Attachment D
CALIFORNIA
OFFICE OF ENERGY INFRASTRUCTURE SAFETY
WILDFIRE SAFETY ADVISORY BOARD
WILDFIRE SAFETY ADVISORY BOARD-
PUBLICLY OWNED ELECTRIC UTILITIES
AND RURAL ELECTRIC COOPERATIVES
WILDFIRE MITIGATION PLAN WORKING
GROUP SUMMARY REPORT
APRIL 2024
TABLE OF CONTENTS
Introduction
1. Summary of Projects and Programs... in
2. Late WMP submissions. 5
3. Revision log.
4. Digital accessibility
5. Areas that exceed General Orders. 7
6. Independent Evaluator (IE) reports.... 8
7. Low wildfire-risk POU requirements... 8
8. Progress and achievements 9
9. QA/QC programs 9
10. Performance metrics 10
11. Other Topics. 11
Conclusion 12
Approval 13
Appendix 1 - Working Group Meeting Summaries.... 14
Appendix 2 - Sample Summary table..... 24
Appendix 3 - Revision Log (City of Lodi). 26
Appendix 4 - CMUA Template supplemental Letter for low-wildfire risk POUs 27 Appendix 5 - CMUA Performance Metrics Template 32
Appendix 6 - Updated Context Setting Template PSPS section 38
INTRODUCTION
1. Background
To minimize future devastating occurrences through risk-driven wildfire prevention, Public Utilities Code (P.U.C) § 8387(b)(2) requires publicly owned electric utilities and rural electrical cooperatives (collectively "POUs") to each annually prepare and adopt a wildfire mitigation plan (WMP). The POUs submit their WMPs by July 1 of each year to the Wildfire Safety Advisory Board (WSAB) which reviews them and issues recommendations.
The WAB issued its Advisory Opinion for the POU 2024 WMPs on December 4, 2023.* The WAB recommended that POUs and their representative bodies including the California Municipal Utilities Association (CMUA), the Northern California Power Agency (NCPA), the Southern California Public Power Authority (SCPPA) and the Golden State Power Cooperative (GSPC) (collectively " Joint Associations") participate in meetings or workshops as requested by the WAB, to engage with the WAB and to exchange information and ideas through discussions on topics including:
• POU progress and achievements;
• Performance metrics;
• QA/QC program;
• Independent Evaluator (IE) reports;
• Executive summaries;
• Late WMP submissions;
• Revision log:
• Digital accessibility; and
• Other items that come up during discussions.
The WAB organized six meetings with the POUs and the Joint Associations from January 19, 2024 to April 5, 2024 to discuss the topics. This report represents the WAB Staff's summary of the working group's discussions and outcomes and includes Staff's preliminary recommendations to the WAB on each of the topics from the meetings. The report also includes detailed summaries from each meeting in Appendix 1.
* California Wildfire Safety Advisory Board, "Advisory Opinion for the 2024 Wildfire Mitigation Plans of Electric Publicly Owned Utilities and Rural Electric Cooperatives" December 4, 2023, https://energvsafety.ca.gov/wp- content/uploads/2023/12//wsab-2024-wmp-pou-advisory-opinion.pdf.
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2. Working Group Attendees
There were no formal requirements to participate in this working group and attendance was open to all of the POUs, the Joint Associations, and the WAB. The regular attendees were as follows:
• WSAB:
• CMUA
• GSPC
• NCPA
• SCPPA
• Sacramento Municipal Utilities District (SMUD)
• Los Angeles Department of Water and Power (LADWP)
DRA
* From the WAB, the participants were Vice Chair Porter, Member Tim Haines, and the advisors Jonathan Frost and Sang Soble.
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DISCUSSION TOPICS
1. Summary of Projects and Programs
Preliminary Recommendation
• The POUs should include a standalone summary that includes all of the key targets and cost estimates for the reporting period by program categories (e.g., grid design and system hardening, community outreach and engagement), and accomplishments from the prior reporting period.
• Appendix 2 is a template that could be used, but other formats may be preferable. • The POUs may include this information in a table as an option.
Explanation
The WMPs document POU strategies and tactics to protect the public from utility caused wildfires. Central to understanding utility risk mitigation are the projects and programs that utilities have underway and have accomplished. The WAB finds that a summary of in- process and completed projects provides insight into the status of POU wildfire risk reduction.
2. Late WMP submissions
Preliminary Recommendation
• Ifa POU determines they will are likely to submit their WMP after the July 1 deadline, the POU should submit a justification letter to the docket or the WAB email ([email protected]) by the July 1 deadline, explaining the cause of the delay and the estimated time when they will be able to submit their WMP.
Explanation
POUs are required by P.U.C. 58387(b)(1) to submit their WMPs to the WAB by July 1" every calendar year. Historically, most of the POUs have complied with the statute but typically a small number do not. In 2023, approximately one-third of the POUs submitted late WMP filings, representing a significant increase in the number of late submissions. In order to mitigate this issue going forward and to improve the communication and when POUs anticipate that they might submit a late WMP filing, the WAB finds that this notification approach is both appropriate and reasonable.
WILDFIRE SAFETY ADVISORY BOARD-PUBLICLY OWNED ELECTRIC UTILITIES AND RURAL ELECTRIC COOPERATIVES WILDFIRE MITIGATION PLANS WORKING GROUP SUMMARY REPORT] WILDFIRE SAFETY ADVISORY BOARD 5
3. Revision log
Preliminary Recommendation
• The POUs should include a revision log to indicate the year-to-year updates made on their WMPs.
Explanation
Many of the sections in the POU WMPs do not change significantly on a year-to-year basis or between triennial WMP revisions. To help the reader understand the changes that have occurred and how the WMPs overall have evolved, some POUs have included a revision log.
An excellent and concise example can be seen in the City of Lodi's 2023 WMP which is included in Appendix 3 for reference.
4. Digital accessibility
Preliminary Recommendation
: The pous should Include hot links in the table of contents of their WMPs.
The POUs should conduct digital accessibility checks of their WMPs prior to submittal and follow the accessible content guidelines set out by the Department of Rehabilitation (DOR).
Explanation
Digital accessibility ensures that people with disabilities can access WMPs without barriers.
California Government Code § 11546.7 specifies that content including documents on the State of California's websites are accessible to all users regardless of their abilities or disabilities. In support of this objective, State entities, including the Office of Energy Infrastructure Safety (Energy Safety) and the WAB are encouraging stakeholders to review the accessibility requirements that the State adheres to and adopt these requirements if feasible.
