HomeMy WebLinkAboutAgenda Report - December 22, 2020 B-03AGENDA ITEM
3,103
CITY OF LODI
COUNCIL COMMUNICATION
TM
AGENDA TITLE: Adopt Resolution Accepting Lodi Electric Utility's 2020 Wildfire Mitigation Plan
MEETING DATE: December 22, 2020
PREPARED BY: Electric Utility Director
RECOMMENDED ACTION: Adopt a resolution accepting Lodi Electric Utility's 2020 Wildfire
Mitigation Plan.
BACKGROUND INFORMATION: In 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. The intent of this submittal is to meet this
annual regulatory requirement.
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 inaugural WMP. Staff's draft plan was then audited by a
Council authorized and CPUC approved independent third -party auditor. The auditor found LEU's 2019
WMP was both comprehensive and in compliance with S13-901. The auditor presented their report along
with LEU's 2019 WMP to Council, on November 20, 2019. Council subsequently approved LEU's WMP
in Resolution 2019-247. As required by SB 901, LEU has now concluded its first annual update to LEU's
WMP, incorporating the most recent information on staffing -levels, infrastructure status, vegetation
management progress, wire -down metrics and other statistics and information collected in the past year.
LEU respectfully submits this 2020 WMP update to Council for acceptance.
FISCAL IMPACT:
FUNDING AVAILABLE
Not applicable.
Not applicable.
_"M J- 4*,
rewmann
PREPARED BY: Tim Conn, Sr. Power Engineer
APPROVED:
Jeff Berkheimer
Electric Utility Director
uer Xity Manager
LODI ELECTRIC UTILITY
WILDFIRE
MITIGATION
PLAN
VERSION 2.0
December 08, 2020
TABLE OF CONTENTS
RevisionLog, Key Changes.............................................................................................................................4
I.
Overview.................................................................................................................................................5
A.
Policy Statement...................................................................................................................................5
B.
Purpose of the Wildfire Mitigation Plan.............................................................................................5
C.
Background............................................................................................................................................6
D.
Organization of the Wildfire Mitigation Plan....................................................................................7
II.
Objectives of the Wildfire Mitigation Plan........................................................................................7
III.
Roles and Responsibilities.....................................................................................................................8
A.
Utility Governance Structure...............................................................................................................8
B.
Wildfire Prevention................................................................................................................................9
C.
Wildfire Response and Recovery.....................................................................................................10
D.
Coordination with Water Utility and Public Safety........................................................................12
E.
Coordination with Communication Infrastructure Providers......................................................13
F.
Standardized Emergency Management System.........................................................................13
IV.
Wildfire Risks and Drivers Associated with Design, Construction, Operation, and
Maintenance.......................................................................................................................................14
A.
Particular Risks and Risk Drivers Associated with Topographic and Climatological Risk
Factors...................................................................................................................................................14
B.
Enterprisewide Safety Risks................................................................................................................15
C.
Changes to CPUC Fire Threat Map.................................................................................................17
V.
Wildfire Preventative Strategies........................................................................................................18
A.
High Fire Threat District.......................................................................................................................18
B.
Weather Monitoring............................................................................................................................18
C.
Design and Construction Standards...............................................................................................19
D.
Vegetation Management.................................................................................................................20
E.
System Maintenance and Inspections............................................................................................22
F.
Reclosing Policy...................................................................................................................................24
G.
De-energization...................................................................................................................................24
VI.
Community Outreach and Public Awareness..............................................................................26
VII.
Restoration of Service.........................................................................................................................26
VIII.
Evaluation of the Plan........................................................................................................................27
A.
Metrics and Assumptions For Measuring Plan Performance.......................................................27
Metric1: Fire Ignitions..............................................................................................................................27
Metric2: Wires Down...............................................................................................................................27
Metric 3: Inspection -Cycle Completion..............................................................................................28
Metric 4: Vegetation -Management Cycle Completion..................................................................28
B.
Impact of Metrics on Plan.................................................................................................................28
C.
