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Agenda Report - November 20, 2019 C-25
AGENDA ITEM c-25 CIry op Lour C ouNcrr, C otvtMUNIcATIoN .IM AGENDA TITLE: MEETING DATE: PREPARED BY: Adopt Resolution Authorizing Lodi Electric Utility's 2019 Wildfire Mitigation Plan November 20,2019 Electric Utility Director RECOMMENDED ACTION Adopt a resolution authorizing Lodi Electric Utility's 2019 Wildfire Mitigation Plan. BACKGROUND INFORMATION ln September 2018, the State of California enacted SB 901, requiring municipal electric utilities to create a Wildfire Mitigation Plan (WMP) and submit it to the state by January 1, 2020, and annually thereafter. Since SB-901's passage, Lodi Electric Utility (LEU) solicited input from multiple entities and stakeholders, authored a draft-WMP and made it available for public comments. On October 15,2019 Staff provided City Council an overview of SB-901 and its numerous requirements, along with salient features of LEU's draft inauguralWMP. Under SB-901, an independent third-party auditor is required to review the plan. Per Council approval, Navigant Consulting, lnc. (Navigant) was used to conduct this review. Navigant recently concluded their review (report attached) and determined that LEU's 2019 WMP is both comprehensive and in compliance with SB-901. Staff has finalized work on the 2019 WMP and respectfully submits it to Councilfor approval FISCAL IMPAGT:Not applicable Not applicableFUNDING AVAILABLE PREPARED BY: Tim Conn, Electrical Engineer STTAìtPIAÊ Foe X44 B¿¡rk4'¿iv*rtr- 1{AÉ^N) Jeff Berkheimer Electric Utility Director APPROVED Stephen , City Manager LODI ELECTRIC UTILITY WILDFIRE MITIGATION PLAN VERSION 1.0 October 30, 2019 TABLE OF CONTENTS I. Overview ............................................................................................................................................. 4 A. Policy Statement ............................................................................................................................... 4 B. Purpose of the Wildfire Mitigation Plan .......................................................................................... 4 C. Background ........................................................................................................................................ 5 D. Organization of the Wildfire Mitigation Plan ................................................................................. 6 II. Objectives of the Wildfire Mitigation Plan ...................................................................................... 6 III. Roles and Responsibilities ................................................................................................................. 7 A. Utility Governance Structure ........................................................................................................... 7 B. Wildfire Prevention ............................................................................................................................ 8 C. Wildfire Response and Recovery .................................................................................................... 9 D. Coordination with Water Utility and Public Safety ..................................................................... 11 E. Coordination with Communication Infrastructure Providers .................................................... 12 F. Standardized Emergency Management System ....................................................................... 12 IV. Wildfire Risks and Drivers Associated with Design, Construction, Operation, and Maintenance ............................................................................................................................................... 13 A. Particular Risks and Risk Drivers Associated with Topographic and Climatological Risk Factors ....................................................................................................................................................... 13 B. Enterprisewide Safety Risks ............................................................................................................. 14 C. Changes to CPUC Fire Threat Map .............................................................................................. 16 V. Wildfire Preventative Strategies ..................................................................................................... 17 A. High Fire Threat District .................................................................................................................... 17 B. Weather Monitoring ........................................................................................................................ 17 C. Design and Construction Standards ............................................................................................ 18 D. Vegetation Management ............................................................................................................. 19 E. System Maintenance and Inspections ........................................................................................ 21 F. Reclosing Policy ............................................................................................................................... 23 G. De-energization ............................................................................................................................... 23 VI. Community Outreach and Public Awareness ............................................................................ 25 VII. Restoration of Service ..................................................................................................................... 25 VIII. Evaluation of the Plan ..................................................................................................................... 26 A. Metrics and Assumptions For Measuring Plan Performance .................................................... 26 Metric 1: Fire Ignitions .......................................................................................................................... 26 Metric 2: Wires Down ........................................................................................................................... 26 Metric 3: Inspection-Cycle Completion ........................................................................................... 27 Metric 4: Vegetation-Management Cycle Completion ................................................................ 27 B. Impact of Metrics on Plan .............................................................................................................. 27 C. Monitoring and Auditing the Plan ................................................................................................ 27 D. Identifying and Correcting Deficiencies in the Plan .................................................................. 28 E. Monitoring the Effectiveness of Inspections ................................................................................ 28 IX. Independent Auditor ...................................................................................................................... 29 X. Cross References to SB-901 Requirements ................................................................................... 29 Lodi Electric Utility Wildfire Mitigation Plan Version 1.0 XXXXXX, XX, 2019 4 I. OVERVIEW A. POLICY STATEMENT Lodi Electric Utility’s (LEU’s) overarching goal is to provide safe, reliable, and economic electric service to its local community. In order to meet this goal, LEU strives to construct, maintain, and operate its electrical lines and equipment in a manner that minimizes the risk of catastrophic wildfire posed by its electrical lines and equipment. LEU is a department within the City of Lodi. As a public entity whose service territory is contained entirely within the City limits, LEU’s interests are entirely aligned with the City’s and the population we serve; we have no fiduciary obligation to any shareholders taking precedence over our customer-residents, nor any other priorities greater than Lodi’s. LEU is singularly focused on serving Lodi, to the greatest extent possible. Lodi’s wildfire prevention and mitigation efforts are thus benefited by Lodi’s organizational structure and focus. B. PURPOSE OF THE WILDFIRE MITIGATION PLAN This Wildfire Mitigation Plan describes the range of activities that LEU is taking to mitigate the threat of power-line ignited wildfires, including its various programs, policies, and procedures. This plan is subject to direct supervision by Lodi’s City Council and is implemented by the Electric Utility Director. This plan complies with the requirements of Public Utilities Code section 8387 for publicly owned electric utilities to prepare a wildfire mitigation plan by January 1, 2020, and annually thereafter. LEU is located in a region of the state with a very low wildfire risk. No part of LEU’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. Lodi Electric’s service territory is predominantly categorized as either “non-fuel” or “moderate” in the California Department of Forestry and Fire Protection’s (CALFIRE) Fire and Resource Assessment Program (FRAP) Fire Threat Map1. Cal Fire also provides the following statement with regard to the Local Responsibility Area for the County of San Joaquin, which LEU’s Service Territory is entirely within, “Update, 6/2008: CAL FIRE has determined that this county has no Very High Fire Hazard Severity Zones in LRA. Therefore [San Joaquin] county will not have a map of recommended VHFHSZ in LRA”2. Based on a review of local conditions and historical fires, Lodi Electric has determined that its electrical lines and equipment do not pose a significant risk of catastrophic wildfire. Despite this low risk, LEU takes appropriate actions to help its region prevent and respond to the increasing risk of wildfires. In its role as a public agency, LEU closely coordinates with other local 1 Cal Fire Map ID: FTHREAT_MAP, Oct. 20, 2005 2 Cal Fire Map ID: FHSZL06_1_MAP, Oct. 02, 2007, http://www.fire.ca.gov/fire_prevention/fhsz_maps_sanjoaquin (05/22/2019) Lodi Electric Utility Wildfire Mitigation Plan Version 1.0 XXXXXX, XX, 2019 5 safety and emergency officials to help protect against fires and respond to emergencies. LEU follows 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 LEU follows to reduce its risk of causing wildfires. C. BACKGROUND LEU has no known history of causing any widespread fire, nor suffering a widespread and prolonged outage due to any fire. While no utility is fully immune to fire, LEU’s history of outages and fire is consistent with operating a utility in an urban area. Per the City of Lodi’s General Plan, “The Planning Area is not characterized by substantial areas of wildlands. The topography of the area is relatively homogenous and steep slopes that could contribute to wildland fires are not common. Data provided by the California Department of Conservation Fire and Resource Assessment Program in 2007 indicate that no portions of the [City’s] Planning Area are classified as having a “High” or “Very High” risk.”3 LEU’s Service Territory is limited to a dense urban footprint (approximately 13.7 square miles of land). With an estimated service-territory population of more than 68,000, there are approximately on-average 5,000 persons per square mile of LEU service-territory, offering tremendous visibility on LEU’s infrastructure. Problems within LEU’s territory are therefore generally discovered very quickly. LEU’s compact territory also allows LEU to reach nearly every utility asset within a 10-minute drive from its headquarters. The high visibility and close proximity generally result in quick discovery and addressing of problems. This is in contrast with utilities having thousands of miles of line in the middle of dry forests, far from urban areas, lacking any real visibility, and with potentially great travel distances required when responding to a problem. Wildfire risk is greatly reduced by LEU’s topography and setting. LEU is relatively flat, lacking mountains, valleys, and other hard to access locations. LEU is bordered on the northern edge by the Mokelumne River. LEU is further benefited by advantageous land use in the surrounding area. In contrast with utilities traversing through large wilderness areas with decades of dry fuel accumulation, LEU is surrounded by miles of actively managed grape vineyards. Grape vineyards, with their open-space, moisture content, and active management, are frequently considered a very good firebreak, "The fire just came up to the edge of the vineyard and stopped."4 Further, much of LEU’s underground circuitry exists on the perimeter of LEU’s service territory, and functions as a buffer between LEU’s overhead infrastructure and the unimproved land abutting LEU’s service territory. 3 City of Lodi, General Plan, 4/2010 § 8.4 4 Mohan, Geoffrey. “Vineyards may have kept the wine country fire from getting worse.” Los Angeles Times, web. https://www.latimes.com/business/la-fi-vineyards-firebreak-20171012-story.html Lodi Electric Utility Wildfire Mitigation Plan Version 1.0 XXXXXX, XX, 2019 6 D. 