The DOR has several helpful and publicly available resources on its website to improve the digital accessibility of documents. The WAB recommends that the POUs to seek out this information, as it will help improve the number of digitally accessible WMPs that are available on the WAB docket for all audiences. Furthermore, hot links in the table of contents allow readers to navigate more quickly through a WMP document. 6 WILDFIRE SAFETY ADVISORY BOARD-PUBLICLY OWNED ELECTRIC UTILITIES AND RURAL ELECTRIC COOPERATIVES WILDFIRE MITIGATION PLANS WORKING GROUP SUMMARY REPORT | WILDFIRE SAFETY ADVISORY BOARD
5. Areas that exceed General Orders
Preliminary Recommendation
• The POUs should include information in their WMPs about how their system design, construction and maintenance exceed the requirements set by the CPUC General Orders (G.O.s), which are the regulatory requirements that specify aspects such as the design, construction, maintenance, inspections and safety of electrical equipment owned and operated by electrical corporations in California. • They should describe their decision-making process that drove any decisions to exceed the G.O.s, experience implementing these decisions and observations to date (e.g. cost impacts, maintenance impacts, safety impacts, etc.) and any lessons learned.
• The WAB should engage with the G.O. 95/128 Rules Committee ("Rules Committee"), which is made up of investor-owned and publicly-owned electric utilities and associated labor unions from across California and considers state-of-the-art technologies and methods and changes to the CPUC G.O.s, to gain insight into the system design, construction, and maintenance requirements related to WAB recommendations on POUs WMPs.
Explanation
The G.O.s cover a range of topics including the design, construction, and maintenance of electric grids and specify technical standards and intervals for inspections. Electric grids that are designed, constructed and maintained per the requirements set in the CPUC G.O.s are generally safe and reliable. However, there are numerous areas where the G.O.s as written are insufficient to maintain safety, particularly in areas with high wildfire risk.
By providing information in their WMPs about how they choose to exceed the CPUC G.O.s, the POUs can provide insights into benefits and limits of industry practices that influence utility wildfire risk management.
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6. Independent Evaluator (IE) reports
Preliminary Recommendation
• The POUs should include in the independent evaluator (IE) report project scope an evaluation of WMP strategy and projects to provide recommendations for improvements for the overall plan and specific initiatives/projects.
Explanation
P.U.C 8387 (c) requires POUs to seek out an IE to assess the comprehensiveness of their WMPs. Relying on an independent evaluator to assure that an organization's risk management, governance and internal control processes are operating effectively is common practice in the utility sector.
7. Low wildfire-risk POU requirements
Preliminary Recommendation
• A POU determined to be low-wildfire risk that has no updates to its WMP can submit the same WMP together with a letter stating that the POU has low-wildfire risk, does not anticipate any changes to wildfire risks in its service territory in coming years, and has no update (or has a few simple updates) to its last WMP. See Appendix 4 for the CMUA's letter template.
• The low-wildfire risk POUs should regularly evaluate their wildfire risk and update the WMPs according.
Explanation
Some POUs have completely underground transmission and distribution assets, others have some overhead assets but also have service territories that are urban, agricultural, or are nowhere near the State's high wildfire threat areas. P.U.C. 8387(b)(1) requires POUs to submit WMPs every year, including POUs with low-wildfire risk and even if their risk profiles remain unchanged. Furthermore, they are subject to the same requirements for seeking out independent evaluations as the other utilities.
The WAB finds that the recommended approach for the low-wildfire risk POUs to submit a supplemental letter describing their low-wildfire risk and any updates with their base WMP is acceptable and would be helpful for the WAB and other stakeholders. The low-wildfire risk POUs taking this approach would still take public comment on their WMPs and submit them 8 WILDFIRE SAFETY ADVISORY BOARD-PUBLICLY OWNED ELECTRIC UTILITIES AND RURAL ELECTRIC COOPERATIVES WILDFIRE MITIGATION PLANS WORKING GROUP SUMMARY REPORT | WILDFIRE SAFETY ADVISORY BOARD to their governing boards and later submit them to the WAB docket along with the letter.
Short of changing the statute to exempt low-wildfire risk POUs from submitting WMPs and lE reports, allowing a low-risk POU to submit a supplemental letter describing the unchanged status of its WMP seems to be an acceptable compromise. It would be unreasonable to expect them to otherwise continue submitting new WMPs every year.
8. Progress and achievements
Preliminary Recommendation
• The POUs should highlight their progress and achievements to date in their WMP programs by including more detailed information in the WMP regarding project targets, and timelines and progress updates for each project in each subsequent WMP.
Explanation
Programs are often described in the WMPs at a high level and it can be difficult to understand the progress made to date, the risk reduction that has been achieved, the POU's targets for the end of the reporting period, or the overall goal of individual programs.
By providing this information about the progress and milestones of the WMP projects, it can help the reader better understand how projects are progressing each year, enhance transparency and accountability and put them into perspective of the POU's evolving risk landscape.
9. QA/QC programs
Preliminary Recommendation
• The POUs should provide descriptions of their QA/QC programs and the findings and lessons learned for inspection and maintenance programs in the WMP.
Explanation
P.U.C. §8387(b)(2)(N) requires the POU to describe the processes and procedures to monitor and audit the implementation of the WMP and the effectiveness of inspections including by third-party contractors. The POUs must also describe how they identify deficiencies and correct them. Work such as utility vegetation management (UVM) and asset inspections are performed by a mix of utility employees and contractors, often with contractors performing
WILDFIRE SAFETY ADVISORY BOARD-PUBLICLY OWNED ELECTRIC UTILITIES AND RURAL ELECTRIC COOPERATIVES WILDFIRE MITIGATION PLANS WORKING GROUP SUMMARY REPORT] WILDFIRE SAFETY ADVISORY BOARD 9 most of the work. Utilities develop QA/QC programs to ensure that the quality of UVM and asset inspections are consistent and meet standards.
By enhancing their reporting on QA/QC programs, the POUs can help readers better understand the processes used to systematically sample and audit their work, and the steps that they take to identify and correct issues.
10. Performance metrics
Preliminary Recommendation
• The WAB recommends the adoption of the CMUA's 2024 revised metrics template. It is expected that POUs will tailor the metrics to their unique circumstances.
Furthermore, the WAB recommends that the Context Setting Template include additional metrics for the impacts of PSPS events that are caused by third parties. See Appendix 5 for the CMUA Template and Appendix 6 for the updated section of the Context Setting Template.
Explanation
P.U.C. §8387(b)(2)(D) and 58387(b)(2)(E) require the POUs to include information describing how they use metrics in their WMPs and how these metrics from earlier plans have informed their plans. The statute does not specify the exact metrics to use, so the CMUA in its original 2020 POU WMP template suggested that the POUs include ignitions and wires down events.
Some POUs have expanded on those two to track and report on a variety of metrics. However, many have opted only to focus on those two metrics and even include them in their reports under circumstances where they would not make sense, such as including wires down in the WMP when the utility is completely underground.