Monitoring and Auditing the Plan....................................................................................................29
D.
Identifying and Correcting Deficiencies in the Plan....................................................................29
E.
Monitoring the Effectiveness of Inspections...................................................................................29
IX.
Independent Auditor..........................................................................................................................31
X.
Cross References to SB -901 Requirements.....................................................................................31
late of Change
Location
Description10/23/2020
Sec. III -C
Updated with current staffing levels
10/23/2020
Sec. III -E
Updated infrastructure status
10/23/2020
Sec. IV -B
Eliminated redundant map
Updated with latest vegetation crew information and
10/23/2020 Sec. V -C
adding tree -inventory
Expanded list with additional de-energization
11/10/2020
Sec. V. G
consequences
10/23/2020
Sec. V -D
j Added details of in -progress tree inventory
10/23/2020
Sec. VI
Replaced projected progress with dates of council
L
presentations and other events which have since
I occurred
12/7/2020
Sec. VIII
Updated metrics
11/10/2020
Sec. IX
Replaced planned Audit with actual Audit dates and
findings and other updates subsequent to prior year's
plan.
Lodi Electric Utility Wildfire Mitigation Plan
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0
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 Map I. 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
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 sanioaquin (05/22/2019)
Lodi Electric Utility Wildfire Mitigation Plan
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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-2017101 2-story.html
Lodi Electric Utility Wildfire Mitigation Plan
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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.
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 this plan, LEU continues to assess and implement new industry practices and
technologies that 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
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7
A. UTILITY GOVERNANCE STRUCTURE
Citizens of Lodi
Lodi City
Council
Operations
Division
Engineering
Division
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:
Lodi Electric Utility Wildfire Mitigation Plan
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December 08, 2020
N.
Lodi City 0 Oversight and approval of Wildfire Mitigation Plan
Council:
City Manager: 0 Oversight responsibility for the underlying departments
Electric Utility 0 Management of the Electric Utility
Director: 0 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 0 Management of the water system (including ensuring adequate
Director: 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. Overall condition of City's Parks (including vegetation
Director: management and fuel removal)
Engineering &
0
Management of Engineering Division
Operations
0
Design practices
Manager:
•
Specifications
•
Standards
•
Management of Operations Division
•
Utility Mapping
Electric
0
Management of Substation Division
Superintendent:
0
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
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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.
As of October 2020 the City's Fire Department is staffed with 54 personnel, including 48 line staff.
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
ranking places Lodi, in the top 95 percent of the ISO's fire -mitigation effectiveness rankings,
5 http://www.iso.com/isoPassportHelp/reading loc ppc reports.htm
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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
Countrywide
14,000 9,214
4,000
$' 6,991 6,964
7,000 6,501
6,000
5,000
4,000 3,490
3.000
2,94T
2,000 1.597 1,359 1.094
1,000 348 0 472 F
Cl 0.
Class Class Class Glass Glass Glass Class Class Class Class Class
1 2 3 4 5 6 7 S 8B 9 10
Source:
httos://www.isomitiaation.com
pc/proara m-works/facts-a nd
fiaures-about-ooc-codes-
around-the-count
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.?
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
(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.
6 City of Lodi, General Plan, 4/2010 § 3.3
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
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"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.
For 2020, the Police Department has budgeted 109 full-time employees, comprised of 77 sworn
officers, 32 support staff, and various additional 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.1120
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
car accidents). While Lodi's Police Department requests assistance from LEU less often, the
same communication channels and access exist and are available.
16 City of Lodi, City Council meeting, June -19 2019, Agenda Item C-1 1
17 City of Lodi, General Plan, 4/2010 § 3.3
18 PD provided info, 10/2020
19 City of Lodi, General Plan, 4/2010 § 8.5
20 City of Lodi, General Plan, 4/2010 § 8.5
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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 recently implemented a reverse -91 1 system, whereby emergency personnel can
send an emergency notification message to area cell -phones, land -lines, and VOIP
phones.
• 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.
(2) "Local government level" manages and coordinates the overall emergency response and
recovery activities within their jurisdiction.
