Summary of Proposed Decisions for 2019 Wildfire Mitigation Plans (R.18-10-007)

The CPUC’s Rulemaking 18-10-007 implements the provision of Senate Bill (SB) 901 that requires electrical corporations under the CPUC’s jurisdiction to submit annual Wildfire Mitigation Plans (WMPs).

On February 6, 2019, WMPs were submitted by Pacific Gas and Electric Company (PG&E), Southern California Edison (SCE), San Diego Gas & Electric (SDG&E), PacifiCorp, Bear Valley Electric Service (Bear Valley), Liberty Utilities (Liberty), and two independent transmission owners – TransBay Cable and Horizon West Transmission.

On April 29, 2019, CPUC Administrative Law Judges (ALJs) issued for CPUC Commissioner consideration a series of six Proposed Decisions addressing these WMPs, finding that each filer’s WMP contains the required statutory elements, and requiring follow-up for this years’ WMPs and more work for future WMPs.

At the CPUC’s May 30, 2019 Voting Meeting, the six Proposed Decisions were voted upon and approved by the Commission.  Below is a brief high-level summary of each of the Decisions:

Guidance Decision (D.19-05-036)

D.19-05-036 DOC  | D.19-05-036 PDF

  • Addresses issues that are common to all of the Wildfire Mitigation Plans and applies to the Wildfire Mitigation Plans of all electrical corporations that filed plans. Specifically, it interprets SB 901; describes the procedural background of the proceeding; orders all electrical corporations to collect data and file reports on this year’s Wildfire Mitigation Plans; initiates a process to establish “metrics” to evaluate the WMPs, and makes clear that these metrics should focus on the success of mitigation at lowering the risk of catastrophic wildfires and not simply the number of trees removed or wires replaced; and creates a process for next year’s WMPs.
  • Authorizes the Commission’s Safety and Enforcement Division to convene one or more workshops for the purpose of initiating the 2020 WMP process and developing metrics to evaluate this year’s Plans.
  • Finds that approval of the WMP does not determine whether, at the time a filer seeks recovery for the costs of carrying out its plan, the filer acted as a prudent manager of its system.
  • Finds that approval of a WMP is not dispositive of a filer’s ultimate cost recovery for the operations and maintenance costs of hardening its system, managing vegetation, increasing situational awareness, and taking the other steps to mitigate wildfire risk.
  • Requires that all WMPs filers must assess their programs using metrics focused on outcomes (i.e., whether the mitigation reduces the risk of its electrical lines and equipment causing a catastrophic wildfire) rather than “program targets” (e.g., number of trees cut or miles of covered conductor installed).
  • Requires all IOUs to conduct community outreach and public awareness before, during, and after a wildfire in English, Spanish, Chinese (including Cantonese, Mandarin, and other Chinese languages), Tagalog, and Vietnamese as required by Public Utilities Code Section 8386(c)(16)(B), in addition to Korean and Russian where prevalent.
  • Does not act upon PG&E’s second amended plan filed April 25, 2019.   The second amended plan will be examined in Phase 2 of this proceeding.
  • Does not resolve several electrical corporations’ request for interim rate relief.

PG&E Decision (D.19-05-037)

D.19-05-037 DOC | D.19-05-037 PDF

Does not act upon PG&E’s second amended plan filed April 25, 2019.   The second amended plan will be examined in Phase 2 of this proceeding.

Determines that PG&E includes all statutorily required elements in its WMP, but requires follow-up on several matters, including the following:

  • Metrics to measure how various mitigation measures reduce risk of catastrophic wildfires, and whether system hardening will achieve the same efficiencies used alone as when used in combination with other mitigation measures such as vegetation management.
  • Summary of the results of the detailed inspections PG&E conducts in the High Fire-Threat District Tier 2 and 3 areas (the highest risk areas on the CPUC Fire Map) of its service territory to allow assessment of whether the fire mitigation measures proposed in the WMP are properly directed or need adjustment.
  • Analysis of pole materials to inform why the utility recommends non-wood materials for distribution versus transmission structures, and why and in what circumstances these materials are superior to wood poles.
  • Analysis of data to determine whether PG&E’s new vegetation-pole clearances have contributed to reduced ignitions, especially during critical weather conditions.
  • Requires the opinion of a certified arborist and evidence of risk to utility electric facilities under wildfire ignition conditions in order to remove healthy trees.
  • PG&E’s efforts to partner with local departments of public works to develop skilled labor and other resources and address the resource constraints it alleges.
  • Whether other mitigations could reduce the need for Public Safety Power Shutoffs or PSPS (also known as de-energization).
  • Additional information on how PG&E intends to share information with first responders and other stakeholders, including providing information in real-time during potential or actual emergency events.
  • Detail of how the utility disseminated wildfire information during the previous WMP cycle, the effectiveness of the communications and information-sharing, complaints or concerns expressed about the utility’s communication and information-sharing, and what measures PG&E will take in the upcoming planning year to address any unanswered questions.