This revised template provides a thorough baseline level of information on external risk factors, and the actions that the utility has taken to identify and address exogenous and endogenous risk factors. It also allows the POU to expand on the template to report on additional metrics that they track and provide context for certain events that have occurred.
Additionally, the modification to the Context Setting Template will help clarify the magnitude of impacts that the POUs face when they lose power due to a third-party PSPS event. 10 WILDFIRE SAFETY ADVISORY BOARD-PUBLICLY OWNED ELECTRIC UTILITIES AND RURAL ELECTRIC COOPERATIVES WILDFIRE MITIGATION PLANS WORKING GROUP SUMMARY REPORT | WILDFIRE SAFETY ADVISORY BOARD
11. Other Topics
Preliminary Recommendation
• The WAB recommends that POUs and the Joint Associations work with the WAB to refine the list of future topics and develop an action plan of activities that could include Board action.
Explanation
During the course of discussions leading to the above preliminary recommendations in 1-10 of this report, the WAB and POU representatives have raised other topics for future discussions. The Board's POU Committee is currently considering the forums to discuss these and other topics. They currently include:
• Communication company risks;
• Issues with U.S. Federal Agencies such as the U.S. Forest Service; • Inclusion of wildfire maps and the sharing of mapping data; • Reporting guidelines and template(s) for WMP updates for POUs other than the low- wildfire risk POUs; and
• Identification and sharing of wildfire management practices at the local, state, regional and federal levels.
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CONCLUSION
The WAB appreciates the engagement of its counterparts in this working group process to help refine the preliminary recommendations that it presents today and make them actionable through consultation with the broader POU community and development of templates and example letters for the POUs to use. The WAB looks forward to continuing its engagement with the POU community to further understand their challenges and perspectives and to appropriately lend its expertise.
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APPROVAL
The Electric Publicly Owned Utilities and Rural Electric Cooperatives Wildfire Mitigation Plans Working Group Summary Report was approved on June 5, 2024, and is hereby accepted by the Board.
Jessica Block, Chair
Christopher Porter, Vice Chair
Ralph M. Armstrong Jr., Board Member
Diane Fellman, Board Member
Timothy Haines, Board Member
John Mader, Board Member
Alexandra Syphard, Board Member
WILDFIRE SAFETY ADVISORY BOARD PUBLICLY OWNED ELECTRIC UTILITIES AND RURAL ELECTRIC COOPERATIVES WILDFIRE MITIGATION PLANS WORKING GROUP SUMMARY REPORT] WILDFIRE SAFETY ADVISORY BOARD 13 APPENDIX 1 - WORKING GROUP MEETING
SUMMARIES
January 19, 2024
This first WAB-POU WMP working group focused on (i) Executive summaries; (ii) Late WMP submissions; (ili) Revision log; (iv) Digital accessibility, and initial feedback on the WAB policy papers."
(i) Executive summaries: The meeting attendees discussed the WAB proposal to include information in the WMP Executive Summary that provides a high-level overview of the progress that utilities have made toward reducing wildfire risk in during the reporting period. For example, the section could summarize all of the key targets and cost estimates for the reporting period by program categories (e.g. grid design and system hardening, community outreach and engage), and accomplishments. During the discussion, it was noted that the WMPs are written with two audiences in mind: (a) the WAB and State government more broadly, and (b) the municipal governing boards and local communities/ratepayers. The executive summaries are often designed with the latter group in mind. Parties agreed to explore the option of an attachment or separate document for the WAB, a sort of "Summary for Policymakers" that would better support the WAB's ability to analyze the programs.
WSAB Preliminary Recommendation:
• The POUs should include a standalone executive summary or "summary for policymakers" that includes all of the key targets and cost estimates for the reporting period by program categories (e.g., grid design and system hardening, community outreach and engagement), and accomplishments from the prior reporting period.
" Feedback on policy papers: The 1/19 agenda was expanded for participants to provide high level feedback of the WAB policy paper drafts that were available for public comment. The POUs explained how they adopt the G.0.s and see themselves as subject to the CUC's standard of care and to CPUC safety audits. They described ongoing involvement with reviewing and providing periodic suggestions to the CPUC on the G.O.s through the Utility Rules Committee. Furthermore, they cautioned that the recommendations may not consider the 2014 and 2020 decisions from the recent CPUC G.0.95 proceedings and the decision from the 2017 utility pole proceeding focused on establishing a pole database.
Takeaways: the POUs see G.0.95 and G.O.128 as engineering standards that generally should remain stable.
Certain procedural aspects of the G.0.s 95 and 128 may be appropriate for change. Additionally, the PUC Section 326(a)(7) regulatory review process may need to be linked somehow with the Rules Committee, which is a group of utilities which convenes to discuss recommendations for the G.O.s. 14 WILDFIRE SAFETY ADVISORY BOARD-PUBLICLY OWNED ELECTRIC UTILITIES AND RURAL ELECTRIC COOPERATIVES WILDFIRE MITIGATION PLANS WORKING GROUP SUMMARY REPORT | WILDFIRE SAFETY ADVISORY BOARD • The POUs may include this information in a table as an option.
Post Meeting Update and Action Items:
• The POU Joint Associations discussed these options and the WAB's suggested program summary table with their members. The POU Joint Associations reported that their members are open to reporting summary information in a table format.
They noted that cost data can be hard to report as it is difficult to tie dollars to projects that serve dual purposes like undergrounding. Some POUs do this, but often not like the IOUs.
(ii) Late WMP Submissions: Public Utilities Code Section 8387 (b)(1) requires POUs to submit WMPs annually to the WAB by July 1st. Though most POUs comply with the filing date, there are exceptions. 2023 may have been an aberration in terms of the large number of late submissions. Some POUs experienced staff change which may have driven some of the late submissions. The WAB proposed that POUs which anticipate delays could file an explanation to the docket for the late submission and share public drafts, if available, to the docket in the interim.
WSAB Preliminary Recommendation:
• The POUs should submit a justification letter to the docket or the WAB email ([email protected]) by the July 1 deadline, explaining the cause of the delay and the estimated time when they would be able to submit their WMPs.
Post Meeting Update and Action Items:
• The POU Joint Associations discussed these potential steps for late filings with their members and they reported back to the working group that the request for a notice to the WAB was a reasonable request.
• In April the Joint Associations plan to identify single points of contact for each POU and check if they anticipate any delays in submitting their WMPs. • The WAB will also put a guide on their website to help make the docketing process easier.
(iii) Revision Log: WAB shared the example of the City of Lodi's revision log.
WAB Preliminary Recommendation
• The POUs should include a revision log to indicate the year-to-year updates made on their WMPs.