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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.
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:
• Extended drought
• High winds
(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.
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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
Wildland areas where exposure to overhead power lines, the availability of water
Tier 3
Extre
resources, and emergency responder circulation routes affect response times to
combat wildland fires.
Elevated risk due to vegetation, high voltage regional transmission lines crossing
Tier 2
Elevated
the area, and adjacency to Tier 3 fire threat zones.
Tier 1
Low
Well-developed areas, typically with underground high voltage circuitry.
Exhibit - 1
Lodi Electric Utility Wildfire Mitigation Plan
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15
Overlay of LEU's service territory over the CPUC fire threat map
CPUC Fire -Threat Map
Adopted by CPUC January 1% 2016
The data -portrayed in the CPUC Fire -Threat Map—m developed under Rukemaking 15 -05 -one,
fallowing procedures in Decision (D.)17-o1-oog, reaised by D.17 -.6.1x4, which adopted a work plan for
the deveolopment of a mitiry High FileThreatDismct IH FTD) far application of enhanced fire safety
mgulaa ns. The aforementioned decisions.rdered that the HFTD he mmpnsed of— individual map
products. One of those map products is this CPUC Fire -Threat Map -The CPUC Fire.Threat Map depicts
` are as where enhanced fire safetyregulations found in Decision 17-11-014wl1spry. The final CPUC Fire
Threat Map was snhmitted m the Commission via a Tier, Advice Letter that was adopted by the
Commision's Safety and Enforcement Division (SLD) with a disposhian letter on January 1g, 1111. All
data and infoimatiln portrayed on the tPut FireThreat Map are for the expressed usP. c.,.d ovt In
017a2m 4, and anyotheruse ofthis map are not the responsibility or endorsed bythe ro.mmnaian nr
ins supporting independent RevlewTeam.
Fire -Threat Areas
i}
Tier a - Elevated
Tier 3 - Extreme
Counties
C I TNF LO
v
`�0 15 30 60 90 120
` Miles
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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).
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1
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/e merge ncy_prepared ness/natural-disaster/wildfires/psps-weather-
map page?WT.mc id=Vanity weather
25 https://www.pge.com/en US/safety/e merge ncy_prepared ness/natural-disaster/wildfires/psps-event-
maps.page
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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
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D. VEGETATION MANAGEMENT
LEU strives to meet or exceed 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.
-
Appendix E, Guidelines 35
The radial clearances shown below are recommended minimum clearances that should be
• 95,
Rule 35, Table
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
Case
Type of Clearance
Trolley
Supply
Supply
Supply
applicable to State Responsibility Area lands pursuant to Public Resource Code Sections
4102 and 4293.
Contact,
Conductors
Conductors
Conductors
more volts, but less than 72,000 volts
Feeder and
and Supply
and Supply
and Supply
Radial clearances for any conductor of a line operating at 1 10,000 orI
10 feet
Span Wires, 0-
Cables, 750 -
Cables, 22.5
Cables, 300 -
5kv
22,500 Volts
- 300 kV
550 kV (mm)
13
Radial clearance of
18 inches
18 inches
'/4 Pin
'/2 Pin
bare line conductors
Spacing
Spacing
from tree branches
or foliage
14
Radial clearance of
18 inches
48 inches
48 inches
120 inches
bare line conductors
from vegetation in
the Fire -Threat District
-
Appendix E, Guidelines 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
4 feet I
more volts, but less than 72,000 volts
Radial clearances for any conductor of a line operating at 72,000 or
6 feet
more volts, but less than 1 10,000 volts
Radial clearances for any conductor of a line operating at 1 10,000 orI
10 feet
more volts, but less than 300,000 volts
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Radial clearances for any conductor of a line operating at 300,000 or 15 feet
more volts
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
Primary
Sub -Transmission /
Voltage
Voltage
Transmission Voltage
<_ 600V
12 kV LL
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 averages two dedicated tree crews throughout the year; LEU's tree contractor has
over 900 employees28, and offers the ability to greatly scale -up the number of crews 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/
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• LEU is currently collecting a detailed tree inventory of all trees in proximity to power lines,
collecting: species, height, GPS coordinates, imagery, health, condition, and trimming
priority. LEU anticipates this survey to be completed 12/31/2020;
• 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.