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; • Community outreach and education; • Metrics for evaluating the performance of the plan and identifying areas for improvement; and • Review and validation of the plan. II. OBJECTIVES OF THE WILDFIRE MITIGATION PLAN The primary goal of this Wildfire Mitigation Plan is to describe LEU’s programs, practices, and measures in-place, which effectively reduce the probability that LEU’s electric supply system could be the origin or contributing source for the ignition of a wildfire; and in doing the aforementioned, comply with CA PUC Section 8387 and CA SB-901 2018 and its underlying goal to operate the electric-system safely when in high wildfire risk conditions. To support this goal, LEU 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. The secondary goal of this Wildfire Mitigation Plan is to improve the resiliency of the electric grid. As part of the development of this plan, LEU will continue to assess new industry practices and technologies that will reduce the likelihood of an interruption (frequency) in service, improve the restoration (duration) of service, and increase public safety during high wildfire risk conditions. Lodi Electric Utility Wildfire Mitigation Plan Version 1.0 XXXXXX, XX, 2019 7 III. ROLES AND RESPONSIBILITIES A. UTILITY GOVERNANCE STRUCTURE Excerpted City of Lodi Organization Chart, As Relevant to Wildfire Mitigation LEU’s governance begins with the citizens of Lodi electing a City Council. The City Council appoints a city manager who in turn hires directors and chiefs to run the various departments and utilities within the City’s auspices. A key difference between LEU and Investor Owned Utilities (IOUs) is that LEU is publicly owned and overseen by the very community it serves; LEU has no shareholders and is not-for-profit. Some of these positions’ duties, specific to wildfire mitigation include: Citizens of Lodi Lodi City Council City Manager Electric Utility Director Engineering & Operations Mgr. Operations Division Engineering Division Electric Superintendent Substation Division Construction / Maint. Division Vegetation Management Police Chief Fire Chief Public Works Director Water Utility Parks & Rec Director Lodi Electric Utility Wildfire Mitigation Plan Version 1.0 XXXXXX, XX, 2019 8 Lodi City Council: • Oversight and approval of Wildfire Mitigation Plan City Manager: • Oversight responsibility for the underlying departments Electric Utility Director: • Management of the Electric Utility • Overall implementation of this plan Fire Chief: • Fire response • Medical-emergency response • Maintaining a high-state of readiness (including staffing, training, perpetrations, equipment status) • Implementation of Incident Command System protocols • Certain public safety functions, partly overlapping with the Police Chief Public Works Director: • Management of the water system (including ensuring adequate supply, delivery, redundancy and back-up) • Maintenance of any City-Owned street trees (trimming, removal, etc.) Police Chief: • Law enforcement • Certain public safety functions, partly overlapping with the Fire Chief Parks & Rec. Director: • Overall condition of City’s Parks (including vegetation management and fuel removal) Engineering & Operations Manager: • Management of Engineering Division • Design practices • Specifications • Standards • Management of Operations Division • Utility Mapping Electric Superintendent: • Management of Substation Division • Management of Construction Division • Vegetation Management program (inspections & trimming) • Conducting system patrols and inspections B. WILDFIRE PREVENTION Under the City’s organizational arrangement, LEU’s Director has overall responsibility for the implementation and execution of this plan; LEU’s Engineering and Operations Manager oversees responsibility for electric facility design; and LEU’s Electric Superintendent oversees responsibility for construction, maintenance, inspections, and vegetation management. Lodi Electric Utility Wildfire Mitigation Plan Version 1.0 XXXXXX, XX, 2019 9 Other City departments contribute greatly to wildfire prevention efforts. Lodi’s Fire Department conducts various forms of community outreach and has historically worked with Lodi’s Parks & Recreation Department to conduct annual inspections of trees and vegetation in certain within certain properties controlled by the City, with the goal of identifying and removing fire-fuels such as dead trees or underbrush which may have accumulated. C. WILDFIRE RESPONSE AND RECOVERY LEU is available to its customers 24 hours per day, seven days per week, 365 days per year. During a wildfire or other public safety event, LEU’s operations center has the ability to dispatch personnel to aide as needed around the clock. In the event that an incident requires more personnel than LEU has on hand, LEU has mutual-aid agreements in place and available to provide nearly unlimited line-worker resources. LEU staff has the following obligations regarding fire prevention, response, and investigation: • Operate the electrical system in a manner that will minimize potential wildfire risks. • Take all reasonable and practicable actions to minimize the risk of a catastrophic wildfire caused by LEU’s electric facilities. • Coordinate with federal, state, and local fire management personnel as necessary or appropriate to implement LEU’s Wildfire Mitigation Plan. • Immediately report fires, pursuant to existing POU practices and the requirements of this Wildfire Mitigation Plan. • Take corrective action when the staff witnesses or is notified that fire protection measures have not been properly installed or maintained. • Comply with relevant federal, state, and industry standard requirements, including the industry standards established by the California Public Utilities Commission. • Collect and maintain wildfire data necessary for the implementation of this Wildfire Mitigation Plan. • Provide suitable training programs for all employees having obligations for implementation of this Wildfire Mitigation Plan. The City has established and positioned numerous public safety and water-utility resources, available to assist in combating wildfires and assisting with other public safety events and emergencies. In 2019/2020 the City’s Fire Department will be staffed with 57 personnel, including 55 firefighters, company officers, or chief officers. The Insurance Services Office (ISO) measures the effectiveness of fire-mitigation services in fire protection areas throughout the country5. The ISO assigns each area a Public Protection Classification (PPC) rating between one and ten (where one is the best, and ten is the worst). As of May 2019, Lodi has the nearly highest ISO PPC rating of two. The Lodi Fire Department’s high 5 http://www.iso.com/isoPassportHelp/reading_loc_ppc_reports.htm Lodi Electric Utility Wildfire Mitigation Plan Version 1.0 XXXXXX, XX, 2019 10 ranking places Lodi, in the top 95 percent of the ISO’s fire-mitigation effectiveness rankings, nationwide. A Class 2 ISO rating “indicates that the Fire Department is strategically placed throughout the City, and has adequate personnel, equipment, and expertise to serve the current population.”6 Source: https://www.isomitigation.com/p pc/program-works/facts-and- figures-about-ppc-codes- around-the-country/ 5/9/2019 Unlike many volunteer fire departments, Lodi’s Fire Department is staffed with professional firefighters 24/7/365 and maintains a constant high-level of readiness.” As of 8/7/2019, the department met the self-imposed National Fire Protection Association’s response time criteria of 6 minutes for 90% of all calls.7 As of 2018, the City operated 28 groundwater wells providing a total pumping capacity of 37,910 gallons per minute8,9 in addition to a Surface Water Treatment Plant, which currently has a capacity of 10-million gallons per day10,11. The 28 wells are computer controlled and “operate automatically on pressure demand, so that when water use increases, more wells are started”12. “Seven wells are fitted with emergency diesel powered generators. (….will help maintain water pressure during power outages….)”13 The City has 4.1 million gallons of water storage, spread across three different tanks14, and is scheduled to receive an additional million-gallon storage tank in October of 2019, increasing storage capacity to 5.1 million gallons15. During peak-season 6 City of Lodi, General Plan, 4/2010 § 3.3 7 Lodi Ca. Incident Compliance Percentage Report, June July 2019 8 City of Lodi, Public Works, Annual Water Quality Report For 2018 9 City of Lodi, Public Works, Water Master Plan, 2012, § 2.1 10 City of Lodi, Urban Water Management Plan, Pg. 40 11 City of Lodi, Public Works, Annual Water Quality Report For 2018 12 City of Lodi, Public Works, Annual Water Quality Report For 2018 13 City of Lodi, Public Works, Annual Water Quality Report For 2018 14 City of Lodi, General Plan, 4/2010 § 3.3 15 City of Lodi, Urban Water Management Plan, Fig. 6-1 Lodi Electric Utility Wildfire Mitigation Plan Version 1.0 XXXXXX, XX, 2019 11 (roughly coinciding with high-heat and fire-season), the City’s Water Utility’s operating practice is to maintain its massive storage reserves at a nearly-full capacity. “The City of Lodi owns and operates 28 emergency standby generator sets that range in size between six kilowatt (kW) to 2,000kW. The generators are located at critical facilities where operation during an extended power outage is necessary to maintain public health and/or safety. Examples of these facilities include fire stations, water wells, the Surface Water Treatment Plant, sanitary lift stations, White Slough Water Pollution Control Facility (WSWPCF), the police station, and Lodi Public Library.”16 The City has also undertaken replacement projects to upsize two and three inch water mains, to larger sizes, capable of providing more flows during fires.17 Additionally, Lodi’s Fire Department has the ability to pump water from the Mokelumne River -- a nearly unlimited fire-water resource on the northern edge of town. Lodi’s Fire Department also has access to wide-area mutual-aid resources, able to provide yet more water tenders and substantial additional fire-fighting resources. The General Plan reports the following policing resources, “For 2019, the Police Department has budgeted 111 full-time employees, with 77 sworn officers, and 72 volunteers.”18 “The City has adopted the San Joaquin County Hazard Mitigation Plan. This plan identifies measures to reduce the impacts of natural and manmade hazards and to facilitate the recovery and repair of structures if damage should occur from hazardous events.”19 “The City provides street standards for all street types, thus ensuring appropriate standards for emergency access and evacuation.”20 D. COORDINATION WITH WATER UTILITY AND PUBLIC SAFETY Lodi’s Fire Department, Lodi’s Public Works (including the Water Utility), and Lodi’s Electric Utility, are all departments within the same organization. This unified structure results in frequent contact and communication between the departments on many fronts and topics, and a beneficial familiarity in working together. Lodi’s Fire Department, (generally by way of its 24-hour Fire Dispatch), is well-versed in requesting assistance from LEU during emergencies. Fire Dispatch requests LEU’s assistance for every structure fire; for all other fires (e.g. vehicle fires) LEU assistance is always available, with utilization determined on a case-by-case basis by the event’s Incident Commander. Examples of LEU assistance include, to de-energize lines for fire and rescue operations, and to assess the hazards when overhead lines are on the ground (such as due to 16 City of Lodi, City Council meeting, June-19 2019, Agenda Item C-11 17 City of Lodi, General Plan, 4/2010 § 3.3 18 City of Lodi, General Plan, 4/2010 § 8.5 19 City of Lodi, General Plan, 4/2010 § 8.5 20 City of Lodi, General Plan, 4/2010 § 8.5 Lodi Electric Utility Wildfire Mitigation Plan Version 1.0 XXXXXX, XX, 2019 12 car accidents). While Lodi’s Police Department requests assistance from LEU less often, the same communication channels and access exist and are available. The Water Utility’s infrastructure is designed to automatically increase pressure and water-supply to the areas of the system where it’s needed, 24 hours per day, without any human involvement required. In the rare event that an unusually large or prolonged event requires more water than is normally possible, Lodi’s Water Utility staff are available 24 hours per day; Lodi’s Fire Department is able to notify the Water Utility of any unusual need. Upon such notification, the Water Utility has some additional ability to manually increase supply and pressure, and allocate more water to certain parts of town. E. COORDINATION WITH COMMUNICATION INFRASTRUCTURE PROVIDERS In the event of a disaster, Lodi has various different communication channels available for notifying and messaging the public. • Lodi has access to the County of San Joaquin’s emergency alert system – able to interrupt radio and television programming to provide an emergency message. • The County of San Joaquin also has a cell-phone triangulation system, able to message cell phones within a user-definable region. This system is available to Lodi for emergency use. • Lodi has the ability to broadcast a message onto the AM spectrum. • Lodi Unified School District has public-messaging capabilities available to the City. • Lodi is currently developing a reverse-911 system, whereby emergency personnel can send an emergency notification message to area cell-phones, land-lines, and VOIP phones. This system is estimated to be available to Lodi by 2021. • LEU also provides notifications on our website www.lodielectric.com and is presently developing an Outage Management System (OMS) and an Interactive Voice Response (IVR) system, to be used for notification purposes once completed. F. STANDARDIZED EMERGENCY MANAGEMENT SYSTEM As a local governmental agency,21 the City of Lodi has planning, communication, and coordination obligations pursuant to the California Office of Emergency Services’ Standardized Emergency Management System (“SEMS”) Regulations,22 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.23 Pursuant to this structure, the City of Lodi annually 21 As defined in Cal. Gov. Code § 8680.2. 22 19 CCR § 2407. 