HomeMy WebLinkAboutAgenda Report - November 16, 2022 C-16CITY OF
a i
CALIFORNIA
COUNCIL COMMUNICATION
AGENDA ITEM con Ito
AGENDA TITLE: Adopt Resolution Accepting Lodi Electric Utility's 2022 Wildfire Mitigation Plan
MEETING DATE: November 16, 2022
PREPARED BY: Electric Utility Director
RECOMMENDED ACTION- Adopt a resolution accepting Lodi Electric Utility's 2022 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. Staffs 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 then provided an annual update to Council on 12/22/2020 and on
12/01/2021. Staff has now concluded its third 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. An independent third -party auditor has audited this
update. LEU respectfully submits the 2022 WMP update and the associated audit report to Council for
acceptance.
FISCAL IMPACT:
FUNDING AVAILABLE:
Not applicable
Not applicable
_�A-,
Jeff Berkheimer (Nov 1, 20221630 PDT)
Jeff Berkheimer
Electric Utility Director
APPROVED: Steve Schwabauer
Stephen Schwabauer, City Manager
LODI ELECTRIC UTILITY
WILDFIRE
MITIGATION
PLAN
VERSION 4.0
November 16, 2022
TABLE OF CONTENTS
RevisionLog, Key Changes.............................................................................................................................4
I.
Overview.................................................................................................................................................5
A.
Policy Statement...................................................................................................................................5
B.
Purpose of the Wildfire Mitigation Plan.............................................................................................5
C.
Background............................................................................................................................................5
D.
Overall Risk Profile..................................................................................................................................5
E.
Organization of the Wildfire Mitigation Plan....................................................................................8
II.
Objectives of the Wildfire Mitigation Plan........................................................................................8
III.
Roles and Responsibilities...................................................................................................................10
A.
Utility Governance Structure.............................................................................................................10
B.
Wildfire Prevention..............................................................................................................................12
C.
Wildfire Response and Recovery.....................................................................................................12
D.
Coordination with Water Utility and Public Safety........................................................................14
E.
Coordination with Communication Infrastructure Providers......................................................15
F.
Standardized Emergency Management System.........................................................................15
IV.
Wildfire Risks and Drivers Associated with Design, Construction, Operation, and
Maintenance.......................................................................................................................................16
A.
Particular Risks and Risk Drivers Associated with Topographic and Climatological Risk
Factors...................................................................................................................................................16
B.
Enterprisewide Safety Risks................................................................................................................17
C.
Changes to CPUC Fire Threat Map.................................................................................................20
V.
Wildfire Preventative Strategies........................................................................................................21
A.
High Fire Threat District.......................................................................................................................21
B.
Weather Monitoring............................................................................................................................21
C.
Design and Construction Standards...............................................................................................22
D.
Vegetation Management.................................................................................................................23
E.
System Maintenance and Inspections............................................................................................26
F.
Reclosing Policy...................................................................................................................................28
G.
De-energization...................................................................................................................................29
VI.
Community Outreach and Public Awareness..............................................................................30
VII.
Restoration of Service.........................................................................................................................31
VIII.
Evaluation of the Plan........................................................................................................................32
A.
Metrics and Assumptions For Measuring Plan Performance.......................................................32
Metric1: Fire Ignitions..............................................................................................................................32
Metric2: Wires Down...............................................................................................................................33
Metric 3: Inspection -Cycle Completion..............................................................................................33
Metric 4: Vegetation -Management Cycle Completion..................................................................34
B.
Impact of Metrics on Plan.................................................................................................................35
C.
Monitoring and Auditing the Plan....................................................................................................35
D.
Identifying and Correcting Deficiencies in the Plan....................................................................36
E.
Monitoring the Effectiveness of Inspections...................................................................................36
IX.
Independent Auditor..........................................................................................................................37
X.
Cross References to SB -901 Requirements.....................................................................................38
I.
WSAB Guiadance Advisory Opinion Recommendations...........................................................41
-Jocation Description
12/7/2020 Sec. III C: Updated with current staffing levels
E: Updated infrastructure status
Sec. IV.B Eliminated redundant map
Sec. V C: Updated with latest vegetation crew information and adding
tree -inventory.