Post Meeting Update and Action Items:
WILDFIRE SAFETY ADVISORY BOARD PUBLICLY OWNED ELECTRIC UTILITIES AND RURAL ELECTRIC COOPERATIVES WILDFIRE MITIGATION PLANS WORKING GROUP SUMMARY REPORT] WILDFIRE SAFETY ADVISORY BOARD 15 • The POU Joint Associations shared the sample with their members and reported back to the working group that they received positive feedback from the members on this and are working on a template.
(iv) Digital Accessibility: The WAB expressed an interest in WMPs being accessible to people with disabilities, It shared digital accessibility resources from the CA Department of Rehabilitation (DOR).
WAB Preliminary Recommendation
• The POUs should include hot links in the table of contents of their WMPs. • The POUs should conduct digital accessibility checks of their WMPs prior to submittal and follow the accessible content guidelines set out by the Department of Rehabilitation.
Post Meeting Update and Action Items:
• The POU Joint Associations shared the resources from the DOR with their members and asked if a training from the DOR on digital accessibility would be possible.
• WSAB Staff will inquire about a training on digital accessibility for the POUs.
Takeaways:
• Meeting every other Friday works well generally for everyone in the group. It allows the POU Joint Associations time to meet with their members and the POU wildfire mitigation working group to discuss proposals from this WAB-POU working group. • The group will need to return to issues after the POU Joint Associations have had the opportunity to discuss them with their members.
February 2, 2024
This second WAB-POU WMP working group focused on (i) Independent Evaluator (IE) Reports; (ii) Reporting of Progress and Achievements; (iii) Areas that Exceed the CPUC General Orders (G.O.s); and (iv) Low-Wildfire Risk POUs. The working group also reviewed updates from the previous meeting's agenda.*
(i) IE Reports: The meeting attendees discussed how the POUs could most effectively fulfill the requirements under Public Utilities Code Section 8387(c) for the POUs to contract with independent evaluators to review their WMPs. The WAB Staff * The POU Joint Associations provided brief updates on the topics of (i) Executive summaries; (il) Late WMP submissions; (iii) Revision log; and (iv) Digital accessibility. See the January 19 summary document for more information.
16 WILDFIRE SAFETY ADVISORY BOARD-PUBLICLY OWNED ELECTRIC UTILITIES AND RURAL ELECTRIC COOPERATIVES WILDFIRE MITIGATION PLANS WORKING GROUP SUMMARY REPORT | WILDFIRE SAFETY ADVISORY BOARD highlighted the example of the lE reports that were prepared for Truckee-Donner and Burbank and inquired if other POU IE reports could have a similar evaluation of specific initiatives/projects with recommendations for improvement. The attendees acknowledged that there are varying levels of quality and cost among the IE services available and some questioned the value of potentially expensive lE contracts for WMPs that see little to know change or for POUs with no wildfire risk.
WAB Preliminary Recommendation
• The POUs should include in the lE report project scope an evaluation of WMP strategy and projects to provide recommendations for improvements for the overall plan and specific initiatives/projects.
Post Meeting Update and Action Items:
• There were no specific action items or updates on this item during the following 2/15 meeting.
(ii) Reporting on Progress and Achievements: The group discussed the WAB's recommendation to include details on the progress and achievements for specific programs, including timelines, targets and progress updates. The POU Joint Associations and SMUD explained why this is not necessarily a straightforward task as numeric targets are not always used, some work is ongoing (like vegetation management and inspections), and some programs fit dual purposes. The group agreed that further discussion will likely be needed on this topic.
WSAB Preliminary Recommendation
• The POUs should highlight their progress and achievements to date in their WMP programs by including more detailed information in the WMP regarding project targets, and timelines and progress updates for each project in the following WMPs.
Post Meeting Update and Action Items:
• The POU Joint Associations reported during the 2/15 meeting that they are looking for an example and noted that this information is mostly in narrative form right now.
(iii) Areas where the POUs exceed the CPUC G.O.s: The WAB mentioned its statutory mandate per Public Utilities Code Section 326(a)(7) to consider new and amended utility regulations in light of the dynamic risks of climate change and wildfires The WSAB expressed how it is interested in learning from various examples from the POUs
WILDFIRE SAFETY ADVISORY BOARD-PUBLICLY OWNED ELECTRIC UTILITIES AND RURAL ELECTRIC COOPERATIVES WILDFIRE MITIGATION PLANS WORKING GROUP SUMMARY REPORT] WILDFIRE SAFETY ADVISORY BOARD 17 exceeding the G.O.s and their lessons learned from implementing these designs or protocols that might be appropriate for wider spread adoption. CMUA suggested that it might make sense to include more information about the decision-making process for when POUs decide to implement designs or protocols that exceed the minimum G.O. standards and provide more examples.
WSAB Preliminary Recommendation
• The POUs should include information in their WMPs about how their system design, construction and maintenance exceed the requirements set by the CPUC G.O.s.
• They should describe their decision-making process that drove these changes, experience implementing these changes and observations to date (e.g. cost impacts, maintenance impacts, safety impacts, etc.) and any lessons learned.
Post Meeting Update and Action Items:
• The POU Joint Associations reported to the working group in the 2/15 meeting that they did not find any examples where the POUs consistently exceeded the G.O.s. They acknowledged that the WMPs could probably provide better explanations for when the minimum G.O. requirements are exceeded. They recommended that the WAB get in touch with the Utility Rules Committee and offered to look into contacts.
(iv) Low-Wildfire Risk POUs: The working group discussed the WAB's proposal for having low-wildfire risk POUs submit their same WMPs with a letter explaining that they do not have any wildfire risk and do not have any updates to the WMPs. The group did not spend time discussing the exact characteristics that would define a low- wildfire risk POU, who would make the determination or if there was a more appropriate term that could be applied to these POUs.
WAB Preliminary Recommendation
A POU that is determined to be low-wildfire risk that has no updates to its WMP should be able to submit the same WMP with a letter stating that the POU has low-wildfire risk, does not anticipate any changes to wildfire risks in its service territory in coming years, and has no update (or has few simple updates) to its last WMP.
• The low-wildfire risk POUs should regularly evaluate their wildfire risk and update the WMPs according.
18 WILDFIRE SAFETY ADVISORY BOARD-PUBLICLY OWNED ELECTRIC UTILITIES AND RURAL ELECTRIC COOPERATIVES WILDFIRE MITIGATION PLANS WORKING GROUP SUMMARY REPORT | WILDFIRE SAFETY ADVISORY BOARD Post Meeting Update and Action Items:
• The POU Joint Associations developed a letter template and shared it with their members, who are still considering the letter.
Takeaways:
• Local conditions may justify exceeding minimum G.O. requirements. For instance, the presence of fast-growing plant species may justify exceeding minimum vegetation clearance distances. Basing broad recommendations for regulatory changes on the local conditions specific to one or a few utilities could be problematic and potentially lead to an unreasonable burden to the utilities and their ratepayers.