23 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. Lodi Electric Utility Wildfire Mitigation Plan Version 1.0 XXXXXX, XX, 2019 13 coordinates and communicates with the relevant safety agencies as well as other relevant local and state agencies. Under the SEMS structure, a significant amount of preparation is done through advanced planning at the county level, including the coordination of effort of public, private, and nonprofit organizations. San Joaquin County serves as the Operational Area; Lodi’s representation includes the City of Lodi’s Fire Chief. The Operational Area includes local and regional organizations that bring relevant expertise to the wildfire prevention and recovery planning process. Pursuant to the SEMS structure, City of Lodi representatives participate in regular meetings (typically monthly) and various simulation exercises (typically yearly), wherein various disasters (e.g. flood, earthquake, fire, etc.) are simulated. LEU is a member of the California Utility Emergency Association, which plays a key role in ensuring communications between utilities during emergencies. LEU also participate in the Western Energy Institute’s Western Region Mutual Assistance Agreement, which is a mutual assistance agreement covering utilities across a number of western states. IV. WILDFIRE RISKS AND DRIVERS ASSOCIATED WITH DESIGN, CONSTRUCTION, OPERATION, AND MAINTENANCE A. PARTICULAR RISKS AND RISK DRIVERS ASSOCIATED WITH TOPOGRAPHIC AND CLIMATOLOGICAL RISK FACTORS Within LEU’s service territory and the surrounding areas, the primary risk drivers for wildfire are the following: (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. Lodi Electric Utility Wildfire Mitigation Plan Version 1.0 XXXXXX, XX, 2019 14 • Extended drought • High winds Specific risks from these risk-drivers include increased vegetation mortality, contributing dry-fuels to the region, as well as deceased vegetation in its weakened-state potentially falling into energized lines during high-wind events. As mentioned in this plan, in contrast with the vegetation encountered by utilities traversing vast stretches of the California wilderness, the vegetation within LEU’s territory is much healthier, limited, less-dense, and managed, consistent with that of an urban/suburban utility; further the land-use surrounding LEU is overwhelmingly actively-managed grape vineyards extending for miles in every direction. LEU is unable to identify any direct risks of catastrophic wildfire in LEU’s service territory in connection with “dynamic climate change” risks. Indirect risks to LEU’s territory include the possible reduction of local Fire Department resources at times of mutual-aid deployments including combatting wildfires in State Responsibility Areas (a 12/12/2017 News Release by Cal Fire, US Forest Service and the Tree Mortality Task Force reports 129 Million dead-trees in California, predominantly in the Sierra Nevada region of the state). B. ENTERPRISEWIDE SAFETY RISKS Fire risks due to drought and windy conditions are low within LEU’s service territory. Lodi is a well- developed urban area with over 50 percent underground high voltage circuitry. In consultation with numerous experts and stakeholders, the CPUC created and adopted a statewide fire threat map to delineate the boundaries to identify, evaluate and potentially adopt stricter fire-safety regulations that apply to overhead power lines, electric equipment, and communications lines located within those boundaries. Drawing on the immense collective expertise responsible for the creation of the CPUC’s map, LEU’s methodology was to overlay LEU’s service territory and overhead transmission lines coming into the City of Lodi onto the fire threat map and therein identify potential areas of concern. LEU’s service territory and transmission all lines fall under the category of Tier-1 (i.e. low risk). The description of tiered fire threat zones are shown in Table-1 and the overlay of LEU’s service territory over the CPUC fire threat map is shown as Exhibit-1 below. Table – 1 Description of tiered fire threat zones Zone Category Description Tier 3 Extreme Wildland areas where exposure to overhead power lines, the availability of water resources, and emergency responder circulation routes affect response times to combat wildland fires. Tier 2 Elevated Elevated risk due to vegetation, high voltage regional transmission lines crossing the area, and adjacency to Tier 3 fire threat zones. Tier 1 Low Well-developed areas, typically with underground high voltage circuitry. Lodi Electric Utility Wildfire Mitigation Plan Version 1.0 XXXXXX, XX, 2019 15 Exhibit – 1 Overlay of LEU’s service territory over the CPUC fire threat map Lodi Electric Utility Wildfire Mitigation Plan Version 1.0 XXXXXX, XX, 2019 16 Note: Three 60kV transmission lines originating from PG&E’s Lockeford substation, operated and maintained by PG&E, enter LEU’s service territory at the Industrial substation. C. CHANGES TO CPUC FIRE THREAT MAP Currently LEU does not propose any changes to the borders of the High Fire Threat District boundaries as indicated in CPUC’s fire threat map (adopted by the CPUC January 19, 2018). Lodi Electric Utility Wildfire Mitigation Plan Version 1.0 XXXXXX, XX, 2019 17 V. WILDFIRE PREVENTATIVE STRATEGIES A. HIGH FIRE THREAT DISTRICT LEU, as a member of California Municipal Utilities Association (CMUA), participated in the development of the CPUC’s fire-threat map which designates a high-fire threat district. In the map development process, LEU served as a territory lead, and worked with utility staff and local fire and government officials to identify the areas of LEU’s service territory that are at an elevated or extreme risk of power line ignited wildfire. It was determined that LEU’s service territory and 60 kV transmission lines leading into the service territory are located outside of the high fire threat district as designated by the CPUC Fire-Threat Map. LEU’s efforts to improve this plan and achieve its goals are ongoing, including its efforts to identify existing and emerging fire threats and validate the characterization of LEU’s service territory. LEU will continue to review any new information, and any future updates in the CPUC’s Fire-Threat Maps, and revisit the above assessment as necessary. B. WEATHER MONITORING LEU monitors current and forecasted weather data from a variety of sources including: • LEU’s in-house weather station • United States National Weather Service • “PG&E Weather Awareness” website24 (an aggregation of regional PSPS, wind, temperature, Red-Flag and other information) • “PG&E PSPS Maps” website25 24 https://www.pge.com/en_US/safety/emergency-preparedness/natural-disaster/wildfires/psps-weather- map.page?WT.mc_id=Vanity_weather 25 https://www.pge.com/en_US/safety/emergency-preparedness/natural-disaster/wildfires/psps-event- maps.page Lodi Electric Utility Wildfire Mitigation Plan Version 1.0 XXXXXX, XX, 2019 18 C. DESIGN AND CONSTRUCTION STANDARDS LEU’s electric facilities are designed and constructed per the City of Lodi’s Electric Overhead Construction Standards to meet or exceed the relevant federal, state, or industry standards. LEU treats CPUC General Order (GO) 95 as a key industry standard for design and construction of overhead electrical facilities. LEU meets or exceeds all standards in GO 95. Additionally, LEU monitors and follows as appropriate the National Electric Safety Code. Additional wildfire-mitigating design and construction standards LEU employs include: • LEU stocks a wide range of covered-wires for use as jumpers and lead-wires • LEU has specified all overhead transformers and capacitors to have bushing covers pre- installed. In targeting the locations where distance between energized medium-voltage phases are in their closest proximity to each other (or ground potential), the combination of bushing covers and covered leads greatly reduces the ability for wildlife, foliage, balloons or other foreign objects to make contact with energized parts and potentially ignite a fire • All new distribution pad-mount transformers and switches have their medium-voltage interfaces specified as dead-front. In contrast with live-front equipment, dead-front equipment reduces the possibility of wildlife (snakes, burrowing-rodents, etc.) entering the equipment, making contact with energized components and igniting a fire; other fire-reduction examples include a dropped-tool or a piece of foliage or debris which blows-in while the cabinet is energized and open for servicing • LEU recently introduced natural ester oil (Envirotemp/FR3) into its specifications for oil- filled distribution transformers and switches. “Envirotemp FR3 fluid has exceptionally high fire and flash points of 360°C and 330°C, respectively - the highest ignition resistance of any high fire point dielectric fluid currently available. It qualifies as a “high fire point”, “less flammable”, “IEC Class K”, and “non-propagating” fluid. FR3 fluid is FM Global Approved and Underwriters Laboratories Classified as a Less-Flammable Dielectric Liquid. FR3 fluid possesses a 100% fire safety record, and is an ideal choice for transformers positioned indoors, underground, and in close proximity to buildings and other equipment”26 • New subdivisions and large commercial customers are connected by extending underground facilities, limiting the creation of additional overhead exposure27 26 Cargill, EnvirotempTM FR3TM Natural Ester Dielectric Fluid Overview, Page-1 27 Very rare exceptions may exist, such as for new minor-infill subdivisions found in overhead regions and where design constraints preclude underground infrastructure Lodi Electric Utility Wildfire Mitigation Plan Version 1.0 XXXXXX, XX, 2019 19 D. VEGETATION MANAGEMENT LEU strives to meet or exceeds the minimum industry standard vegetation management practices. The recommended time-of-trim guidelines do not establish a mandatory standard, but instead provide useful guidance to utilities. LEU will use specific knowledge of growing conditions and tree species to determine the appropriate time-of-trim-clearance in various circumstances. 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 Appendix E, Guidelines to Rule 35 The radial clearances shown below are recommended minimum clearances that 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 Radial clearances for any conductor of a line operating at 2,400 or more volts, but less than 72,000 volts 4 feet Radial clearances for any conductor of a line operating at 72,000 or more volts, but less than 110,000 volts 6 feet Lodi Electric Utility Wildfire Mitigation Plan Version 1.0 XXXXXX, XX, 2019 20 Radial clearances for any conductor of a line operating at 110,000 or more volts, but less than 300,000 volts 10 feet Radial clearances for any conductor of a line operating at 300,000 or more volts 15 feet LEU’s typical practice for trimming exceeds GO-95 Table-1, as well as the recommendations in GO-95 Appendix-E Case-13. LEU’s standard practice in trimming is to provide a minimum five- foot clear zone area around all secondary-voltage overhead infrastructure, a minimum ten-foot clear zone around all primary-voltage overhead infrastructure, and a minimum 15-foot clear zone around all sub-transmission and transmission overhead infrastructure. In instances including when our arborists believe that this high degree of trimming may kill a tree, they will occasionally reduce these large clearances, never going below GO-95’s proscribed values. LEU, Typical Trimming Clearances: Secondary Voltage ≤ 600V Primary Voltage 12 kV LL Sub-Transmission / Transmission Voltage 60 kV LL 5’ 10’ 15’ While LEU’s typical-practices already greatly exceed the state’s GO-95 requirements, LEU will at times trim vegetation even further for various reasons including arboricultural best practices, matching prior trimming cuts, aesthetics, or customer request. Additional features of LEU’s tree trimming program: • Prioritization given to dense-vegetation areas. • Consideration for vegetation-species, when determining prioritization. • When LEU encounters fast-growing or invasive species beneath overhead power lines, subject to permission from tree’s owner, LEU will undertake complete removal in lieu of trimming. • If LEU can anticipate an imminent seasonal growth spurt, LEU will generally trim deciduous trees beyond LEU’s typical amounts. • LEU has at its disposal two dedicated tree crews; LEU’s tree contractor has over 900 employees28, and offers the ability to greatly scale-up on a job-by-job basis should a particular job need additional crews and resources. • LEU’s contractor can provide cranes, as needed. • Every tree in proximity of electric infrastructure will be visited every 18-24-months, some even more frequently. 28 https://westcoastarborists.com/ Lodi Electric Utility Wildfire Mitigation Plan Version 1.0 XXXXXX, XX, 2019 21 • While customer-initiation is not required, customers with concerns can submit a request to have their vegetation situation reviewed. Customer-initiated requests are visited for assessment purposes within 48-hours, and frequently as fast as same-day. • Minimization of fuel-accumulation by removal of trimmings and resulting wood byproducts (with rare exceptions for property owners requesting to maintain possession). LEU’s urban service territory is again distinguished from utilities having lines traversing vast, isolated, rural lands and dry wild forests. The fuel-loading underneath LEU’s assets is consistent with the health, levels and species of vegetation found in other urban/suburban settings. Nearly all vegetation in the vicinity of LEU’s lines and Rights-of-Way belongs to private parties or the City of Lodi. These parties bear the responsibility for the removal of any accumulation of fuels (e.g. fallen logs, dead shrubbery) on their respective properties. LEU believes that the vegetation- owning parties within its territory succeed at removing accumulated fuels at a level vastly exceeding what is seen in California’s wildland areas. E. SYSTEM MAINTENANCE AND INSPECTIONS Periodic patrols and inspections provide the opportunity of identifying and remedying certain anomalous conditions prior to realization of any harm, possibly including wildfire. LEU meets or exceeds the minimum inspection cycles provided in CPUC GO 165 and CPUC GO 95, Rule 18. Additionally, LEU staff uses their knowledge of the specific environmental and geographical conditions to determine when certain areas require more frequent inspections. Lodi Electric Utility Wildfire Mitigation Plan Version 1.0 XXXXXX, XX, 2019 22 General Order 165 Table 1 -- Distribution Inspection Cycles (Maximum Intervals in Years) Patrol Detailed Intrusive Urban Rural Urban Rural Urban Rural Transformers Overhead 1 21 5 5 --- --- Underground 1 2 3 3 --- --- Padmounted 1 2 5 5 --- --- Switching/Protective Devices Overhead 1 21 5 5 --- --- Underground 1 2 3 3 --- --- Padmounted 1 2 5 5 --- --- Regulators/Capacitors Overhead 1 21 5 5 --- --- Underground 1 2 3 3 --- --- Padmounted 1 2 5 5 --- --- Overhead Conductor and Cables 1 21 5 5 --- --- Streetlighting 1 2 x x --- --- Wood Poles under 15 years 1 2 x x --- --- Wood Poles over 15 years which have not been subject to intrusive inspection 1 2 x x 10 10 Wood poles which passed intrusive inspection --- --- --- --- 20 20 (1) Patrol inspections in rural areas shall be increased to once per year in