D: Added details of in -progress tree inventory
Sec. VI Replaced projected progress with dates of council presentations
and other events which have since occurred
Sec. V.G Expanded list with additional de-energization consequences
Replaced planned Audit with actual Audit dates and findings
Sec. IX and other updates subsequent to prior year's plan
Sec. VIII Updated metrics
11/30/2021 Sec I.D Created new sub. sec. "Risk Profile" & consolidated related info
Sec. VIII Updated all metrics, Clarified reporting dates for metrics
Sec. V.F Updated Reclosing section to include trial device
11/2/2022 Sec. VIII A Updated metrics for last one year.
Lodi Electric Utility Wildfire Mitigation Plan
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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 protect LEU
infrastructure from wildfire impacts and 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.
This Wildfire Mitigation Plan describes the safety-related measures that LEU follows to reduce its
risk of causing wildfires.
C. BACKGROUND
LEU has provided Electric Service to the City of Lodi for over 110 years with 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.
D. OVERALL RISK PROFILE
Wildfire risk is greatly reduced by LEU's topography, setting, and urbanization. LEU is located in a
region of the state with a very low wildfire risk. LEU is entirely situated within the California Public
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Utilities Commission's (CPUC) lowest fire -threat risk -tier (Tier -1) with no part of LEU's service territory
in or near the High Fire Threat District designed in the CPUC's Fire Threat Map I. 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 Map2. The area that is categorized as "moderate" is only approximately 2% of
LEU's service territory primarily along the Mokelumne river. 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"3. 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.
LEU's territory is flat, lacking any mountains, valleys, and similar hard to access locations. The City
of Lodi's General Plan describes LEU's service territory as, "...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."
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.
LEU's Service Territory is limited to a dense urban footprint (approximately 13.7 square miles of
land). With an estimated population of more than 68,000; this results in a density of 5,000
persons per square mile of LEU service -territory; this density is advantages to the Utility as it
provides tremendous visibility on LEU's infrastructure and any problems which arise. Problems
within LEU's territory are therefore generally discovered very quickly. LEU's compact territory also
allows LEU personnel to reach nearly every utility asset within a 10 -minute drive from its
headquarters. The high visibility and close proximity therefore generally result in quick discovery
and quick addressing of problems. This is in stark contrast with utilities having thousands of miles
of line traversing inaccessible areas of California's dry forests, far from urban areas, lacking any
1 Cal Fire Map ID: FTHREAT_MAP, Oct. 20, 2005
2 Cal Fire Map ID: FTHREAT_MAP, Oct. 20, 2005
3 Cal Fire Map ID: FHSZL06_1_MAP, Oct. 02, 2007,
http://www.fire.ca.gov/fire prevention/fhsz maps sanioaquin (05/22/2019)
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
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meaningful public visibility, and with potentially great travel distances required for the Utility and
fire -fighting resources in responding to a problem.
As detailed extensively in the plan below, Lodi is also well-positioned with impressive water
resources and fire -fighting capabilities, making for another stark contrast with utilities traversing
sparse wilderness areas.
Despite LEU's low-risk profile, 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 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.
WSAB Requested Risk Profile Information
im
.. -
Size (Sq Mi.)
- 13.7 Sq. Mi.
Assets
✓ Distribution
✓ Sub -transmission (60 kV)
Note -1: LEU owns shares in generation plants outside of LEU
service territory, managed and operated by NCPA.
Note -2: A 27 MW Peaker-Plant, owned and operated by NCPA,
is found within LEU's service territory
Number of Customers
Approximately 28,000 active accounts, of which approximately
Served
are 22,600 residential accounts, and the balance is divided
between commercial/industrial/misc. Estimated 2021
Population: 68,000+
Customer Classes
✓ Residential
✓ Government
✓ Small/Medium Business
✓ Commercial/Industrial
Location / Topography
Central Valley, approximately 100% urban / Flat
Percent Territory in CPUC
0%
High Fire Threat Districts
CAL FIRE FRAP Map Fire
Non -Fuel
Threat Zones
Existing Grid Hardening
Approximately 50% underground. Overhead hardening
Measures
measures include pole-changeouts, overclassing poles,
reconductoring with steel -reinforced conductors, etc.
Utility Fire Threat Risk Level
Low
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Impacted by Another
No known historical instances
Utility's PSPS?