February 15, 2024
This third WAB-POU WMP working group focused on the reporting of quality assurance and quality control (QA/QC) protocols in the WMPs. The working group also reviewed updates from the previous meeting's agenda.
The working group discussed the WAB preliminary recommendation that the POUs provide descriptions of their QA/QC programs, the findings, and lessons learned for inspection and maintenance programs in the WMP. Representatives of LADWP, SMUD and the POU Joint Associations described the variation in how contractors are used among the POUs, the hiring and payment of them, safety training/briefing provided to contractors, and how POU employees oversee and evaluate/review contractor work. Some POUs may have policy documents describing QA/QC protocols. The WAB Staff requested that the POUs provide such documents as attachments to the WMPs for reference. Board Member Tim Haines raised the example of SMUD's description of its QA/QC programs in Section 9.2 of its 2023 WMP highlighting the continual review and learning process involved. He encouraged the working group to consider how lessons learned from the QA/QC programs could be reported out in the WMPs.
Action Items:
• The POU Joint Associations suggested that providing a narrative description of the QA/QC protocols in the WMP would be helpful and would check with their members about this.
* The POU Joint Associations provided brief updates on the topics of (i) Independent Evaluator Reports; (i) Reporting of Progress and Achievements; (il) Areas where the POUs exceed the CPUC General Orders; and (iv) Low Wildfire Risk POUs. See the February 2 summary document for more information.
WILDFIRE SAFETY ADVISORY BOARD-PUBLICLY OWNED ELECTRIC UTILITIES AND RURAL ELECTRIC COOPERATIVES WILDFIRE MITIGATION PLANS WORKING GROUP SUMMARY REPORT] WILDFIRE SAFETY ADVISORY BOARD 19 Takeaways:
• The use of contractor work varies among the POUs as well as the QA/QC protocols to ensure that the work is completed safely and satisfactorily.
March 8, 2024
This fourth WAB-POU WMP working group focused on WMP performance metrics. There was no specific WAB preliminary recommendation going into this meeting. The working group also reviewed updates from topics from previous meetings.® The working group discussed WMP performance metrics at a high-level, what could be achieved by enhancing the metrics, and how they can be part of a broader risk-informed decision-making framework. The POU Joint Associations explained that the two metrics in the 2020 CMUA WMP template (ignitions and wires down events) were never intended as a minimum standard. They recognized that there needed to be an appropriate balance of metrics, a separate template for low-risk POUs, and that they needed to separate out irrelevant statistics such as winter storm-related outages or statistics outside of the HFTD.
They also acknowledged how it can be challenging to report on upgrades done on the system that may also enhance wildfire risk reduction. SMUD emphasized the importance of providing context to the metrics. They also raised concern over potentially duplicative reporting of PSPS information between the context setting table and the metrics. Energy Safety Staff provided additional perspective with how the metrics should be able to help isolate performance (risk reduction) and how they can be used as to further risk-informed decision- making by the POUs.
Action Items:
• WAB Staff circulated the WAB and Energy Safety Metrics Templates. • CMUA circulated the draft CMUA POU WMP metrics template.
Inkeaways:
• There are clear challenges to translating underlying objectives of identifying external and internal risk factors and the utilities' actions to reduce these risks them into a robust set of metrics that would be suitable for a majority of the POUs. However, the process of preparing and understanding this information can help describe the * The POU Joint Associations provided a brief update on the topics of reporting on QA/QC program and areas where the utility exceeds the G.O.s. The POU internal working group discussed the example of SMUD's QA/QC reporting and LADWP's description of exceeding the G.O.s in certain areas, but nothing was agreed upon. See the meeting summary documents from February 15 and February 5 for more information. 20 WILDFIRE SAFETY ADVISORY BOARD-PUBLICLY OWNED ELECTRIC UTILITIES AND RURAL ELECTRIC COOPERATIVES WILDFIRE MITIGATION PLANS WORKING GROUP SUMMARY REPORT | WILDFIRE SAFETY ADVISORY BOARD evolving risk landscape and support the POUs' risk-informed decision-making frameworks.
March 15, 2024
This fifth SAB-POU WMP working group focused on reviewing and providing feedback on the CMUA draft POU WMP metrics template. The WAB provided two templates as well for reference in advance of the meeting but did not explicitly recommend either for adoption.? The working group discussed the components of the CMUA WMP metrics template. CMUA explained that the template they developed considered the examples in the WAB and Energy Safety templates and allows for flexibility to the POU to add any additional data and/or context beyond the items that are in the template. They mentioned that there was some uneasiness among the POUs for setting a baseline set of metrics. They also emphasized that the POUs may adopt the metrics differently depending on how they track and report their data. The WAB Staff highlighted that the Table 3 Outcome Metrics, while helpful in separating out different types of events, does not identify events that occur during fire season (which differs depending on the area. Furthermore, Staff noted that it could be helpful to also separate out equipment failures from the category of "other". The Joint Associations mentioned in response that additional thinking would be needed. The group revisited the matter of PSPS reporting and WAB Staff asked if it would be possible to include additional information in the context setting template about the impact of third-party PSPS events specifically. The Working Group did not reach an agreement on that during the meeting.
Action Items:
• The CMUA will circulate any updated version of the metrics template and any low-risk POU version with the Working Group.
• The WAB needs to evaluate final versions of both in order to arrive at a preliminary recommendation on the metrics.
• The Working Group will revisit the issue of low-risk POUs during the next meeting.
Takeaways:
• There is expected to be variation in how the POUs will take the new CMUA metrics template and expand upon it and/or add additional context to their reported data. *The WAB shared the template from Energy Safety that is used for collecting metrics from the investor-owned electrical corporations and the WAB's template which was developed based on inputs from both the POUs' and electrical corporations' metrics.
WILDFIRE SAFETY ADVISORY BOARD-PUBLICLY OWNED ELECTRIC UTILITIES AND RURAL ELECTRIC COOPERATIVES WILDFIRE MITIGATION PLANS WORKING GROUP SUMMARY REPORT] WILDFIRE SAFETY ADVISORY BOARD 21 April 5, 2024
This sixth WAB-POU WMP working group focused on reviewing and providing feedback on (i) the CMUA draft template for a letter for low-wildfire risk POUs, (ii) revisited the topic of performance metrics and began discussing (ili) issues appropriate for a separate discussion track (Track 2) distinct from the WMP-specific topics that had been initially scoped out for the working group.
(i) Low-wildfire risk POUs: the working group discussed the CMUA's template for a supplemental letter that low-wildfire risk POUs would be able to submit with their base WMP to comply with Public Utilities Code Section 8387 which requires the POUs to submit WMPs by July 1" each year. The low-wildfire risk POUs taking this approach would still take public comment on their WMPs and submit them to their governing boards and later submit them to the WAB docket along with the letter.