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General Order 165
Table 1 -- Distribution Inspection Cycles (Maximum Intervals in Years)
L��''.111I�L'IGIIW.'r'.111IVL'IGIIW.'r'.111IVL'IGII
Transformers * +
,Overhead 1121 ��
Underground ����
Padmounted F1 F2
Switch inb/Protective Devices
Overhead
�
21 ���—
Underground
F���
Padmounted
FF2—
F5�
Re lato s/Capacitors
Overhead
F1 --F2
1
��
Underground
F1
Padmounted
Fl--F2--F5--F
Overhead Conductor and Cables F121 I5 I' F --—F-
-F--
I1 12 Ix lx
Wood Poles under 15 years �F2 x
----
Wood Poles over 15 years which have not been 1 2 Fx
F
F
10
subject to intrusive inspection
Wood poles which passed intrusive inspection F-- --- F----— F ----—F20 �O
(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.
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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 precautionary wildfire prevention 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 is not
adopting specific protocols for doing so. LEU will re-evaluate this determination in future
updates to this Wildfire Mitigation Plan. This decision is in-line with various other utilities, including
Los Angeles Department of Water and Power (LADWP)30
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
30 LADWP Wildfire Mitigation Plan Ver. 1.1, April 17, 2020, section 4.7, pages 30, 34
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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, electric wheelchairs, and other battery -powered
objects are unable to charge during loss -of -power.
• During an evacuation or other emergency, turning off the power to streetlights, gas
pumps, elevators and other equipment can compound the severity.
• During Northern California's 2017 wildfires, five persons died, unable to open their
garage -doors after loss of power31
• 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
31 https://www.sacbee.com/news/politics-government/capitol-alert/article2l8811560.html
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outage with an instantaneous restoration, this methodical inspection process can be
very lengthy and increases each of the above impacts.
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.
LEU presented the draft version of this plan to the Lodi City Council and the public during the
October 15, 2019 Council meeting and the final version of the inaugural plan at the November
20, 2019 Council meeting. In addition to having provided continuous public access to this
document on LEU's homepage, LEU will present an annual review and revision to the Lodi City
Council for 2021. As detailed further in Section IX, LEU contracted with an independent third
party to perform an audit of this Wildfire Mitigation Plan. The audit findings were presented to the
Lodi City Council at a public meeting, giving the general public an opportunity to provide
comments. LEU also posted the plan and auditor's findings on LEU's website
www.lodielectric.com and made both available for public review and comment.
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.
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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 fire32;
• 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.
In 2020, LEU had zero known events meeting the above criteria33 34
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.
32 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.
33 Data per LEU Operations, 1 1 /20/2020.
34 At least one known fire grew to involve LEU assets (outage 57-20), however, the fire was started by a
homeless person and was not utility -caused. This incident and possibly others, were not counted in this
year's metric, as their external origin did not meet the defined criteria, nor the intention of this metric.
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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.
In 2020, LEU had one such documented event meeting this criteria (outage No. 83-20), due to
the failure of a hot-tap.35
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. For Urban utilities, GO -165 provides a maximum detailed -inspection
cycle of 5 -years for overhead, underground and padmounted infrastructure. LEU has decided
to prioritize detailed overhead inspections ahead of underground & padmounted inspections.
LEU is approximately 55% complete with its overhead 5 -year inspection cycle. Upon completion
of the overhead inspections, LEU will embark on the underground and padmounted inspections,
therefore at present LEU is 0% complete these latter inspections.
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.
To satisfy the above stated targets, LEU would normally complete vegetation management in
approximately 50 - 66% of the system grids each year. In the past year, however, LEU increased
and accelerated its efforts on vegetation management; resulting in an increase in the number
of vegetation crews and a substantial increase in utility -spend. As a result of this increased
effort, as of November 2020, LEU successfully completed vegetation management in 10017o of its
system grids in the prior 12 months.