Mitigates Impact of Other
Not as LEU interprets this question
Utility's PSPS?
Expects to Initiate its own
No
PSPS?
Prevailing Wind Directions
Low
& S eeds by Season
E. 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 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.
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A. UTILITY GOVERNANCE STRUCTURE
Citizens of Lodi
Lodi City
Council
Operations
Division
Engineering
Division
City of Lodi Organization Chart (Excerpt, 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.
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Some of these positions' duties, specific to wildfire mitigation include:
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
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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.
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.
Fire Department staffing fluctuates from time -to -time, but has budgeted approximately 54
personnel, including 48 line staff.
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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,
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
1 Q,000 9,214
9,000
5,000
7,000 6,991 6,964 6.501
6,000
5,000 -
4,000 3,490
3,000 2,947
2,000 1.597 1,559 1,094
1,00 348 _o El .
472
0.
Class Class Class Class Class Class Class Class Class Class Class
1 2 3 4 5 6 7 8 8B 9 10
httr)s://www.isomitiaation.com/p
oc/proaram-works/facts-and-
fiaures-about-in Dc -codes
around -the -country/
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 900 of all calls.?
As of 2021, 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 5 million gallons of water storage, spread
5 htta://www.iso.com/isoPassoortHeID/readina loc Doc reaorts.htm
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 2021
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 2021
12 City of Lodi, Public Works, Annual Water Quality Report For 2021
13 City of Lodi, Public Works, Annual Water Quality Report For 2021
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across different tanks14. 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.
"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." 15 The Library will also serve as a community resource center
during a de-energization event.
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. 16 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.
Police Department staffing fluctuates from time -to -time, but has budgeted approximately 109
full-time employees, comprised of 77 sworn officers, 32 support staff, and various additional
volunteers." 17
"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." 18
"The City provides street standards for all street types, thus ensuring appropriate standards for
emergency access and evacuation." 19
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
14 City of Lodi, General Plan, 4/2010 § 3.3
15 City of Lodi, City Council meeting, June -19 2019, Agenda Item C-1 1
16 City of Lodi, General Plan, 4/2010 § 3.3
17 PD provided info, 10/2020
18 City of Lodi, General Plan, 4/2010 § 8.5
19 City of Lodi, General Plan, 4/2010 § 8.5
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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.
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 -911 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
• LEU has recently implemented an Outage Management System (OMS) and an
Interactive Voice Response (IVR) system, for outage dispatch and notification purposes.
F. STANDARDIZED EMERGENCY MANAGEMENT SYSTEM
As a local governmental agency,20 the City of Lodi has planning, communication, and
coordination obligations pursuant to the California Office of Emergency Services' Standardized
Emergency Management System ("SEMS") Regulations,21 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,
20 As defined in Cal. Gov. Code § 8680.2.
21 19 CCR § 2407.
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operational area, regional, and state.22 Pursuant to this structure, the City of Lodi annually
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
22 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.
(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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Within LEU's service territory and the surrounding areas, the primary risk drivers for wildfire are the
following:
• Extended drought
• High winds
• Low humidity
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.
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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
Overlay of LEU's service territory over the CPUC fire threat map
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" Fi re -Th reat Areas
` Tier a - Elevated
Tier 3 - Extreme
r
Counties
C I T OF LO
?I
w H o 25 30 60 90 3.20
Miles
s
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rw I
r --
19
CPUC Fire -Threat Map
Adopted by CPUC January is, 2018
The data -portrayed in the CP UC Fire -Threat Map we re developed under Rulemaking a5 o5 -ooh,
fodowing procedures in Decision (D.) s7-of-oag, reeised by D.a7-a6-oa4, which adopted a wo rh plan for
-
the development ofa utility High Fire Th re at District(H FT D) for application of enhanced fire safety
regulanans. The aforementioned decisionsorderedthatthe HFTD he comprised oftwo individual map
products. Cer, fth— mappraductsisthis CPUCFire-Threat Map -The CPUC File -Threat Mapdepiets
-
49
area—here enhanced fire safety regulations found in Decision %7-ax-oo4 Will apply, The fjnal CPUC Fire.