The CMUA suggested that an Attachment C to the letter with the Base WMP might make sense.
(ii) Performance Metrics: The CMUA noted that some of the POUs were concerned about overhauling their existing reporting structure to fit to the template. The CMUA told them that the POUs did not need to do this if it was not feasible. The working group agreed. SMUD also mentioned that they and likely many of the other POUs have already drafted their WMPs and it would be unlikely that they would adopt the new performance metrics template until 2025. (ill) Track 2 Issues: the working group briefly discussed some of the feedback from the POUs on some of the known coordination issues with communications companies.
The group agreed that it would be beneficial to have the subject matter experts from the POUs available to have a more robust discussion on this topic and for issues working with U.S. federal agencies. The group also brought up the idea of having separate, truncated reporting guidelines/template(s) for WMP updates (i.e. non-base year plans) for POUs with fire risk. Additionally, the group began discussing the inclusion of POU maps in the WMPs and the sharing of mapping data with the WAB. All these topics will require further consideration. The WAB only offered the specific preliminary recommendation for the POUs to include maps of their service territory to illustrate their wildfire risk. While not mentioned during the meeting, the City of Anaheim on page 21 of their WMP provides a useful * These issues deemed appropriate were either broader than the WMPs or were WMP-related issues that were not initially scoped out among the original working group topics. These matters include coordination with U.S. federal agencies such as the U.S. Forest Service, coordination with communications providers, reporting requirements/template(s) for WMP updates for POUs with wildfire risk, reporting of POU maps and the sharing of map data, and wildfire mitigation practices that may be suitable for wider use. 22 WILDFIRE SAFETY ADVISORY BOARD-PUBLICLY OWNED ELECTRIC UTILITIES AND RURAL ELECTRIC COOPERATIVES WILDFIRE MITIGATION PLANS WORKING GROUP SUMMARY REPORT | WILDFIRE SAFETY ADVISORY BOARD example for consideration." The WAB also encouraged the POUs to provide GIS files with their service territory boundaries and any data that they think can assist the WSAB with its review of the POUs' risk. For the other topics, the WAB did not have a preliminary recommendation but expressed interest in better understanding the issues, what roles the WAB could have in relation to them and what opportunities there might be to broaden the discussion and engage other stakeholders.
Action Items:
• The WAB will check with their Legal if they think that the letter template could allow low-wildfire risk POUs to comply with P.U.C 98387. • The POU side needs to re-evaluate the metrics template to see if they can focus on events that occur during wildfire season (as declared by CAL FIRE).
Takeaways:
Many of the POUs have already finalized their draft WMPs for this year and would not be able to incorporate the proposed changes such as the metrics template or the low-risk POU letter template into the WMPs until 2025.
* City of Anaheim Public Utilities Department, "2023 Wildfire Mitigation Plan," June 13, 2023, https://anaheim.net/DocumentCenter/View/49082/2023-Wildifire-Mitigation-Plan.
WILDFIRE SAFETY ADVISORY BOARD-PUBLICLY OWNED ELECTRIC UTILITIES AND RURAL ELECTRIC COOPERATIVES WILDFIRE MITIGATION PLANS WORKING GROUP SUMMARY REPORT] WILDFIRE SAFETY ADVISORY BOARD APPENDIX 2 - SAMPLE SUMMARY TABLE
Sample Summary Table
Grid Design, Current Reporting Period Goals:
Operations and • 5 miles of undergrounding - SXX million Maintenance
• 30 wood-to-steel pole replacement - SX million
• 80 miles of covered conductor - 5X million
Prior Reporting Period Accomplishments:
• 35 miles of underaroundina - SXX million
• 100 miles of covered conductor - SX million
Iotals prolected by end of reporting period:
• 100 underground circuit miles (700 pre-WMP efforts
ISXXX million, if known). 250 undergrounded since
2019 - SXXX million. 50 forecasted 2026-2028 - SXX
millionl
• 200 miles of covered conductor (1920 installed 2019-
2022 - SXX million, 100 miles forecosted 2026-2028 -
SXX million)
Vegetation Current Reporting Period Goals:
Management and • 200 circuit miles of patrol inspections - SX million Inspections
• 20 intrusive pole inspections - SX thousand
• 200 miles of vegetation management - SX million
Prior Reporting Period Accomplishments:
• 35 miles of undergrounding - SXX million
• 100 miles of covered conductor - SX million
Situational Awareness Current Reporting Period Goals:
and Forecasting • 10 weather stations - SXXXXX
• 10 cameras - $XXXXX
• 5 new inspection drones - SXXXXX
Prior Reporting Period Accomplishments:
• 5 weather stations added - $XXXXX
• 3 cameras installed - $XXXXX
Iotals prolected by end of reporting period;
24 WILDFIRE SAFETY ADVISORY BOARD-PUBLICLY OWNED ELECTRIC UTILITIES AND RURAL ELECTRIC COOPERATIVES WILDFIRE MITIGATION PLANS WORKING GROUP SUMMARY REPORT | WILDFIRE SAFETY ADVISORY BOARD • 30 weather stations (5 pre-WMP efforts (SXXXXX. II
knownl. 17 added since 2019 - SXXXXX, 8 forecasted
2026-2028 - SXXXXXI
• 20 cameras (10.2019-2022 - SXXXXX, 10 forecast 2026-
2028 - SXXXXX]
Emergency Current Reporting Period Goals;
Preparedness • Ltable too exercise
Prior Reporting Period Accomplishments:
• _table top exercise
Community Outreach Current Reportina Period Goals:
and Engagement • 3 customer emergency alert tests
4 community wildlite safety meeting
or Reportina Perod Accomishments
• 3 customer emeraency alert tests
• 4 community wildfire safety meetings
WILDFIRE SAFETY ADVISORY BOARD-PUBLICLY OWNED ELECTRIC UTILITIES AND RURAL ELECTRIC COOPERATIVES WILDFIRE MITIGATION PLANS WORKING GROUP SUMMARY REPORT] WILDFIRE SAFETY ADVISORY BOARD 25 APPENDIX 3 - REVISION LOG (CITY OF LODI)
REVISION LOG, KEY CHANGES
Date Location Description
12/7/2020 Sec. III C: Updated with current staffing levels E: Updated infrastructure status
Sec. IV.B Eliminated redundant map
Sec. V C: Updated with latest vegetation crew information and adding tree-inventory.
D: Added details of in-progress tree inventory
Sec. Vi Replaced projected progress with dates of council presentations and other events which have since occurred
Sec. V.G Expanded list with additional de-energization consequences Replaced planned Audit with actual Audit dates and findings Sec. IX and other updates subsequent to prior year's plan Sec. VIll Updated metrics
11/30/2021 Sec ID Created new sub.sec. "Risk Profile" & consolidated related info Sec. VIll Updated all metrics. Clarified reporting dates for metrics Sec. V.F Updated Reclosing section to include trial device 11/2/2022 Sec. VIlI A Updated metrics for last one year. 7/17/2023 Sec, VIII A Updated metrics.