SCE Decision (D.19-05-038)

D.19-05-038 DOC | D.19-05-038 PDF

Determines that SCE includes all statutorily required elements in its WMP, but requires action in 2019 and future plans, including the following:

  • A process for bringing SCE’s “High Fire Risk Areas” into conformity with the CPUC’s High Fire-Threat District area maps, or more detail on why SCE should not be required to do so.
  • Explanation of the Enhanced Overhead Inspection program to ensure SCE’s enhanced program does not simply consist of drive-by patrols.
  • Verification that SCE’s covered conductor and vegetation management programs will occur in the CPUC-adopted “High Fire-Threat Districts” during this 2019 WMP cycle.
  • Discussion of how SCE’s enhanced inspection and maintenance activities, including Light Detection and Ranging (LiDAR), will target distribution lines and not only transmission lines.
  • SCE must inform local communities and residents of its vegetation management plans, especially when it plans large scale vegetation work in a heavily forested area.
  • Requires the opinion of a certified arborist and evidence of risk to utility electric facilities under wildfire ignition conditions in order to remove healthy trees.
  • In future WMPs, discuss the strengths and weaknesses of its emergency preparedness, outreach, and response program as SCE engages with stakeholders during this upcoming fire season.

SDG&E Decision (D.19-05-039)

D.19-05-039 DOC | D.19-05-039 PDF

Determines that SDG&E includes all statutorily required elements in its WMP, and imposes additional requirements, including:

  • SDG&E’s next WMP must include a summary of the results of the detailed inspections it conducts in the High Fire Threat District Tier 3 area of its service territory.
  • SDG&E may proceed with its proposed Fire Risk Mitigation plan to replace wood poles with steel poles in 2019, but must continue to assess the best materials to use for poles in High Fire-Threat District areas. In future WMPs, SDG&E must document that its selections for pole replacements are reasonable.   Ingress and egress impacts should be considered in the assessment of pole material selection.
  • Requires work with manufacturers to accelerate the production of new poles and covered conductors and conduct quality control on the production of this equipment.
  • Allows 25-foot post-trim clearance where necessary and feasible if supported by scientific evidence or data showing that such clearance will reduce wildfire risk, but requires SDG&E to propose detailed guidelines for where a 25-foot post-trim clearance for vegetation management is both feasible and necessary in next year’s plan.

Small and Multi-Jurisdictional (SMJUs) Utilities Decision (D.19-05-040)

D.19-05-040 DOC  | D.19-05-040 PDF

Determines that the WMPs of PacifiCorp, Bear Valley, and Liberty each contain the statutorily required elements, and imposes additional requirements on each company, including:

  • Requires Liberty Utilities to track additional data: number of elevated fire danger days in its territory, using indicators from the National Fire Danger Rating System or the National Weather Service’s Red Flag Warnings, along with the number and types of potential ignition events; wire-down events and fault data, including data for previously unreported ignitions, and if applicable, where the investigating fire agency determined utility facilities to be the cause of ignition.
  • Requires Bear Valley Electric Service to report additional data including faults and ignitions on dry days; deploy situational awareness such as cameras across its service territory and work with  CAL FIRE  to site the cameras and share camera information
  • Requires PacifiCorp in future WMPs to assess the relative effectiveness of any system hardening activities to determine how best to prioritize these activities; discuss its efforts to coordinate its evacuation planning for isolated communities in its service territory with the appropriate agencies; conduct outreach in languages other than English; and gather and report fire incident data on “wires down” and fault events.

Independent Transmission Operators (ITOs) Decision (D.19-05-041)

D.19-05-041 DOC  | D.19-05-041 PDF

  • Determines that the WMPs of Transbay Cable and Horizon West Transmission substantially comply with the SB 901 WMP requirements, taking into account the fact that the ITOs are transmission-only utilities with limited infrastructure whose rates and cost recovery are regulated exclusively by the Federal Energy Regulatory Commission.