Threat map uhmittedto theCommission via aTler a advice tetter that was adopted by the
Commission's Safety and Enforcement Division (SED) wl[h a disposition letter on lenuaryag,a"B. PJI
data and information portrayed on the CPUC Fire.Threat Map are for the expressed use called out in
D. 17aa 4, and any other use ofthis map are not the responsibility or endorsed by the Commission cr
is supporting Independent aeviewTeam.
" Fi re -Th reat Areas
` Tier a - Elevated
Tier 3 - Extreme
r
Counties
C I T OF LO
?I
w H o 25 30 60 90 3.20
Miles
s
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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" website23 (an aggregation of regional PSPS, wind,
temperature, Red -Flag and other information)
• "PG&E PSPS Maps" website24
• National Fire Danger Rating System (NFDRS)
23 https://www.pge.com/en US/safety/e merge ncy_prepared ness/natural-disaster/wildfires/psps-weather-
map page?WT.mc id=Vanity weather
24 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 an unintended object making contact with
energized components and igniting a fire. Examples include: wildlife (snakes, burrowing -
rodents, etc.), 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"25
• New subdivisions and large commercial customers are connected by extending
underground facilities, limiting the creation of additional overhead exposure26
25 Cargill, EnvirotempTm FR3Tm Natural Ester Dielectric Fluid Overview, Page -1
26 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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• LEU is aggressively pursuing the removal of aged small -diameter overhead copper
primary -voltage conductor (specifically, #6CU solid), commonly replacing it with larger
diameter, stranded conductor with a steel core. LEU believes this will provide greater
safety, reliability and minimize lines -down events and in turn, fires associated with them.
LEU anticipates nearly all of this conductor will be removed from the system over the next
5 -years. LEU does not have robust historical data on how much has been removed from
the system to -date, but has the following data -points which are indicative of LEU's efforts:
System Inventory of
Overhead #6CU Conductor 302,400 feet 217,650 feet
(Approx.)
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.
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
areater clearances than those listed below to ensure compliance until the next scheduled
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• 95, Rule 35, Table
Case
Type of Clearance
Trolley
Supply
Supply
Supply
Contact,
Conductors
Conductors
Conductors
Feeder and
and Supply
and Supply
and Supply
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
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
areater clearances than those listed below to ensure compliance until the next scheduled
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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
Radial clearances for any conductor of a line operating at 2,400 or
more volts, but less than 72,000 volts
Radial clearances for any conductor of a line operating at 72,000 or
more volts, but less than 110,000 volts
Radial clearances for any conductor of a line operating at 110,000 or
more volts, but less than 300,000 volts
Radial clearances for any conductor of a line operating at 300,000 or
more volts
Case 13
4 feet
6 feet
10 feet
15 feet
LEU has taken an aggressive approach to vegetation management. As many of the fires which
ravaged the state from 2015-2022 appear to have included contact between power lines and
vegetation, LEU believes that vegetation management is one of the most effective methods to
avoid wildfires.
• LEU has greatly increased its vegetation management efforts in recent years, resulting in
more frequent visits to more locations and better clearances from lines. LEU's 2022
vegetation management budget is now triple its 2020 level. This increased attention to
vegetation is seen in the chart below from 2020, notice the sharp rise following the
increase in LEU's vegetation budget:
Trees Trimmed by Month
350
M
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• Despite the increased cost of doing so, LEU often pursues tree -removals instead of
trimming; this is particularly beneficial for faster growing species which require more
frequent return visits. LEU has setup a program to provide customers who undergo tree
removal, with complimentary starter trees, which will better co -exist in the vicinity of
power lines.
• 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 while still complying with GO -95's proscribed values.
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 employees27, 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.
27 https://westcoastarborists.com/
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Secondary
Voltage
<_ 600V
Primary
Voltage
12 kV LL
Sub -Transmission /
Transmission Voltage
60 kV LL
57
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 employees27, 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.
27 https://westcoastarborists.com/
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• Every tree in proximity of electric infrastructure will be visited every 18 -24 -months, some
even more frequently.
• LEU has surveyed trees in its service territory and collected a detailed tree inventory of all
trees in proximity to power lines, collecting: species, height, GPS coordinates, imagery,
health, condition, and trimming priority.