26 WILDFIRE SAFETY ADVISORY BOARD-PUBLICLY OWNED ELECTRIC UTILITIES AND RURAL ELECTRIC COOPERATIVES WILDFIRE MITIGATION PLANS WORKING GROUP SUMMARY REPORT | WILDFIRE SAFETY ADVISORY BOARD APPENDIX 4 - CMUA TEMPLATE SUPPLEMENTAL
LETTER FOR LOW-WILDFIRE RISK POUS
[POU Letterhead]
XXXXXX XX. 2025
Re: Notice of Public Meeting on [POU] Wildfire Mitigation Plan Dear Wildfire Safety Advisory Board
This letter notifies the Wildfire Safety Advisory Board ("WSAB") that on , 2025. [POU| ("[POU|") presented its existing Wildfire Mitigation Plan ("WMP") to its (Governing Board/City Council] at a publicly noticed meeting, in accordance with Public Utilities Code section 8387(b). [POU]'s WMP was most recently adopted on _ 2024. At the , 2025 meeting, [POU] provided an opportunity for public comment on its existing WMP and [POU]'s Governing Board/City Council] verified that [POU]'s existing WMP complies with all applicable rules, regulations, and standards, as appropriate. [POU] does not have any overhead electric supply facilities located in or near an area of the state that is designed as "extreme" or "elevated" in the California Public Utilities Commission's High Fire Threat District Map. In consideration of this historical wildfire risk, [POU) has determined that its existing WMP adequately addresses the risk of a utility-caused, catastrophic wildfire occurring in [POU]'s service territory and that no substantive changes are merited for this reporting year. [POU] will continue to evaluate its existing WMP in relation to the wildfire risk posed by [POU]'s system on an annual basis.
In order to provide the WAB with information on (POU]'s system and WMP performance, please find as Attachment A, an updated Informational Table, and Attachment B, an updated Metrics Table.
[POU] thanks the WAB for their review and support in helping to mitigate wildfire risks in California.
Sincerely,
(Signature]
WILDFIRE SAFETY ADVISORY BOARD-PUBLICLY OWNED ELECTRIC UTILITIES AND RURAL ELECTRIC COOPERATIVES WILDFIRE MITIGATION PLANS WORKING GROUP SUMMARY REPORT] WILDFIRE SAFETY ADVISORY BOARD 27 Attachment A
[POU] 2025 Informational Table
28 WILDFIRE SAFETY ADVISORY BOARD-PUBLICLY OWNED ELECTRIC UTILITIES AND RURAL ELECTRIC COOPERATIVES WILDFIRE MITIGATION PLANS WORKING GROUP SUMMARY REPORT | WILDFIRE SAFETY ADVISORY BOARD [Insert Informational Table]
WILDFIRE SAFETY ADVISORY BOARD-PUBLICLY OWNED ELECTRIC UTILITIES AND RURAL ELECTRIC COOPERATIVES WILDFIRE MITIGATION PLANS WORKING GROUP SUMMARY REPORT] WILDFIRE SAFETY ADVISORY BOARD 29 Attachment B
[POU] 2025 Metrics Table
30 WILDFIRE SAFETY ADVISORY BOARD-PUBLICLY OWNED ELECTRIC UTILITIES AND RURAL ELECTRIC COOPERATIVES WILDFIRE MITIGATION PLANS WORKING GROUP SUMMARY REPORT | WILDFIRE SAFETY ADVISORY BOARD WMP Metrics
Performance Metrics
(Actual) (Actual)| (Forecast) | (Forecast) | (Forecasts Metrich pe Prostess metric name 2021 2022 2021 2024 2025 Unitel Comments
1. Above-Ground, Utlity-Owned Routine Inspections
Simpections
Distribution System Components
2. Distribution Inspections Patrol Inspections # circuit miles (Delere for fully undergrounded POUl Detailed Inspections # circuit miles Routine Vesetation Management I cecult miles
3. Transmission Inspections Patrol Inspections cecult miles (Deiete for fully undergrounded Poul Detailed Inspections # dircuit miles Routine Vegetatien Management & circuit miles
Outcome Metrics
(Actual) (Actuat) (Actuall (Actual) (To Date)
Event Caterory Cause category 2019 2020 2021 2022 2023 Unitisi Comments Outage Event Distribution #outages
Transmistion Boutates
Ignitions* Distribution * ignitions
Transmission Bienitions
(level 1) Safety Hazards** & harards
Distribution
discovered
(Note: rename based in highest level # hatards
Transmistion
tracked! discovered
Notes:
" An "ignition" is deemed to occur if each of the following conditions is met: (1) a utilty cured or controlled facility was associated with the fine; (2) the fire was self propagating and of a material other than electrical and for communication facities; (3) the resulting fire traveled greater than one linear meter from the ignition point; and (4) the utility has knowledge that the fire occurred.
** A [level 1) Safety Hazard is defined as
WILDFIRE SAFETY ADVISORY BOARD-PUBLICLY OWNED ELECTRIC UTILITIES AND RURAL ELECTRIC COOPERATIVES WILDFIRE MITIGATION PLANS WORKING GROUP SUMMARY REPORT WILDFIRE SAFETY ADVISORY BOARD 131
APPENDIX 5 - CMUA PERFORMANCE METRICS TEMPLATE
This document was developed by the CMUA Wildfire
Preparedness Recovery and Response Working Group and is intended is for general information only and is not offered or intended as legal advice. This document does not reflect minimum or mandatory elements for a wildfire mitigation plan, C CMUA nor does this document reflect industry standards or best practices. Readers should seek the advice of an attorney when CALIFORNIA MUNICIPAL UTILITIES confronted with legal issues and attorneys should perform an ASSOCIATION independent evaluation of the issues raised in this document.
Wildfire Working Group
Potential Metrics for Consideration in POU WMPs
April 16, 2024
*NOTE: this is a discussion draft and is subject to change* 32 WILDFIRE SAFETY ADVISORY BOARD-PUBLICLY OWNED ELECTRIC UTILITIES AND RURAL ELECTRIC COOPERATIVES WILDFIRE MITIGATION PLANS WORKING GROUP SUMMARY REPORT | WILDFIRE SAFETY ADVISORY BOARD
Introduction
This document is intended to provide a useful example for publicly owned electric utilities (POUs) and Electric Cooperatives (Co-ops) to consider when updating the metrics tracked in their WMPs. Each POU and Co-op is encouraged to adapt these tables as appropriate for their unique circumstances. Tables 1-4 are intended to be considered together, with each table covering a different category of metric. Tables 2 and 3 have alternate versions that remove the the High Fire Threat District (HFTD) columns. Table 5 is intended for use by a POU or Co-op with no overhead facilities in or near the HFTD.
