The audit covered 13 vegetation management initiatives in six programmatic areas of PG&E’s 2024 WMP. Energy Safety found that PG&E completed 12 of 13 vegetation management initiatives for 2024. Energy Safety has identified one outstanding initiative deficiency within PG&E’s vegetation management program regarding wood and slash management. PG&E has acknowledged this deficiency and has implemented a plan for corrective action.

Energy Safety’s assessment of TBC found that it did not have any WMP initiative work planned for 2024 in its 2023-2025 Base WMP and therefore, had no proposed budget. However, TBC spent $35,800 to install a fire suppression system in its spare parts building that was a carry-over expense from its 2023 WMP work. Also, the independent evaluator (IE) assigned relatively low scores to TBC’s quality assurance quality control program maturity, a clear indication that TBC must mature these programs moving forward.

Energy Safety’s assessment of LS Power found three of four of its 2024 initiative targets activities completed in its 2023-2025 Base WMP. LS Power failed to meet its target for one of its 2024 WMP initiative activities to install cameras at both its Orchard and Fern substation sites. Only the Orchard site had camera installations completed in 2024. LS Power also spent below its proposed amount, for initiatives applicable to 2024, by approximately $26,000 (88% of its proposed budget). LS Power explained that actual expenditures deviated from its proposed expenditures for various reasons, including emergency preparedness activities that required less resources than had been forecasted.

Energy Safety will monitor TBC’s and LS Power’s progress and expects improvement for both moving forward,

Liberty Utilities has been unable to satisfactorily demonstrate how it can identify and mitigate wildfire risk across its system effectively. Liberty must develop a wildfire mitigation plan that can be approved by prioritizing plan initiatives that reduce that risk, correct the deficiencies in their WMP, and resubmit a new plan.

Energy Safety has identified a series of steps Liberty should take to ensure that their WMP may ultimately be approved. It’s expected that Liberty will submit a new plan later in 2026.

Energy Safety found that SCE has made year-over-year improvements in achieving 12 of its 13 vegetation management initiatives for 2024. However, Energy Safety did identify one outstanding deficiency in open work orders. SCE has acknowledged this deficiency and has either planned or initiated implementation of corrective actions for it to be addressed.

An electrical corporation must demonstrate completion of seven statutory requirements to be eligible for a certificate. An electrical corporation with a certificate is presumed to have acted reasonably in proceedings before the CPUC to recover costs from a utility-caused wildfire unless demonstrated otherwise.

A certificate does not protect or shield an electrical corporation from liability, nor does it constitute an affirmation by Energy Safety that an electrical corporation has taken all possible steps to prevent its equipment from causing wildfire or is in full compliance with its wildfire mitigation plan or other laws and requirements.

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PacifiCorp is making an important advancement by implementing the first version of its investment planning model. This will enable PacifiCorp to identify the assets most at-risk from wildfires, assess the cost efficiency of its grid hardening activities, and map its High Fire Risk Areas. Additionally, PacifiCorp is running power simulation models on de-energized transmission lines to learn of its induction risk and mitigations for coupled transmission lines. While PacifiCorp took the initiative to evaluate induction risk, Energy Safety has required an induction risk assessment of all the electrical corporations in their WMPs. PacifiCorp has established risk remediation timelines for its vegetation management efforts, that if followed, will reduce wildfire risk.

There are areas where PacificCorp needs to improve that include prioritizing mitigations based upon an understanding of all risks. Further, PacifiCorp must overcome its grid hardening management challenges so risk reduction may be realized. Additionally, PacifiCorp must complete implementation of its enhanced safety settings to maximize the potential of the program. Progress in all these areas must be demonstrated in PacificCorp’s future WMPs.

The audit covered 13 vegetation management initiatives in six programmatic areas of SDG&E’s 2024 WMP. Energy Safety’s audit concluded that SDG&E successfully achieved the objectives of 10 of its vegetation management initiatives within its 2024 WMP. However, Energy Safety identified deficiencies in three initiatives (wood and slash management, substation defensible space, and open work orders) that SDG&E did not successfully implement. SDG&E has acknowledged these deficiencies and has planned for or initiated implementation of corrective actions to address them.

In its 2026-2028 Base WMP, SCE is continuing to evaluate circuits to reduce PSPS risk and has conducted new analyses to target more circuits. SCE also improved its grid hardening and vegetation management strategies and leads in Rapid Earth Fault Current Limiter (REFCL) deployment and asset inspections. SCE is reducing wildfire risk in high wind conditions through three types of remediation to reduce conductor clashing on its long spans. SCE is also mitigating the risk of aging assets by identifying spans and splices that could cause outages.  

There are areas where SCE must improve including the refinement of its risk models and how SCE calculates risk variables. These improvements include greater explanation about SCE’s line removal activities in areas with the highest fire threat, particularly for lines that are de-energized but could come into contact with energized lines, detail into certain types of its fast curve settings, better coordination with Bear Valley Electric Service on an interconnected power line infrastructure, and more proactive pole inspections and activity tracking. 

In its 2026-2028 Base WMP, Liberty Utilities has been unable to satisfactorily demonstrate how it can identify and mitigate wildfire risk across its system effectively. Liberty must develop a wildfire mitigation plan that can be approved by prioritizing plan initiatives that reduce that risk, correct the deficiencies in their WMP, and resubmit a new plan. 

Energy Safety has identified a series of steps Liberty should take to ensure that their WMP may ultimately be approved. It’s expected that Liberty will submit a new plan later in 2026. 

Energy Safety’s initial audit found that BVES was deficient in providing documentation for completed work in seven of 13 vegetation management initiatives (vegetation management Inspections, pole clearing, clearance, high-risk species, quality assurance and quality control, open work orders, workforce planning). However, in its corrective action plan, BVES provided additional data, clarifications, and corrective actions to address the seven deficient vegetation management initiatives. In addition, BVES demonstrated that all 13 vegetation management initiatives from its 2023-2025 WMP were implemented successfully for program year 2024 and no further action is necessary.