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. With LEU's Wildfire Mitigation Plan having been in-
place for approximately one year, metric gathering provides no other data points for
35 Data per LEU Operations, 11 /20/2020.
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comparison. LEU anticipates that as the data collection history becomes more robust, LEU may
be able to identify areas of its operations and service territory that are disproportionately
impacted and may be better positioned to evaluate potential improvements to the plan.
C. MONITORING AND AUDITING THE PLAN
The inaugural version of this Wildfire Mitigation Plan was presented to the Lodi City Council, and
LEU will present updates to this plan to the Lodi City Council on an annual basis. Additionally, a
qualified independent evaluator has evaluated the plan and presented a report on their
findings to the Lodi City Council. Key findings include (emphasis added):
• "LEU's Plan appropriately responds to each of the required elements of PUC Section
8387."36
• "After internal review of the latest version of the WMP and associated data collection
products, Navigant concludes this Report with the following: 1. LED'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.1137
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.
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.0 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
36 Page -14, Navigant, 2019, "Wildfire Mitigation Plan Independent Evaluation"
37 Page -14, Navigant, 2019, "Wildfire Mitigation Plan Independent Evaluation"
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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.
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Public Utilities Code section 8387(c) required 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 which is posted to Lodi Electric Utility's website and presented to the Lodi City
Council at a public meeting.
LEU is a member of the Northern California Power Agency (NCPA). In 2019, LEU leveraged the
expertise of NCPA in selecting and engaging an independent evaluator (Navigant) as required
in PUC Section 8387(c). Navigant performed an audit of LEU's Wildfire Mitigation Plan and was
given the opportunity to audit the LEU processes as necessary to complete the audit. Following
the completion of their audit, Navigant briefed relevant LEU staff and prepared a written report
of its findings. In November of 2019, Navigant provided its Independent Evaluation report, which
LEU made available to the public at the November 2020 Council meeting; the Wildfire Mitigation
Plan and Navigant report were also made available to the public on LEU's website where they
have remained continuously since their completion. Key findings include (emphasis added):
• "LEU's Plan appropriately responds to each of the required elements of PUC Section
8387."38
• "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."39
All records associated with these audits shall be retained by LEU for at least five years.
38 Page -14, Navigant, 2019, "Wildfire Mitigation Plan Independent Evaluation"
39 Page -14, Navigant, 2019, "Wildfire Mitigation Plan Independent Evaluation"
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Lodi Electric Utility Wildfire Mitigation Plan
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PUC § 8387(b)(2)(C): A description of the preventive strategies
and programs to be adopted by the local publicly owned
Preventive
electric utility or electrical cooperative to minimize the risk of
Section V
Strategies
its electrical lines and equipment causing catastrophic wildfires,
including consideration of dynamic climate change risks.
PUC § 8387(b)(2)(D): A description of the metrics the local
Evaluation
publicly owned electric utility or electrical cooperative plans
Metrics
to use to evaluate the wildfire mitigation plan's performance
Section VIIIA
and the assumptions that underlie the use of those metrics.
PUC § 8387(b)(2)(E): A discussion of how the application of
Impact of
previously identified metrics to previous wildfire mitigation
Section VIII.B
Metrics
plan performances has informed the wildfire mitigation plan.
PUC § 8387(b)(2)(F): Protocols for disabling reclosers and
deenergizing portions of the electrical distribution system that
Deenergization
consider the associated impacts on public safety, as well as
Section V.F
Protocols
protocols related to mitigating the public safety impacts of
Section V.G
those protocols, including impacts on critical first responders
and on health and communication infrastructure.
PUC § 8387(b)(2)(G): Appropriate and feasible procedures for
a customer who may be impacted by the
Section 111.1)notifying
Customer
deenergizing of electrical lines. The procedures shall consider
Section III.E
Notification
the need to notify, as a priority, critical first responders, health
Section III.F
Procedures
care facilities, and operators of telecommunications
Section V.G
infrastructure.
