primary distribution conductor falls to the ground, or on to a foreign object. As VPU does not own or operate VERNON WILDFIRE MITIGATION PLAN 20242025 Page 14
any transmission lines or own/operate distribution lines in the High Fire-Threat District, reporting of Wires Down is limited to local distribution outside of the High Fire-Threat District.
VPU will not normalize this metric by excluding unusual events, such as severe storms.
Instead, VPU will supplement this metric with a qualitative description of any such unusual events.
YEAR Number of Wires Down
2019 0
2020 0
2021 0
2022 0
2023 0
2024 2
Metric 3: Outage Caused by Trees
The third metric is the number of distribution outages caused by trees within VPU’s service territory. (VPU does not own or operate any transmission lines.) For purposes of this metric, a tree-related outage event includes any instance where service on an electric primary distribution circuit is interrupted by contact with a tree or vegetation. As VPU does not own or operate any transmission lines or own/operate distribution lines in the High Fire-Threat District, reporting of tree-related outages is limited to local distribution outside of the High Fire-Threat District.
VPU will not normalize this metric by excluding unusual events, such as severe storms.
Instead, VPU will supplement this metric with a qualitative description of any such unusual events.
YEAR Number of Tree Outages
2019 0
2020 0
2021 1
2022 0
2023 2
2024 0
VERNON WILDFIRE MITIGATION PLAN 20242025 Page 15
14. Impact of Metrics on Plan
Due to VPU’s extremely-low risk wildfire circumstances, VPU anticipates that there will be relatively limited data gathered through these metrics. However, as the data collection history increases, VPU will be able to identify if any areas of its operations and service territory are disproportionately impacted. VPU will then evaluate potential improvements in future updates to this Plan including the use of additional metrics.
15. Monitoring and Auditing
the Plan
This Wildfire Mitigation Plan will be reviewed annually and will include an assessment of the Plan programs and performance. Annual updates and triennial comprehensive revisions shall be publicly presented and approved by minute order of the City Council and adopted by resolution.
15.1. Identifying and Correcting Deficiencies in the Plan At any point in time, when deficiencies are identified, the Utilities Operations Manager or his/her delegates are responsible for correcting the deficiencies.
15.2. Monitoring the Effectiveness of Inspections
VPU’s Utilities Operations Manager will be responsible for monitoring and auditing the targets specified in the Plan to confirm that the objectives of the Plan are met.
16. Independent Evaluator
Public Utilities Code section 8387(c) requires VPU to contract with a qualified independent evaluator with experience in assessing the safe operation of electrical infrastructure to review and assess the comprehensiveness of this Wildfire Mitigation Plan. The independent evaluator must issue a report that is posted to the City of Vernon’s website. This report must also be presented to the Vernon City Council at a public meeting.
VPU participated in a public request for proposals, to identify the best qualified independent evaluator to assess the comprehensiveness of VPU’s Wildfire Mitigation VERNON WILDFIRE MITIGATION PLAN 20242025 Page 16
Plan. VPU contracted with Dudek & Associates, a qualified independent evaluator with experience in assessing the safe operation of electrical infrastructure. Dudek’s Independent Evaluation is attached in Appendix A of this Plan.
The independent evaluator’s report is posted to the City of Vernon’s website and has been presented to Vernon’s City Council at a noticed public meeting.
17. Acronym Glossary
AB (Assembly Bill)
CAISO (California Independent System Operation)
CAL FIRE (California Department of Forestry and Fire Protection) CPUC (California Public Utilities Commission)
CUEA (California Utilities Emergency Association)
ERM (Enterprise Risk Management)
FRAP (Fire Resource and Assessment Program)
GHG (Greenhouse gas)
GIS (Geographic Information System)
GO (General Order)
KV (Kilovolt)
KWH (Kilowatt Hours)
MW (Mega Watts)
O&M (Operations & Maintenance)
EOC (Emergency Operations Centers)
OES (Office of Emergency Services)
PUC (Public Utilities Code)
SB (Senate Bill)
SEMS (Standardized Emergency Management System)
SME (Subject Matter Expert)
T&D (Transmission and Distribution)
WMP (Wildfire Mitigation Plan)
VERNON WILDFIRE MITIGATION PLAN 20242025 Page 17
Appendix A: Independent
Evaluation of Vernon Plan