Extreme and Very High Fire Threat Zones in the following counties: Imperial, Los Angeles, Orange, Riverside, Santa Barbara, San Bernardino, San Diego, and Ventura. Extreme and Very High Fire Threat Zones are designated on the Fire and Resource Assessment Program (FRAP) Map prepared by the California Department of Forestry and Fire Protection’s Fire and Resource or the modified FRAP Map prepared by San Diego Gas & Electric Company (SDG&E) and adopted by Decision 12-01-032 in Phase 2 of Rulemaking 08-11-005. The fire threat map is to be used to establish approximate boundaries and Utilities should use their own expertise and judgment to determine if local conditions require them to adjust the boundaries of the map. Lodi Electric Utility Wildfire Mitigation Plan Version 1.0 XXXXXX, XX, 2019 23 F. RECLOSING POLICY In contrast with the majority of electric utilities in California, at present, LEU does not have any reclosers deployed downstream of LEU’s substations. Power outages create adverse impacts to life-safety (information on the impacts to life-safety can be found in Section-V, Subsection-G. De-Energization), these impacts often increase as outages are extended. While momentary-faults account for greater than 70-80% of all faults29, policies which direct the disabling of reclosing functionality, have the feature of extending what would otherwise be momentary and self-clearing power-outages and consequently, increasing the life-safety impacts of an outage. Further, undertaking such actions based largely upon weather predictions of unknown accuracy, carries the risk of doing so unnecessarily It is LEU’s goal to reduce outages both in count and duration. In determining a policy for reclosing, LEU has considered its complete lack of field-reclosers, its unique and low-risk urban setting and its beneficial service-territory specifics; LEU has additionally considered the large- scale adverse customer impacts arising from disabling reclosing at the substation-level. In consideration of the above, LEU finds that the public-interest is better served by not disabling substation-level reclosing functionality as a wildfire precautionary measure, and that doing-so would yield hard-to-identify benefits to wildfire reduction in LEU’s territory. G. DE-ENERGIZATION In the 100+ years of LEU’s existence, there is no known instance of LEU ever conducting a de- energization for wildfire mitigation purposes. Due to minimal risk of LEU’s electrical supply facilities causing a power-line ignited wildfire, LEU has taken the position that the practice of voluntarily de-energizing lines on a precautionary basis due to fire-threat conditions is not applicable to LEU’s service territory and system, and as a result LEU not adopting specific protocols for doing so. LEU will re-evaluate this determination in future updates to this Wildfire Mitigation Plan. Some of LEU’s rationale for this are as follows: Since the practice of de-energizing lines (aka “Public Safety Power Shutoff” or “PSPS”) is undertaken as a preventative measure to prevent a potential event of unknown certainty, based largely upon weather predictions of unknown accuracy, it carries the risk of being undertaken unnecessarily. 29 Cooper Power Systems, Electrical Distribution System Protection, P.7 Lodi Electric Utility Wildfire Mitigation Plan Version 1.0 XXXXXX, XX, 2019 24 While utilities in certain sparsely populated, hard-to-access wildland areas will occasionally conduct a de-energization, the decision to do so in dense urban population centers such as the City of Lodi, introduces greater safety concerns and other drawbacks: • A large percentage of Lodi’s signalized intersections do not have battery backups. During loss of power, numerous four-way arterial intersections (and others) lose their traffic-signal and street-lighting, greatly increasing the risk of traffic accidents. • Depending on the area involved, de-energization may remove the primary source of power to certain Water Utility infrastructure, whose wells, pumps and other assets are distributed across LEU’s territory. The continued delivery of water is integral to combating fires and providing safe clean drinking water to the residents of the City. • Lodi occasionally reaches high summertime temperatures. Upon loss of power, certain vulnerable residents who depend on air conditioning can suffer heat-related medical issues. • Some customers’ medical conditions require specialized powered medical equipment. While the best-practice would be for these customers to maintain backup sources and to pre-arrange exit plans, many do not. Further, these customers do not always identify themselves to LEU, creating the situation where any power-line under consideration for de-energization risks disconnecting an unknown number of these critical customers. • Industry-wide, many house fires have been caused by customers who attempt to use a stove during a power outage, mistakenly leaving it in the on position, and are not present when power is restored. • Under fire-threat conditions, which may already cause first responders to be stretched thin, de-energization imposes additional demands on first responders, such as combating looting, controlling unpowered intersections, evacuating residents, responding to heat- related medical issues, etc. and more. • Cell phones, laptops, electric cars, and other battery-powered objects are unable to charge during loss-of-power. • During Northern California’s 2017 wildfires, five persons died, unable to open their garage-doors after loss of power30. • Once the conditions triggering de-energization have passed, utilities usually methodically patrol every section of every line to verify their condition is acceptable for re- energization (e.g. free of tree-branches and in good condition). Unlike a momentary outage with an instantaneous restoration, this methodical inspection process can be very lengthy and increases each of the above impacts. 30 https://www.sacbee.com/news/politics-government/capitol-alert/article218811560.html Lodi Electric Utility Wildfire Mitigation Plan Version 1.0 XXXXXX, XX, 2019 25 In the extraordinary and yet-to-occur event that an upstream feed to LEU, operating beyond LEU’s control, is de-energized as part of a PSPS, LEU would utilize the communication and notification approach identified in Section III-E of this report. VI. COMMUNITY OUTREACH AND PUBLIC AWARENESS LEU will present the draft version of this plan to the Lodi City Council during public meetings. Currently LEU plans to hold two public meetings before adopting this plan. LEU will contract with an independent third party to perform an annual audit of this Wildfire Mitigation Plan. The audit findings will be presented to the Lodi City Council at a public meeting where the general public will have the opportunity to provide comments. In addition, LEU will post this plan on the LEU website www.lodielectric.com and make it available for public review in the City Clerk’s office. VII. RESTORATION OF SERVICE LEU has an Electric Emergency Plan (EEP) which governs the order in which loads are restored to service. The EEP shows the order in which circuits are to be brought up following a city-wide blackout. Vital loads are restored first followed by non-vital loads. In the event of a partial outage, circuits will be brought back as conditions permit in the order of priority listed in the EEP. In the case of wildfires involving lines and other utility assets and resulting in outages, once conditions have been made safe to do so, LEU will visually inspect every involved asset looking for visual damage and any hazards potentially remaining. Patrols will be conducted using a combination of human resources (both internal and depending on the scale, mutual aid resources) and may involve certain technology (possibly including drones, binoculars, etc.) prior to reenergizing circuits. Lodi Electric Utility Wildfire Mitigation Plan Version 1.0 XXXXXX, XX, 2019 26 VIII. EVALUATION OF THE PLAN A. METRICS AND ASSUMPTIONS FOR MEASURING PLAN PERFORMANCE LEU will track four metrics to measure the performance of this Wildfire Mitigation Plan: (1) number of fire ignitions; (2) wires down within the service territory; (3) inspection-cycle completion; and (4) vegetation-management cycle completion. Assumptions underlying the use of these metrics: As catastrophic wildfires are a subset of all fires, tracking and reporting all fire ignitions (as defined in metric-1) will necessarily capture wildfires. As wires-down events have the possibility of causing wildfires, tracking and reporting these events (as defined in metric-2) will over-time reveal LEU’s success at minimizing their occurrence and in-turn fires caused by such events. As inspections provide the opportunity of remedying certain conditions prior to realization of any harm, the successful progression of inspections is important to capturing this opportunity. METRIC 1: FIRE IGNITIONS For purposes of this metric, a fire ignition is defined as follows: • An LEU facility was associated with the origin of the fire31; • 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 • LEU has knowledge that the fire occurred. In future Wildfire Mitigation Plans, LEU will provide the number of fires that occurred that were less than 10 acres in size. Any fires greater than 10 acres will be individually described. METRIC 2: WIRES DOWN The second metric is the number of distribution and transmission wires downed within LEU’s service territory. For purposes of this metric, a wires-down event includes any instance where an electric transmission or primary distribution conductor falls to the ground or on to a foreign object. LEU will not normalize this metric by excluding unusual events, such as severe storms. Instead, LEU will supplement this metric with a qualitative description of any such unusual events. 31 Origin of the Fire distinguishes from fires of external origin e.g. a discarded cigarette butt, arson etc., which then spreads to involve utility facilities. This distinction is in keeping with the goal of identifying and minimizing utility-sources of fire, and not diluting the metric’s value with fires of unrelated origin. Lodi Electric Utility Wildfire Mitigation Plan Version 1.0 XXXXXX, XX, 2019 27 METRIC 3: INSPECTION-CYCLE COMPLETION The Third metric relates to the completion percentage of each system-inspection cycle. As discussed in Section V-D System Maintenance and Inspections, LEU practices the inspection cycles specified in GO-165. LEU tracks the progress of this by dividing its service territory into sixty- six similarly sized grids, and focusing and containing inspection efforts to service one grid at a time until that grid’s completion, before advancing to the next grid. While the amount of infrastructure needing inspecting in each grid is not exactly equal, the metric of number of grids complete out of the total, serves a reasonable approximation for progress towards the stated goal. METRIC 4: VEGETATION-MANAGEMENT CYCLE COMPLETION The Fourth metric relates to the completion percentage of each vegetation-management cycle. As discussed in Section V-D Vegetation Management, all vegetation within proximity of LEU assets is visited at a minimum every 18-24 months. LEU tracks the progress of this by dividing its service territory into sixty-six similarly sized grids, and focusing and containing vegetation- management efforts to service one grid at a time until that grid’s completion, before advancing to the next grid. While the amount of vegetation needing addressing in each grid is not exactly equal, the metric of number of grids complete out of the total, serves a reasonable approximation for progress towards the stated goal. B. IMPACT OF METRICS ON PLAN A discussion of how the application of previously identified metrics to previous plan performance has informed the plan, is required by SB-901. This being the initial year of LEU’s Wildfire Mitigation Plan and commencement of metric gathering provides no previous metrics for doing so. In the initial years of this plan, LEU anticipates that there will be relatively limited data gathered through these metrics. However, as the data collection history becomes more robust, LEU will be able to identify areas of its operations and service territory that are disproportionately impacted. LEU will then evaluate potential improvements to the plan. C. MONITORING AND AUDITING THE PLAN This Wildfire Mitigation Plan will be presented to the Lodi City Council. LEU will present this plan to the Lodi City Council on an annual basis. Additionally, a qualified independent evaluator will present a report on this plan to the Lodi City Council. The LEU Wildfire Mitigation Plan will be internally audited for completeness, effectiveness and implementation annually by the Electric Utility Director, in preparation for the presentation to the Lodi City Council. Lodi Electric Utility Wildfire Mitigation Plan Version 1.0 XXXXXX, XX, 2019 28 D. IDENTIFYING AND CORRECTING DEFICIENCIES IN THE PLAN LEU’s Utility Director shall identify any deficiencies in the plan’s implementation and take appropriate action to remedy any issues found. Additionally, the third-party auditor described in VIII.C will review the plan and provide feedback to LEU and the Lodi City Council. Findings from the above audits will be recorded and appropriate corrections to the Wildfire Mitigation Plan and supporting procedures and processes will be made. E. MONITORING THE EFFECTIVENESS OF INSPECTIONS A key mitigation measure against wildfires in LEU’s service territory is vegetation management, (described in greater detail in section V-D, Vegetation Management). All vegetation program matters are overseen by LEU’s Electric Superintendent. LEU uses contract tree trimmers who audit the vegetation in need of management and maintain the proscribed clear-zones. LEU audits the contractors and conducts Quality Assurance as to their successful implementation of LEU’s requirements, by at times working directly with them, and also by conducting audits (approximately weekly) of their work. In addition, LEU Staff performs system patrols and inspections (described further in section V-E, System Maintenance and Inspections) to identify system issues and deficiencies. The results of these patrols and the associated corrective action