• 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)
Transformers
,Overhead
Underground
Padmounted
Switch inb /Protective Devices
UrbanRurall Urban Rural urbanRu rail
I1� 21 �I'
I1�IL�IJ�-13
I1 IL I, I'
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
ood Poles under 15 years �F2 x
W
Wood Poles over 15 years which have not been 1 I` x x 10 10
subject to intrusive inspection
Wood poles which passed intrusive inspection � F-- 2
--- �0 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.
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F. RECLOSING POLICY
In contrast with the majority of electric utilities in California, prior to 11/2021, LEU did not have any
traditional reclosers deployed downstream of LEU's substations.
In 11 /2021 LEU completed installation of a single, new type of non -spark emitting protection
device with limited reclosing functionality. This single trial -device was located immediately
behind sidewalk deep within our urban setting, positioned upstream of a circuit -branch,
monitoring various short downstream line -lengths, with trivial vegetation exposure nearly all of
which is within residential private property. This device replaces a traditional spark -emitting fuse
that was formerly at this location, and under standard operation this trial device should never
emit sparks to the ground below. This device is designed to minimize and contain outages on
the lines it monitors downstream, and prevent impacts from spilling -over and affecting other
customers on the circuit. The areas downstream are unlikely to get draped with windblown
vegetation due to urban environment. Prior to the installation of this device, fusing limitations
would have resulted in certain mis-coordinations in the protection scheme, and created circuit -
level outages affecting substantially more customers. One of the critical customers downstream
of this device is a large school. The Utility's belief is that the installation of this device will provide
a net benefit to life -safety by increasing the uptime to this critical customer and in minimizing the
downtime to others in the wider area.
Power outages create serious adverse impacts to life -safety (find examples in Section-V(G) De-
Energization), these impacts increase as outages are extended. Nationwide, momentary -faults
account for greater than 70-80% of all faults28. Policies which disable reclosing functionality,
unnecessarily extend what would otherwise be momentary and self -clearing faults and outages,
and consequently, increase the adverse 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.
The concept of disabling reclosing is predicated on the assumption that a small limited number
of subsequent line -tests could possibly cause a problem not caused by the initial incident. In
most situations (momentary self -clearing faults, urban lines not at risk of starting fires) there is no
harm caused by successive tests, and no safety benefit gained by disabling reclosing, while
there is potential harm caused by not re -powering lines to critical customers.
It is LEU's goal to reduce outages both in count and duration. In determining a policy for
reclosing, LEU has considered its Ione instance of a non-traditional field-recloser, 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
reclosing functionality as a wildfire precautionary measure, and that doing -so would yield hard -
to -identify benefits to wildfire reduction in LEU's territory.
28 Cooper Power Systems, Electrical Distribution System Protection, P.7
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G. DE-ENERGIZATION
While utilities in certain sparsely populated, hard -to -access wildland areas will occasionally
conduct a de-energization (AKA "Public Safety Power Shutoff" or "PSPS"), the decision to do so
in dense urban population centers such as the City of Lodi, introduces greater safety concerns
and other drawbacks.
Some of the serious adverse impacts to life -safety include:
• During Northern California's 2017 wildfires, five persons died, unable to open their
garage -doors after loss of power29
• During an evacuation or other emergency, turning off the power to streetlights, _ gas
Pumps, elevators and other equipment can compound the severity.
• 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.
• Under fire -threat conditions which 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.
• 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 is known to reach triple -digit summertime temperatures. Upon loss of power, certain
vulnerable residents who depend on air conditioning can suffer heat -related medical
issues.
• Critical customers such as hospitals, medical facilities rely on power in performing
emergency life-saving procedures. These customers traditionally have backup
generators, however, there is no guarantee a generator will work. In Jan. 2021 LEU had
first-hand experience with a backup generator failing to start during an outage event.
• Some residential customers' medical conditions require specialized at-home 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
29 https://www.sacbee.com/news/politics-government/capitol-alert/article2l881 1560.html
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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.
• Cell phones, laptops, electric cars, electric wheelchairs, and other battery -powered
objects are unable to charge during loss -of -power.
• 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.
Further, de -energizing lines as a preventative measure to prevent a potential theoretical chain -
of -events of unknown certainty, in the lowest wildfire risk -tier of the state, based largely upon
weather predictions of unknown accuracy, carries the risk of being undertaken unnecessarily.