Description of Tables
Table 1: External Risk Metrics - This table includes metrics that track the relative risks that impact the utility that are outside the control of the utility, such as red flag days, high wind events.
Table 2: Performance Metrics - Leading metrics that describe actions that are intended to reduce the risk of utility caused wildfires, such as inspections and routine vegetation management.
Table 3: Outcome Metrics - Lagging metrics that measure outcomes that may be associated with an increased risk of utility-caused wildfires, such as ignitions and outages.
Table 4: Planned Upgrade Metrics - This is an optional table for POUs or Co-ops that are implementing a new wildfire mitigation measure. This table will provide information on the planned rollout of the new measure.
WILDFIRE SAFETY ADVISORY BOARD-PUBLICLY OWNED ELECTRIC UTILITIES AND RURAL ELECTRIC COOPERATIVES WILDFIRE MITIGATION PLANS WORKING GROUP SUMMARY REPORT WILDFIRE SAFETY ADVISORY BOARD 33
Table 1: External Risk Metrics
Metric type External Risk Event 2021 2022 2023 Unit(e) Comments
1. Red Flag Warnings Red Flags Warning Days* for Weather Zone that includes Utility Service Territory
#Days
2. Wind Conditions High Wind Warning Days* in Weather Zone that Includes Utility Service Territory
#Days
3. [Other Relevant Weather [Other relevant weather pattern metrics tracked| Metric]
Notes:
* Red Flag Warnings and High Wind Warnings are declared by the National Weather Service 34 WILDFIRE SAFETY ADVISORY BOARD PUBLICLY OWNED ELECTRIC UTILITIES AND RURAL ELECTRIC COOPERATIVES WILDFIRE MITIGATION PLANS WORKING GROUP SUMMARY REPORT | WILDFIRE SAFETY ADVISORY BOARD
Table 2: Performance Metrics
2021 2022 2023
Metric type Progress metric name in HFTD In HFTD In HFTD Unites) comment
1. Distribution Patrol Inspections Performed # circuit
Inspection miles
Detailed Inspections Performed I circult
miles
Routine Vegetation Management Performed if circult
miles
2. Patrol Inspections Performed # circuit
Transmission miles
Inspections
Derailed Inspections Performed # circult
miles
Routine Vegetation Management Performed # circult
miles
Notes:
WILDFIRE SAFETY ADVISORY BOARD-PUBLICLY OWNED ELECTRIC UTILITIES AND RURAL ELECTRIC COOPERATIVES WILDFIRE MITIGATION PLANS WORKING GROUP SUMMARY REPORT WILDFIRE SAFETY ADVISORY BOARD 35
Table 3: Outcome Metrics
Event Category 2021 2022 2023
In HITD Units) Commens
In HFTO during during Fire In MFTD during
Fire Season* Season* Fire Season*
Outare Event - Distribution Vegetation caused - Distribution # outages Other- Distribution # outages
Unknows- Distribution #outages
Outage Event - Transmission Vegetation caused - Transmission # outages Ocher- Transmission # outages
Unknown- Transmission # outages
Ignitions** Distribution Vegetation caused - Distribution # ignitions Other- Distribution # ignitions
Unknown- Distribution # ignitions
Ignitions** Transmission Vegetation caused - Transmission • ignitions Other- Transmission # ignitions
Unknown- Transmission # ignitions
Safety Hazards - Distribution*** Level 1 • hazards dincovered Safety Hazards - Transmission*** Level 1 # hazards discovered Vegetation Management Offcycle Treatment - Distribution # poles (No Outage/Ignition) Defcycle Treatment - Transmission #poles Notes:
• "Fire Season" is defined as the period from [May 1) until CAL FIRE declares an end for the season in a given area, If the given area is outside of CAL FIRE jurisdiction, then the POU should defer to federal or local fire suppression authorities to determine the end of fire season. ** An "ignition" is deemed to occur if each of the following conditions is met: (1) a utility owned or controlled facility was associated with the fire; (2) the fire was self. propagating and of a material other than electrical and/or communication facilities; (3) the resulting fire traveled greater than one linear meter from the ignition point; and (4) the utility has knowledge that the fire occurred.
•** A Level 1 Safety Hazard is defined as [Note: Rename or add categories to align with existing utility practices] 36 WILDFIRE SAFETY ADVISORY BOARD-PUBLICLY OWNED ELECTRIC UTILITIES AND RURAL ELECTRIC COOPERATIVES WILDFIRE MITIGATION PLANS WORKING GROUP SUMMARY REPORT | WILDFIRE SAFETY ADVISORY BOARD
Table 4: Planned Mitigation Measures
Mitigation Measure Measure Description 2024 2025 2026 2027 2028 Unit(s) Comments
1. [Planned Mitigation [Description of measure, [unit]
Measurel including targeted location]
WILDFIRE SAFETY ADVISORY BOARD PUBLICLY OWNED ELECTRIC UTILITIES AND RURAL ELECTRIC COOPERATIES WILDFIRE MITIGATION PLANS WORKING GROUP SUMMARY REPORT WILDFIRE SAFETY ADVISORY BOARD 37
APPENDIX 6 - UPDATED CONTEXT SETTING
TEMPLATE PSPS SECTION
(See redline for new recommended addition)
• Yes • No
If yes, then provide the following data for calendar vear / l:
Customers have ever lost
service due to an IOU
PSPS event? Number of shut-off events: [
Customer Accounts that lost service for >10 minutes: [
For prior response, average duration before service restored: L Customers have ever • Yes • No
been notified of a
potential loss of service
to due to a forecasted
IOU PSPS event?
Has developed protocols • Yes • No
to pre-emptively shut off
electricity in response to
elevated wildfire risks?
• Yes • No
If yes, then provide the following data for calendar year ]:
Has previously pre-
emptively shut off
electricity in response to Number of shut-off events: [__] elevated wildfire risk?
Customer Accounts that lost service for ≥10 minutes: L/ For prior response, average duration before service restored: L WILDFIRE SAFETY ADVISORY BOARD. PUBLICLY OWNED ELECTRIC UTILITIES AND RURAL ELECTRIC COOPERATIVES WILDFIRE MITIGATION PLANS WORKING GROUP SUMMARY REPORT | WILDFIRE SAFETY ADVISORY BOARD
CALIFORNIA OFFICE OF ENERGY INFRASTRUCTURE SAFETY CALFORNIA
CALIFORNIA WILDFIRE SAFETY ADVISORY BOARD
www.energysafety.ca.gov
715 P Street
20** Floor
Sacramento, CA 95814
wsab@energysafety ca gov