are prioritized based on their degree of safety-concern. The findings of the above audits, together with any trending provided by the metrics tracked in VIII-A of this plan will provide evidence of the effectiveness of the LEU Wildfire Mitigation plan. Lodi Electric Utility Wildfire Mitigation Plan Version 1.0 XXXXXX, XX, 2019 29 IX. INDEPENDENT AUDITOR Public Utilities Code section 8387(c) requires LEU 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 Lodi Electric Utility’s website and presented to the Lodi City Council at a public meeting. LEU, a member of the Northern California Power Agency (NCPA), will leverage the expertise of NCPA in selecting and engaging an independent evaluator as required in PUC Section 8387(c). The above-referenced evaluator will perform an audit of the LEU Wildfire Mitigation Plan annually. The third-party evaluator will be provided the plan and given the opportunity to audit the LEU processes as necessary to complete the audit. Some amount of electronic information sharing in preparation for the audit and following the audit will be allowed. Following the completion of the audit, the third-party evaluator shall brief relevant LEU staff and prepare a written report of findings which shall be presented to the Lodi City Council at a public meeting. All records associated with these audits shall be retained by LEU for at least five years. X. CROSS REFERENCES TO SB-901 REQUIREMENTS CROSS REFERENCES TO SB 901 REQUIREMENTS Requirement Statutory Language Location in POU Template Persons Responsible PUC § 8387(b)(2)(A): An accounting of the responsibilities of persons responsible for executing the plan. Section III Objectives of the Plan PUC § 8387(b)(2)(B): The objectives of the wildfire mitigation plan. Section II 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 V 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 VIII.A Lodi Electric Utility Wildfire Mitigation Plan Version 1.0 XXXXXX, XX, 2019 30 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 VIII.B 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 those protocols, including impacts on critical first responders and on health and communication infrastructure. Section V.F Section V.G 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 III.D Section III.E Section III.F Section V.G Vegetation Management PUC § 8387(b)(2)(H): Plans for vegetation management. Section V.D Inspections PUC § 8387(b)(2)(I): Plans for inspections of the local publicly owned electric utility’s or electrical cooperative’s electrical infrastructure. Section V.E 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 IV.A Section IV.B 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 IV.C Enterprisewide Risks PUC § 8387(b)(2)(L): A methodology for identifying and presenting enterprisewide safety risk and wildfire-related risk. Section IV.B Lodi Electric Utility Wildfire Mitigation Plan Version 1.0 XXXXXX, XX, 2019 31 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 VII 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. (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. Section VIII.C-E 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 IX Lodi Electric Utility Wildfire Mitigation Plan Version 1.0 XXXXXX, XX, 2019 32 Information NOT REQUIRED BY SB 901 Template Topic Location in POU Template Policy Statement Section I.A Purpose of the Plan Section I.B Background Section I.C Organization of the Plan Section I.D Coordination with water utilities Section III.D Coordination with communication companies Section III.E Standardized Emergency Management Systems Section III.F High Fire Threat District Section V.A Weather Monitoring Section V.B Design and Construction Section V.C Community Outreach Section VI ©2019 Guidehouse Inc. Wildfire Mitigation Plan Independent Evaluation Prepared for: Lodi Electric Utility Submitted by: Navigant, A Guidehouse Company 35 Iron Point Circle Suite #225 Folsom, CA 95630 guidehouse.com November 12, 2019 Wildfire Mitigation Plan Independent Evaluation Page i ©2019 Guidehouse Inc. TABLE OF CONTENTS Executive Summary ..................................................................................................... iii 1. Background ............................................................................................................... 1 1.1 SB 901 – Wildfire Mitigation Plans ................................................................................................ 1 1.1.1 AB 1054 Statutory Modifications ...................................................................................... 2 1.1 Lodi Electric Utility Plan Preparation ............................................................................................. 2 1.1.1 Independent Evaluation Services ..................................................................................... 2 2. Evaluation Scope and Approach ............................................................................. 4 2.1 Evaluation Parameters .................................................................................................................. 4 2.1.1 Provisional Requirements ................................................................................................ 4 2.1.2 Industry Knowledge and Regulatory Proceedings ........................................................... 6 2.2 Evaluation Approach ..................................................................................................................... 6 2.2.1 Statutory Compliance ....................................................................................................... 6 2.2.2 Industry Wildfire Mitigation Practices Comparison ........................................................... 6 2.2.3 Value Determination of Plan Metrics ................................................................................ 8 3. LEU WMP Plan Elements .......................................................................................... 9 3.1 Objectives and Overview of Preventative Strategies and Programs ............................................ 9 3.1.1 Risk Assessment & Drivers .............................................................................................. 9 3.1.2 Asset Overview & Service Territory ................................................................................ 10 3.1.3 Wildfire Prevention Strategies ........................................................................................ 10 3.1.4 Response & Restoration................................................................................................. 11 3.1.5 Metrics & Plan Monitoring............................................................................................... 12 4. Results & Discussion .............................................................................................. 14 Appendix A. Statutory Compliance Matrix ................................................................ 15 Wildfire Mitigation Plan Independent Evaluation Page ii ©2019 Guidehouse Inc. DISCLAIMER This report was prepared by Navigant Consulting, Inc., n/k/a Guidehouse Inc. (“Navigant”),1 for Lodi Electric Utility. The work presented in this report represents Navigant’s professional judgment based on the information available at the time this report was prepared. Navigant is not responsible for the reader’s use of, or reliance upon, the report, nor any decisions based on the report. NAVIGANT MAKES NO REPRESENTATIONS OR WARRANTIES, EXPRESSED OR IMPLIED. Readers of the report are advised that they assume all liabilities incurred by them, or third parties, as a result of their reliance on the report, or the data, information, findings and opinions contained in the report. 1 On October 11, 2019, Guidehouse LLP completed its previously announced acquisition of Navigant Consulting Inc. In the months ahead, we will be working to integrate the Guidehouse and Navigant businesses. In furtherance of that effort, we recently renamed Navigant Consulting Inc. as Guidehouse Inc. Wildfire Mitigation Plan Independent Evaluation Page iii ©2019 Guidehouse Inc. EXECUTIVE SUMMARY Lodi Electric Utility (LEU) contracted with Navigant Consulting, Inc. n/k/a Guidehouse Inc. (Navigant) to engage in an independent evaluation of its Wildfire Mitigation Plan (Plan or WMP). This independent evaluation report (Report) describes the technical review and evaluation provided by Navigant. Navigant performed this evaluation in October and November 2019 and completed the Report on November 12, 2019. Navigant’s project team reviewed detailed information related to the Plan and assessed LEU’s procedures related to the Plan. The Plan was prepared as a response to Senate Bill (SB) 901, which was signed into law on September 21, 2018. SB 901 resulted in a number of provisions and directives, among which includes the requirement for electric utilities to prepare and adopt Plans within 2019 and revise and update the Plan annually thereafter. These requirements are codified in the California Public Utilities Code (PUC) Section 8387 for publicly-owned utilities (POUs). Navigant evaluated the Plan based on the statutory requirements of PUC Section 8387 as it relates to POUs. This PUC Section was amended on July 12, 2019 as a result of the signing of California’s Assembly Bill (AB) 1054 into law. The POUs are now subject to the guidance provided by the California Wildfire Safety Advisory Board 2 and mandatory cyclical reviews. The required elements for a WMP have not been modified by this new legislation. This Report meets LEU’s requirements under PUC Section 8387(c), which mandate an independent evaluation of LEU’s Plan. The Report was developed to satisfy the statutory requirement for public review. This Report underlies the required evaluation by the Board of Directors at a public meeting, scheduled for November 20, 2019. The Report includes the following: • Background of the legislative history requiring WMPs and their independent evaluations • Approach and methodology evaluating the Plan’s comprehensiveness • LEU’s Plan elements and their compliance with SB 901 and PUC Section 8387 WMP elements and directives • An evaluation of the Plan’s presented metrics to assess the effectiveness of the overall Plan • Determinations and results Based on relevant experience in grid hardening and resiliency, natural disaster response, prior experience in WMP development, and active tracking of wildfire legislative and regulatory proceedings Navigant has concluded that LEU’s WMP is comprehensive in accordance with PUC section 8387. 2 Due for implementation in 2020. Wildfire Mitigation Plan Independent Evaluation Page 1 ©2019 Guidehouse Inc. 1. BACKGROUND In recent years, California has seen an increase in utility equipment-involved, catastrophic wildfires. The unique geographic profile of California and the impacts of climate change, including continued dry conditions, high winds, and elevated heat index risk from global rising temperatures, have led to elongated fire seasons. The state is also experiencing increased levels of vegetation fuel due to the wet winters, hotter summers following a seven-year drought, and past fire suppression efforts. This increasingly abundant dry vegetation is the leading driver of wildfires. The levels of dry vegetation fuel have been aggravated by a destructive bark beetle infestation that continues to impact the health of the state’s forested areas, further increasing fire risk. These fuel-rich environments, coupled with intensified climatological conditions with high wind gusts and natural electrical infrastructure risks, produce the conditions conducive to potential wildfire ignition. The three attributes that provide optimal conditions for a fire ignition are illustrated through the graphic in Figure 1. Figure 1: Fire Triangle Disastrous wildfire threat is a well-known and shared priority among electric utilities in California. The recent spike in utility-involved wildfire incidents since the 2015 wildfire season and the significant financial and livelihood impacts associated with them have led to more formalized efforts to ensure safe operations of electric utility equipment and greater investment in wildfire mitigation efforts.3 Specifically, the state has approved legislation that strengthens governmental and regulatory oversight of wildfire prevention implementation activities, utility Wildfire Mitigation Plans (WMPs or Plans), and proper dispersal of state funds to wildfire victims. In an effort to minimize future devastating occurrences through risk-driven wildfire prevention, electric utilities, including cooperatives, were mandated, by Senate Bill (SB) 901 (Senator Bill Dodd, 2018), to prepare and annually adopt a WMP before January 1, 2020. This effort is foundational to the state’s prioritized goal of minimizing the potential of devastating fires in future years. 1.1 SB 901 – Wildfire Mitigation Plans On September 21, 2018, Governor Jerry Brown signed SB 901 into law. The bill directs electrical utilities to annually prepare WMPs that include several mitigation and response elements in each utility’s strategies, protocols, and programs. Each electric utility is to prepare and adopt a comprehensive WMP before January 1, 2020. The requirements for publicly-owned utilities (POUs) are presented in Public 3 California Public Utilities Commission, 2019. “Fire Incident Data Reports for Investor-Owned Utilities,” https://www.cpuc.ca.gov/fireincidentsdata/. Wildfire Mitigation Plan Independent Evaluation Page 2 ©2019 Guidehouse Inc. Utilities Code (PUC) Section 8387. Details relating to POU requirements are discussed in Section 2 of this WMP evaluation report (Report). 