Vegetation
PUC § 8387(b)(2)(H): Plans for vegetation management.
I
Section V.D
Management
PUC § 8387(b)(2)(1): Plans for inspections of the local publicly
Inspections
owned electric utility's or electrical cooperative's electrical
Section V.E
infrastructure.
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:
Prioritization of
(i) Risks and risk drivers associated with design, construction,
Section IV.A
Wildfire Risks
operation, and maintenance of the local publicly owned electric
Section IV.B
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.
Lodi Electric Utility Wildfire Mitigation Plan
Version 2.0
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Lodi Electric Utility Wildfire Mitigation Plan
Version 2.0
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PUC § 8387(b)(2)(K): Identification of any geographic area in
the local publicly owned electric utility's or electrical
CPUC Fire
cooperative's service territory that is a higher wildfire threat
Threat Map
than is identified in a commission fire threat map, and
Section IV.0
Adjustments
identification of where the commission should expand a high
fire threat district based on new information or changes to the
environment.
Enterprisewide
PUC § 8387(b)(2)(L): A methodology for identifying and
Risks
presenting enterprisewide safety risk and wildfire-related risk.
Section IV.B
Restoration of
PUC § 8387(b)(2)(M): A statement of how the local publicly
Service
owned electric utility or electrical cooperative will restore
Section VII
service after a wildfire.
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.
Monitor and
(ii) Identify any deficiencies in the wildfire mitigation plan or its
Audit
implementation, and correct those deficiencies.
Section VIII.0-E
(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.
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
Qualified
comprehensiveness of its wildfire mitigation plan. The
Independent
independent evaluator shall issue a report that shall be made
Section IX
Evaluator
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.
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Information NOT•
•1
Location in POU Template
Template Topic
Policy Statement
Section LA
Purpose of the Plan
Section LB I
Background
Section LC I
Organization of the Plan
Section LD I
Coordination with water utilities
Section III.D
Coordination with communication companies
Section III.E
Standardized Emergency Management Systems
Section 1111
High Fire Threat District
Section V.A
Weather Monitoring
Section V.B
Design and Construction
Section V.0
Community Outreach
Section VI
Lodi Electric Utility Wildfire Mitigation Plan
Version 2.0
December 08, 2020
RESOLUTION NO. 2020-306
A RESOLUTION OF THE LODI CITY COUNCIL ACCEPTING
LODI ELECTRIC UTILITY'S 2020 WILDFIRE MITIGATION PLAN
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WHEREAS, in September 2018, California adopted SB 901, amending Public Utilities
Commission Code Section 8387 to require publicly -owned electric utilities to create a Wildfire
Mitigation Plan (WMP); and
WHEREAS, Lodi Electric Utility (LEU) solicited input from various entities and
stakeholders and discussed a draft plan with City Council and the public on October 15, 2019;
and
WHEREAS, a CPUC -approved independent third -party auditor reviewed the plan, and
provided its report to Council on November 20, 2019, concluding that LEU's 2019 WMP is in
compliance with SB 901; and
WHEREAS, Lodi City Council approved of LEU's 2019 WMP by adoption of Resolution
No. 2019-24; and
WHEREAS, SB 901 requires annual updates to the WMP, which LEU has now completed.
NOW, THEREFORE, BE IT RESOLVED that the Lodi City Council does hereby accept
the Lodi Electric Utility 2020 Wildfire Mitigation Plan.
Dated: December 22, 2020
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I hereby certify that Resolution No. 2020-306 was passed and adopted by the City Council
of the City of Lodi in a special meeting held on December 22, 2019 by the following vote:
AYES: COUNCIL MEMBERS — Chandler, Kuehne, and Mayor Nakanishi
NOES: COUNCIL MEMBERS — None
ABSENT: COUNCIL MEMBERS — Hothi and Khan
ABSTAIN: COUNCIL MEMBERS — None
JENNIFE CUSMIR
City Clerk