1.1.1 AB 1054 Statutory Modifications On July 12, 2019, Governor Gavin Newsom signed Assembly Bill (AB) 1054 into law. This bill was developed with the consideration of the Governor’s Strike Force effort to develop prioritized strategies to help the state achieve its decarbonization goals. AB 1054 aims to mitigate the intensity of wildfire impacts through several initiatives separate from those actions required of electric utilities. SB 901 directed the Office of Planning and Research to establish a Commission on Catastrophic Wildfire Cost Recovery (SB 901 Commission) with the goal of addressing utility wildfire liability, cost responsibility and victim support, and issues with insurance availability and affordability. On June 18, 2019, the SB 901 Commission presented to the state Legislature, findings and recommendations on the issues discussed at public workshops over the course of several months. This, in part with Governor Newsom’s Wildfire Reform Package, resulted in legislation that culminated in the provisions listed in AB 1054. AB 1054 includes directives to establish the Wildfire Safety Division at the California Public Utilities Commission (CPUC) and the state’s Wildfire Safety Advisory Board. POUs will their WMPs by July 1 of each year starting in 2020 for review by and recommendations from the Wildfire Safety Advisory Board. No less than every three years, POUs are required to comprehensively update their WMPs. This change is included in this evaluation as a reference for future requirements. 1.1 Lodi Electric Utility Plan Preparation Lodi Electric Utility (LEU) is a department within the City of Lodi. Its service territory is contained entirely within the City limits. LEU’s primary goal is to provide safe, reliable, and cost-effective electricity while also anticipating and meeting customer needs. As a POU, LEU has no fiduciary obligations to shareholders and its actions and decisions are governed by City Manager and the City Council and ultimately to the citizens of Lodi. LEU prepared its first WMP pursuant to SB 901 directives. The Plan aims to address each of the required elements presented by PUC Section 8387 and ultimately reduce the risk of contributing to utility-involved wildfire events through Plan execution and metric tracking. LEU has posted its draft plan to its website for public review. LEU reserves the right to modify the WMP until it is presented to and approved by City Council in November 2019. 1.1.1 Independent Evaluation Services PUC Section 8387(c) directs POUs to procure services for an independent evaluation (IE) of the comprehensiveness of the WMP. In January 2020, upon commencement of the California Wildfire Safety Advisory Board, guidelines and further details related to the scope and timelines of future IEs will be discussed and reviewed. In its present 4 form, the provisions of PUC Section 8387 state that the independent evaluator shall be experienced in “assessing the safe operation of electrical infrastructure” and will perform an assessment to determine the comprehensiveness of the Plan.5 LEU sought out IE services to assess the comprehensiveness of its WMP pursuant to PUC Section 8387(c) prior to presenting the final WMP to City Council and contracted Navigant Consulting, Inc., n/k/a Guidehouse Inc. (Navigant) in October of 2019 to undertake an assessment of its Plan based on 4 The CPUC has just begun its investigation to develop a list of recognized independent evaluators by March of 2021. 5 It is recognized that this requirement does not yet include a clear definition of comprehensiveness. Wildfire Mitigation Plan Independent Evaluation Page 3 ©2019 Guidehouse Inc. Navigant’s prior experience with assessing the safe operation of electrical infrastructure, including grid- hardening and WMPs, with an emphasis on electrical equipment, public, and personnel safety. Emergent practices will materialize as evolving legislative action and technology advances continue to shape wildfire mitigation and safety efforts. Understanding this, Navigant performed a comparison of the wildfire mitigation investments undertaken by other utilities throughout California as well as relied on the team’s experience in working directly with utilities to develop their WMPs and data collection practices along with prior experience related to gird hardening and electric safety assessments. This Report presents the results of Navigant’s WMP IE. The following section describes the methodology in executing this evaluation. Navigant Identification of Qualifications Navigant provides IE services throughout the United States. Navigant’s grid-related IE projects include storm hardening, wildfire mitigation, resiliency assessments, advanced technology suitability, among others. Our approach includes an evaluation of data considered, suitability of tracking metrics – both frequency and trends analysis - and an evaluation of key performance indicators. Navigant assesses the efficacy of tools for creating sufficient awareness and for effectiveness of understanding overall WMP’s intended and actual impacts. Navigant also leverages experience developing “Metrics and Benefits Reporting Plans” to gauge cost-effectiveness of activities and alignment of plans to intentions. Navigant understands LEU’s publicly-owned business practices relative to IOUs, through our experience developing WMPs for two IOUs and our continued tracking of related CPUC dockets intended to refine strategies that carry an effective Plan.6 Navigant continues to track proceedings, pending legislation, and other developments surrounding utility wildfire risk. Our team remains active with WMP engagements across jurisdictions and risk profiles. As part of maintaining high acumen of prudent mitigation strategies, Navigant participates in forums focused on innovative wildfire mitigation strategies—further expanding our industry knowledge. Navigant provides thought leadership and advisory services related to WMP and other resiliency innovative technologies to the California Energy Commission and has supported their system hardening and fire prevention efforts since 2008. Additionally, Navigant’s reach into grid resiliency and disaster-related hardening extends across the United States including island grids, such as Puerto Rico, recovering from recent, weather- related catastrophes. 6 Navigant provided technical services to Liberty Utilities (CalPeco Electric) and Bear Valley Electric Service (BVES) immediately prior to and within the 2019 calendar year. The services resulted in support of the development and filing of their respective WMPs to the CPUC on February 6, 2019. Navigant continued to support BVES in development of their Data Collection for WMP report, filed on July 30, 2019. Wildfire Mitigation Plan Independent Evaluation Page 4 ©2019 Guidehouse Inc. 2. EVAL UATION SCOPE AND APPROACH At the time of this IE, the guidelines and requirements were not available to POUs regarding the structure or determination of comprehensiveness pursuant to PUC Section 8387(c). In lieu of this formalized directive, Navigant completed this evaluation based on industry standard practices, our experience developing and reviewing WMPs and other grid hardening activities, our active tracking of wildfire legislative and regulatory proceedings and, most importantly, a comparison of the specific criteria in PUC Section 8387(b)(2) to the specific wildfire-related plans outlined in LEU’s WMP. 2.1 Evaluation Parameters Figure 2 represents the attributes comprising the methodology and approach of the evaluation. Figure 2: Contributing Factors to Evaluate the Plan 2.1.1 Provisional Requirements As mentioned above, the requirement for electric utilities and corporations to develop WMPs emerged from the directives of SB 901 and associated statutory modifications. With respect to POUs, the nested subsections under PUC Section 8387(b)(2) outline the required elements to be included in the Plan. See Table 1 for the complete statutory compliance list. Wildfire Mitigation Plan Evaluation Statutory Compliance State Wildfire Mitigation Practices IOU Plan Reference WMP Strategies and Metrics Wildfire Mitigation Plan Independent Evaluation Page 5 ©2019 Guidehouse Inc. Table 1: POU Requirements for the WMP PUC Section 8387 (as amended on July 12, 2019) (a) Each local publicly owned electric utility and electrical cooperative shall construct, maintain, and operate its electrical lines and equipment in a manner that will minimize the risk of wildfire posed by those electrical lines and equipment. (b) (1) The local publicly owned electric utility or electrical cooperative shall, before January 1, 2020, prepare a wildfire mitigation plan. After January 1, 2020, a local publicly owned electric utility or electrical cooperative shall prepare a wildfire mitigation plan annually and shall submit the plan to the California Wildfire Safety Advisory Board on or before July 1 of that calendar year. Each local publicly owned electric utility and electrical cooperative shall update its plan annually and submit the update to the California Wildfire Safety Advisory Board by July 1 of each year. At least once every three years, the submission shall be a comprehensive revision of the plan. (2) The wildfire mitigation plan shall consider as necessary, at minimum, all of the following: (A) An accounting of the responsibilities of persons responsible for executing the plan. (B) The objectives of the wildfire mitigation plan. (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. (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. (E) A discussion of how the application of previously identified metrics to previous wildfire mitigation plan performances has informed the wildfire mitigation plan. (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 those protocols, including impacts on critical first responders and on health and communication infrastructure. (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. (H) Plans for vegetation management. (I) Plans for inspections of the local publicly owned electric utility’s or electrical cooperative’s electrical infrastructure. (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. (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. Wildfire Mitigation Plan Independent Evaluation Page 6 ©2019 Guidehouse Inc. (L) A methodology for identifying and presenting enterprise wide safety risk and wildfire-related risk. (M) A statement of how the local publicly owned electric utility or electrical cooperative will restore service after a wildfire. (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. (iii) Monitor and audit the effectiveness of electrical line and equipment inspections, including inspections performed by contractors, that are carried out under the plan, other applicable statutes, or commission rules. (3) The local publicly owned electric utility or electrical cooperative shall, on or before January 1, 2020, and not less than annually thereafter, present its wildfire mitigation plan in an appropriately noticed public meeting. The local publicly owned electric utility or electrical cooperative shall accept comments on its wildfire mitigation plan from the public, other local and state agencies, and interested parties, and shall verify that the wildfire mitigation plan complies with all applicable rules, regulations, and standards, as appropriate. (c) The local publicly owned electric utility or electrical cooperative shall contract with a qualified independent evaluator with experience in assessing the safe operation of electrical infrastructure to review and assess the comprehensiveness of its wildfire mitigation plan. The independent evaluator shall issue a report that shall be made available on the internet website of the local publicly owned electric utility or electrical cooperative, and shall present the report at a public meeting of the local publicly owned electric utility’s or electrical cooperative’s governing board. 2.1.2 Industry Knowledge and Regulatory Proceedings The state’s priority towards abating future catastrophic wildfire events is demonstrated through aggressive measures, directing utilities to enhance their protocols for fire prevention, public communications, and response. That collection of information is presented in a comprehensive WMP. While POUs are directed to develop this Plan prior to January 1, 2020, Navigant recognizes that California utilities subject to CPUC jurisdiction have filed their respective Plans on February 6, 2019. Navigant has tracked docketed proceedings and maintains a presence in state activities and workshops surrounding wildfire prevention. Understanding that LEU is not subject to CPUC regulations, the insight gained from this related experience is leveraged in assessing LEU’s Plan relative to its risk profile and industry position. 2.2 Evaluation Approach To perform an assessment of the comprehensiveness of the Plan, Navigant used the following described approach. 2.2.1 Statutory Compliance Navigant sought to determine compliance with the provisional requirements laid out in SB901 as codified in PUC Section 8387. The Plan’s alignment with the statutory requirement is presented in Appendix A. LEU’s mitigation measures are not required to exceed the statutory requirements. 2.2.2 Industry Wildfire Mitigation Practices Comparison Accepted practices for wildfire mitigation have been discussed and presented at numerous events, such as the Wildfire Technology Innovation Summit, held on March 20-21, 2019. Additionally, Plans approved Wildfire Mitigation Plan Independent Evaluation Page 7 ©2019 Guidehouse Inc. by the CPUC have garnered significant insight from the industry at large. Navigant’s understanding of an effective Plan draws on comparisons from existing WMPs and industry practices and is summarized according to business practice categories described in Figure 3. Figure 3: Mitigation Strategy Overview Expertise in these critical elements facilitated Navigant’s review of the comprehensiveness of LEU’s WMP. While not all of these strategies are present in or applicable to LEU’s Plan, due to LEU’s size, location, and operational characteristics, Navigant’s understanding of collected utility strategies demonstrated throughout the state are summarized below: • Inspection and maintenance of distribution transmission and substation assets including conducting system patrols and ground inspections, using technological inspection tools, managing predictive and electrical preventative maintenance, and conducting vegetation inspections and management, vulnerability detection such as Light Detection and Ranging (LiDAR) inspection; and geospatial and topography identification, geographic information system (GIS) mapping data. A key component is identifying collected data elements through each program and understand how that data is used and shared to improve utility practices. • Vegetation management that includes routine preventative vegetation maintenance; corrective vegetation management and off-cycle tree work; emergency vegetation clearance, prioritized for portions of the service territory the lie in high hazard zones, quality control processes; and resource protection plan, including animal and avian mitigation programs. • System hardening that includes pole replacement, non-expulsion equipment, advanced fuses, tree attachment removal, less flammable transformer oil, covered wire and wire wrap, and undergrounding where cost beneficial. • Operational practices including communications and mustering plans under varying degrees of wildfire risk. Plans to deactivate automatic reclosers, de-energization of “at risk” area powerlines based on type of facility (overhead bare conductions, high voltage, etc.), tree and vegetation density, available dry fuel, and other factors that make certain locations vulnerable to wildfire risk. • Situational awareness including obtaining information from devices and sensors on actual system, weather and other wildfire conductivity conditions, two-way communication with agencies and key personnel. Programs such as online feeds and websites such as the National Fire Wildfire Mitigation Plan Independent Evaluation Page 8 ©2019 Guidehouse Inc. Danger Rating System. Situational awareness should help achieve a shared understanding of actual conditions and serve to improve collaborative planning and decision making. • De-Energization actions triggered and prioritized by forecasted extreme fire weather conditions; imminent extreme fire weather conditions; validated extreme fire weather conditions; and plans for re-energization when weather subsides to safe levels. Manual or automatic capabilities exist for implementation. • Advanced Technologies including Distribution Fault Anticipation technology, tree growth regulators, pulse control fault interrupters, oblique and hyper-spectral imagery; advanced transformer fluids; advanced LiDAR, and advanced SCADA, to reduce electrical ignition while also helping to mitigate power outages and equipment damage. • Emergency Preparedness, Outreach and Response communications before, during, and after emergencies including but not limited to engaging with key stakeholders that include critical facilities and served customers; local governments, critical agencies such as California Department of Forestry and Fire Protection (CAL FIRE), local law enforcement agencies and other first responders, hospitals, local emergency planning committees, other utility providers, California Independent System Operator, and the utility’s respective Board. Coordination agreements such as Mutual Assistance should be leveraged. Community outreach plan should inform and engage first responders, local leaders, land managers, business owners and others. • Customer support programs including financial assistance and support for low-income customers; billing adjustments; deposit waivers; extended payment plans; suspension of disconnection and non-payment fees; repair processing and timing; access to utility representatives; and access to outage reporting and emergency communications. Consideration of languages in addition to English. Identification of priority customers, such as first responders and local agencies, health care providers, water and telecommunication facilities, groups that assist children, elderly, mobility impaired, and other vulnerable populations. 2.2.3 Value Determination of Plan Metrics Metrics for tracking the Plan’s progress intend to allow the utility to refresh information as trends become clearer. Based upon the discussion included in the CPUC’s Phase 2 of the SB 901 proceeding docket, interests in metric development and underlying data collection are beginning to take shape. While these determinations do not directly influence the public power sector, insight has been leveraged to employ effective metrics.7 7 CPUC Order Instituting Rulemaking to Implement Electric Utility Wildfire Mitigation Plans Pursuant to SB 901 (2018) (Rulemaking 18-10-007) https://apps.cpuc.ca.gov/apex/f?p=401:56:0::NO:RP,57,RIR:P5_PROCEEDING_SELECT:R1810007. Wildfire Mitigation Plan Independent Evaluation Page 9 ©2019 Guidehouse Inc. 3. LEU WMP PLAN ELEMENTS Navigant reviewed the Plan elements and determined whether the activities supported the intention to deploy an effective WMP. This determination incorporated individual elements as well as underlying data sources that further described data collection methodologies and implementation procedures to ensure measures are carried out and also tracked. This understanding also informs internal reviews and subsequent updates for future Plan iterations. Navigant found that LEU’s WMP meets the statutory requirements of comprehensiveness PUC Section 8387. In this section, we review the WMP’s elements and their purpose relative to the development and successful execution of the WMP. A table comparing each subsection of PUC Section 8387 to the significant sections of the WMP can be found in Appendix A. 3.1 Objectives and Overview of Preventative Strategies and Programs PUC Section 8387 (B) The objectives of the wildfire mitigation plan. (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. LEU has clearly stated objectives in its WMP in section II of the WMP. LEU’s primary objective refers to “reducing the probability that LEU’s electric supply system could be the origin or contributing source for the ignition of a wildfire; and in doing the aforementioned, comply with CA PUC Section 8387 and CA SB- 901 2018 and its underlying goal to operate the electric-system safely when in high wildfire risk conditions.” The secondary objective is to improve the resiliency of LEU’s electric system Section V of LEU’s Plan describes in detail LEU’s preventative strategies and programs, which are discussed in more detail in the sections below. 3.1.1 Risk Assessment & Drivers PUC Section 8387 (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. (L) A methodology for identifying and presenting enterprise-wide safety risk and wildfire-related risk. Wildfire Mitigation Plan Independent Evaluation Page 10 ©2019 Guidehouse Inc. Section IV of LEU’s WMP elaborates the risk analysis and risk drivers that guide the development of LEU’s wildfire prevention practices. LEU identifies vegetation mortality, extended drought, and high winds as the primary risk drivers in this section. It also identifies indirect risks associated with dynamic climate change risk such as resource limitations if they are redirected to wildfire-related efforts outside of LEU service territory. This section also sets forth LEU’s methodology for identifying enterprise-wide and wildfire-related risk includes overlaying its service territory on the CPUC’s Fire-Threat Map. This exercise identifies that LEU service territory currently falls under the category of Tier 1 or low risk under the CPUC Fire-Threat Map. Additionally, LEU’s system and service area characteristics (primarily urban, flat, compact, and without any unmanaged wildlands) demonstrate LEU poses a low risk of providing an ignition source for a wildfire. LEU also discusses the specific design and construction standards it has implemented to minimize fire risk in Section V.C of the WMP. This section details the use of insulated wires, transformer selection, use of high flashpoint transformer oil, and use of undergrounding for new subdivisions and large commercial customers. 3.1.2 Asset Overview & Service Territory PUC Section 8387 (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. As described in Section IV of the WMP, LEU service territory falls under the Tier 1, low risk area of the CPUC fire threat map. LEU does not propose any changes to the map at this time as mentioned in section IV.C. 3.1.3 Wildfire Prevention Strategies PUC Section 8387 (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 those protocols, including impacts on critical first responders and on health and communication infrastructure. (H) Plans for vegetation management. (I) Plans for inspections of the local publicly owned electric utility’s or electrical cooperative’s electrical infrastructure. 3.1.3.1 Disabling Reclosers Section V.F of the WMP states that it does not have any reclosers deployed downstream of its substations and it does not currently have a protocol for disabling reclosers at its substations. This decision is explained in detail based on the low-risk nature of LEU’s power system and the negative impacts to public safety, critical first responders, and on health and communication infrastructure expected under extended outages. Wildfire Mitigation Plan Independent Evaluation Page 11 ©2019 Guidehouse Inc. 3.1.3.2 De-Energization Protocols Section V.G of the WMP identifies that while LEU has the authority to de-energize portions of its electric system for fire-threat conditions, it is not proposing to implement De-energization protocols for wildfire prevention As with the decision not to disable LEU’s reclosers, because LEU operates entirely within a Tier 1, low risk area LEU considered the harm from preemptory and longer duration power outages exceeds the low likelihood LEU’s system may ignite a wildfire. LEU discusses several reasons related to public safety, critical first responders, and on health and communication infrastructure for not developing such a protocol. This section also addresses that if power fed into LEU’s system is cut but a public safety power shutoff (PSPS) LEU would enact its communication and notification capabilities to alert the community of the PSPS. 3.1.3.3 Vegetation Management In Section V.D, LEU describes its vegetation management plan that implements standards based on and exceeding the minimum requirements in CPUC GO 95. LEU’s standard practice for trimming is to have at least a five-foot clearance around secondary voltage overhead infrastructure, a ten-foot clearance around all primary voltage overhead infrastructure, and a 15-foot clearance around all sub-transmission and transmission overhead infrastructure. The vegetation within LEU’s service territory is reflective of those typically found in an urban or suburban setting. All trees in proximity to LEU electric infrastructure are visited at least every 18-24 months. Dense- vegetation areas are prioritized and fast-growing or invasive species are removed, subject to the permission of the tree’s owner. LEU contracts this service out and has two dedicated tree crews with the ability to quickly scale up if needed. 3.1.3.4 Infrastructure Inspections Section V.E of the WMP describes LEU’s infrastructure inspection program. LEU seeks to always meet or exceed the inspection requirements in CPUC GO 95 Rule 18 and GO 165. LEU staff also leverage their knowledge of the system and geographical conditions to determine when certain areas require m ore frequent inspections. 3.1.4 Response & Restoration PUC Section 8387 (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. (M) A statement of how the local publicly owned electric utility or electrical cooperative will restore service after a wildfire. 3.1.4.1 Event Communication LEU sets forth several communication channels in Section III (notably parts D, E, and F) of the WMP for use in an emergency situation to notify the public. These include the County of San Joaquin’s emergency Wildfire Mitigation Plan Independent Evaluation Page 12 ©2019 Guidehouse Inc. alert system and cell-phone triangulation system, AM broadcasting, the company website, and Lodi Unified School District’s public-messaging capabilities. LEU is also developing an Outage Management System and an Interactive Voice Response system. In addition, the utility complies with the California Office of Emergency Services’ Standardized Emergency Management System (SEMS) Regulations and is a participant in the Western Energy Institute’s Western Region Mutual Assistance Agreement. The WMP states that these communication channels and resources are available to LEU during an emergency event and would be used in the event of de-energization of an upstream feed to LEU (operating beyond its control). 3.1.4.2 Restoration Section VII of the Plan states LEU will restore service following an outage based on the circuit prioritization outlined in its Electricity Emergency Plan (EEP). Lodi restores vital loads first, before the restoration of non-vital loads. During and following wildfire conditions the WMP also discusses how the system will be inspected for visual damage and hazards prior to energization. 3.1.5 Metrics & Plan Monitoring PUC Section 8387 (A) An accounting of the responsibilities of persons responsible for executing the plan. (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. (E) A discussion of how the application of previously identified metrics to previous wildfire mitigation plan performances has informed the wildfire mitigation plan. (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. (iii) Monitor and audit the effectiveness of electrical line and equipment inspections, including inspections performed by contractors, that are carried out under the plan, other applicable statutes, or commission rules. 3.1.5.1 Responsibilities of Persons Responsible for Executing the Plan Section III.A, and to a lesser extent Section III.B, identify the organization of LEU within the City of Lodi and identifies those responsible for the execution of the activities detailed in the plan. 3.1.5.2 Metrics This section provides an assessment of the proposed metrics in Section VIII.A of LEU’s WMP. The metrics are intended to result in measurable, tracked results illustrating the efficacy of the Plan through to successful implementation. Tracking these metrics will also inform appropriate revisions and updates to Wildfire Mitigation Plan Independent Evaluation Page 13 ©2019 Guidehouse Inc. the Plan in future years. There are no set standards for metric development as they remain unique to a utility’s approach in fire prevention and Plan execution. The statutory requirements for the inclusion of metrics are found in PUC Section 8387(b)(2)(D) and (E) where utilities are directed to present these metrics and address how prior metrics impact the proposed metrics for the next version of the Plan. The four proposed metrics in LEU’s 2019 WMP (shown in Table 5 below) serve as LEU’s first version, providing no previous metrics with which to compare. This metrics represent LEU’s approach to track fire ignitions related to its electrical infrastructure and to track the progress of its vegetation management and inspection programs. The underlying assumptions suggest that monitoring the frequency and cause of ignition events as well as the status of its programs will shape the direction of mitigation strategies as this information is collected and analyzed. These proposed metrics meet the statutory requirements and will assist in providing insight on the effectiveness of the Plan in future years. Table 2: LEU Proposed Metrics Specific metric Indicator Measure of effectiveness Criteria Wire down events Count of events No material increase Any instance where an electric transmission or primary distribution conductor falls to the ground or on a foreign object Fire ignitions Count of events No material increase (1) LEU facility was associated with origin of the fire (2) Fire was self-propagating and of a material other than electrical and/or communication facilities (3) Resulting fire traveled greater than one linear meter from ignition point (4) LEU has knowledge fire occurred Inspection-cycle completion % grid completion 100% complete per GO 165 timelines LEU service territory is divided into 66 smaller grids and each grid is inspected per the GO 165 timeline Vegetation management cycle completion % grid completion 100% complete every 18-24 months LEU service territory is divided into 66 smaller grids and the vegetation near LEU assets is trimmed, removed, or managed in each grid every 18-24 months 3.1.5.3 Monitoring and Auditing the Plan LEU plans to present its WMP to the Lodi City Council on an annual basis and have an independent evaluator review the Plan. LEU also plans to have its Operations Division internally audit its WMP and record the findings and corrective actions. In addition, LEU will monitor the effectiveness of its asset inspections through its Computer Maintenance Management System, which tracks issues and deficiencies identified during the inspections and ensures they are addressed. The details of these efforts are described in Section VIII.B-E. 3.1.5.4 Annual Review The WMP will be reviewed at least annually. The review will include assessments of the WMP’s programs and performance. As part of this process LEU will monitor and audit the implementation of the WMP, identify and correct deficiencies, and monitor and audit the effectiveness of electrical line and equipment inspections, including inspections carried out by contractors. The findings of these audits will be presented at a public meeting of the Lodi City Council in accordance with Section VI. of the WMP. Wildfire Mitigation Plan Independent Evaluation Page 14 ©2019 Guidehouse Inc. 4. RESULTS & DISCUSSION Navigant concluded this assessment on November 12, 2019. Over the course of reviewing LEU’s WMP and supporting documentation, Navigant captured takeaways and findings that align the Plan with state laws and effective wildfire measure demonstration. LEU’s Plan appropriately responds to each of the required elements of PUC Section 8387, which is detailed in Appendix A. The following describes the assessment and resulting findings of the Plan’s proposed and established mitigation measures as it applies to safe, reliable operation of all electric infrastructure and wildfire prevention and response. Report Conclusions After internal review of the latest version of the WMP and associated data collection products, Navigant concludes this Report with the following: 1. LEU’s WMP aligns appropriately with PUC Section 8387 and includes all required elements.8 2. LEU’s Plan is determined to be comprehensive as described through this Report for an electric utility operating completely within Tier 1 fire risk areas. 8 Following acceptance of this Report, LEU will post the Report and results online for public view. The Report is scheduled for presentation to the City Council at a public meeting in November 2019. Accomplishing these follow-up tasks will meet all required statutory provisions up until presenting the final WMP to the City Council. Wildfire Mitigation Plan Independent Evaluation Page 15 ©2019 Guidehouse Inc. APPENDIX A. STATUTORY COMPLIANCE MATRIX Required Statutory Element Plan Section Reference(s) LEU Plan Elements (Summarized) Meets Section Elements (Determination ) (a) Each local publicly owned electric utility and electrical cooperative shall construct, maintain, and operate its electrical lines and equipment in a manner that will minimize the risk of wildfire posed by those electrical lines and equipment. (b) (1) The local publicly owned electric utility or electrical cooperative shall, before January 1, 2020, prepare a wildfire mitigation plan. After January 1, 2020, a local publicly owned electric utility or electrical cooperative shall prepare a wildfire mitigation plan annually and shall submit the plan to the California Wildfire Safety Advisory Board on or before July 1 of that calendar year. Each local publicly owned electric utility and electrical cooperative shall update its plan annually and submit the update to the California Wildfire Safety Advisory Board by July 1 of each year. At least once every three years, the submission shall be a comprehensive revision of the plan. (2) The wildfire mitigation plan shall consider as necessary, at minimum, all of the following: (A) An accounting of the responsibilities of persons responsible for executing the plan. Section III A, B & C, pp. 5-6 LEU has a Roles and Responsibilities section in its plan with descriptions of the roles of the Electric Utility Director, Engineering and Operations Manager, and Electric Superintendent as well as each City Department. While the Plan identifies the Fire Chief as the person responsible for implementing the Incident Command Structure protocols, the identification of other roles with respect to the Incident Command Structure during a potential wildfire emergency may be helpful. Yes Wildfire Mitigation Plan Independent Evaluation Page 16 ©2019 Guidehouse Inc. (B) The objectives of the wildfire mitigation plan. Section II, p. 4 LEU has clearly stated objectives in its plan. LEU’s primary objective refers to reducing, eliminating, minimizing or mitigating the risk of wildfires caused by or exacerbated by the entity’s electrical system. The secondary goal of improving system resilience in the context of wildfire risk is also a valid objective. Yes (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 V, pp. 14-19 Section V provides a detailed description of LEU’s preventative strategies with specific subsections on its low-risk service territory, weather monitoring, design and construction standards, vegetation management and maintenance and inspection. LEU also states that it has not identified any direct impacts on its territory from dynamic climate change risks. Yes (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 VIII A, p. 21 The four metrics identified represent measurements of WMP effectiveness, including metrics that track wires down, fire ignitions, the completion rate of its inspection, and vegetation management cycles. Yes (E) A discussion of how the application of previously identified metrics to previous wildfire mitigation plan performances has informed the wildfire mitigation plan. Section VIII B, p. 21 As with many other WMPs prepared for 2020, LEU’s plan does not discuss the impact of previous metrics because those metrics have not been monitored and there was no previous wildfire mitigation plan to assess performance. The Plan clearly states LEU has not monitored these metrics in the past. Yes (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 those protocols, including impacts on critical first responders and on health and communication infrastructure. Section V F & G, pp. 18-19 A section on reclosers is included in the plan and clearly states that LEU does not currently have a protocol for blocking the reclosing of lines because it is in a low risk area and it would have significant adverse impacts on customers. Similarly, de-energization is not being implemented by LEU at this time and the discussions and justification are explained in detail. LEU will review this decision in the future iterations of the Plan. Yes Wildfire Mitigation Plan Independent Evaluation Page 17 ©2019 Guidehouse Inc. (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 III E, p. 11 While LEU’s stated policy is NOT performing de-energization, it would use the communication procedures noted in Section III.E to notify customers. Yes (H) Plans for vegetation management. Section V-D, pp. 14-16 Details of tree trimming activities are adequate and include minimum distances and frequency of vegetation work. LEU may wish to consider appending additional vegetation management program details. Yes (I) Plans for inspections of the local publicly owned electric utility’s or electrical cooperative’s electrical infrastructure. Section V-E, pp. 16-18 LEU’s Plan states that it meets or exceeds the inspection cycles and requirements provided in GO 95 and 165. LEU may wish to consider appending additional vegetation management program details. Yes (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: Section IV A & B, pp. 10-13 In general, this section identifies LEU’s risk and risk drivers and addresses the topics of design, operation, and construction, as well as topographic and climatological risk factors. Yes (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. Section IV A & B, pp. 10-13 LEU states that specific risks from these risk-drivers include increased vegetation mortality, contributing dry- fuels to the region, as well as vegetation in a weakened-state potentially falling into energized lines during high-wind events. Yes (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 IV A & B, pp. 10-13 In general, this section identifies LEU’s risk and risk drivers and addresses the topics of design, operation, and construction as well as topographic and climatological risk factors. Yes Wildfire Mitigation Plan Independent Evaluation Page 18 ©2019 Guidehouse Inc. (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 IV B, pp. 11-12 LEU’s WMP confirms that its system is located completely in a low (tier 1) fire threat zone. LEU states it does not propose changes to the CPUC fire threat map at this time. Yes (L) A methodology for identifying and presenting enterprise wide safety risk and wildfire-related risk. Section IV B, pp. 11-12 LEU includes a map overlay exercise as its methodology to identify and present wildfire-related risk. LEU should consider adding a formal risk assessment process to identify and present enterprise safety and wildfire- related risks. Yes (M) A statement of how the local publicly owned electric utility or electrical cooperative will restore service after a wildfire. Section VII, p. 27 LEU’s Plan provides a statement of how it plans to restore service after a wildfire, including a discussion of efforts to inspect the condition of the system prior to energization. Yes (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. Section VIII C, D & E, pp. 21-22 LEU states it will conduct both internal and external (independent) audits of the plan to identify deficiencies. LEU has stated that the Electric Utility Director is responsible for the internal review and audit of the plan as well as the identification and tracking of deficiencies in the WMP’s implementation and direct corrective actions for any plan or implementation deficiencies identified by LEU, its contractors or any external auditing parties. LEU also plans to monitor and audit the implementation of the plan by evaluating the progress of its vegetation management and inspection programs. LEU could expand upon this by instituting monthly or quarterly assessments that track LEU investments and activities proposed in the plan or directed to minimize wildfire risks. Yes Wildfire Mitigation Plan Independent Evaluation Page 19 ©2019 Guidehouse Inc. (ii) Identify any deficiencies in the wildfire mitigation plan or its implementation, and correct those deficiencies. Section VIII C, D & E, pp. 21-22 LEU has stated that the Electric Utility Director is responsible for the internal review and audit of the plan as well as the identification and tracking of deficiencies in the WMP’s implementation and direct corrective actions for any plan or implementation deficiencies identified by LEU, its contractors or any external auditing parties. Yes (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. Section VIII C, D & E, pp. 21-22 LEU also plans to monitor and audit the effectiveness of its vegetation management and inspection programs through two of the metrics it has established in its Plan. LEU could expand upon this by instituting monthly or quarterly assessments that track LEU investments and activities proposed in the plan or directed to minimize wildfire risks. Yes (3) The local publicly owned electric utility or electrical cooperative shall, on or before January 1, 2020, and not less than annually thereafter, present its wildfire mitigation plan in an appropriately noticed public meeting. The local publicly owned electric utility or electrical cooperative shall accept comments on its wildfire mitigation plan from the public, other local and state agencies, and interested parties, and shall verify that the wildfire mitigation plan complies with all applicable rules, regulations, and standards, as appropriate. Section VIII LEU will present its WMP to the City Council at a public meeting in November 2019. Yes (c) The local publicly owned electric utility or electrical cooperative shall contract with a qualified independent evaluator with experience in assessing the safe operation of electrical infrastructure to review and assess the comprehensiveness of its wildfire mitigation plan. The independent evaluator shall issue a report that shall be made available on the internet website of the local publicly owned electric utility or electrical cooperative, and shall present the report at a public meeting of the local publicly owned electric utility’s or electrical cooperative’s governing board. Section IX LEU contracted with Navigant Consulting, Inc. to perform an independent evaluation of its WMP. Qualifications are described in Section 1. Yes