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. This decision is in-line with various other
utilities, including Los Angeles Department of Water and Power (LADWP)30. LEU will re-evaluate
this determination in future updates to this Wildfire Mitigation Plan.
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. PG&E has never placed LEU's
service lines on the PSPS list for either notification or de-energization. NCPA's backup power
plant located within LEU's service territory can serve critical loads during a loss of power.
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 provided an annual revision to the Lodi City Council in
12/2020 and will continue to do so annually. 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
30 LADWP Wildfire Mitigation Plan Ver. 1.1, April 17, 2020, section 4.7, pages 30, 34
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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.
Due to the non -aligning year-to-year dates for the annual meeting where this plan is presented,
in 2021 LEU added the clarification that metric -reporting for this plan covers the period of
November -1 (prior year) to October -31 (current year).
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.
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.
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11/1/2019 -10/31/2020 I LEU had zero known events meeting the above criteria32 33
11/1/2020 -10/31/2021 LEU had one known incident of fire ignition meeting the above
criteria3a
11/1/2021 -10/31/2022 LEU had two known incident of fire ignition meeting the above
criteria35
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.
11/1/2019 -10/31/2020 LEU had one such documented event meeting this criteria
(outage No. 83-20), due to the failure of a hot-tap.36
11 /1 /2020 - 10/31/2021 LEU had two events meeting this criteria37
11 /1 /2021 - 10/31/2022 LEU had zero known events meeting this criteria
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
32 Data per LEU Operations, 11 /20/2020.
33 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.
34 Data per LEU Operations, 11 /16/2021. This fire is believed to be the result of an overhead transformer
malfunction in an urban location, resulting in a secondary -bushing failure which emitted sparks onto dry
vegetation located on customer -maintained private property.
35 Data per LEU Operations. This fire is believed to be the result of an overhead transformer malfunction in
an urban location, resulting in a secondary -bushing failure which emitted sparks onto dry vegetation
located on customer -maintained private property.
36 Data per LEU Operations, 11 /20/2020.
37 Data per LEU Operations, 11 /16/2021.
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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 will at times shift resources to accelerate or prioritize one category of inspection over
another for strategic purposes (while achieving all required inspection timelines); this has the
result of making the completion percentages of the various cycles uneven.
11/1/2019- Detailed overhead
10/31/2020 (5 -year inspection cycle)
Detailed underground
(5 -year inspection cycle)
Intrusive Overhead
(10/20 -year cycle)
11/1/2020- Detailed overhead
10/31/2021 (5 -year inspection cycle)
Detailed underground
(5 -year inspection cycle)
Intrusive Overhead
(10/20 -year cycle)
11/1/2021 - Detailed overhead
10/31/2022 (5 -year inspection cycle)
Approx. 55%38
Approx. 45%
Detailed underground 100%
(5 -year inspection cycle)
Intrusive Overhead 0%
(10/20 -year cycle)
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
38 Data per LEU Superintendent, 11/16/2021
39 Data per 2021 Osmose inspections
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equal, the metric of percent complete, 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 2020, 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.
11/1/2019 -10/31/2020 100%
11/1/2020 -10/31/2021 66%40
11/1/2021 -10/31/2022 66%
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 a short -duration, metric gathering provides insufficient data points for trending and
comparisons. 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 publicly to the Lodi City
Council. LEU will present plan updates 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.
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.
40 Data per LEU Superintendent, 1 1 /16/2021
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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
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
8387.1141
• "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."42
All records associated with these audits shall be retained by LEU for at least five years.
41 Page -14, Navigant, 2019, "Wildfire Mitigation Plan Independent Evaluation"
42 Page -14, Navigant, 2019, "Wildfire Mitigation Plan Independent Evaluation"
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CROSS 901 REQUIREMENTS
Location in
Requirement
Statutory Language
POU Template
Persons
PUC § 8387(b)(2)(A): An accounting of the responsibilities of
Responsible
persons responsible for executing the plan.
Section III
Objectives of
PUC § 8387(b)(2)(B): The objectives of the wildfire mitigation
the Plan
plan.
Section II
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 VIILB
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.
Management
Section V.D
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.
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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.
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.
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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
Template Topic
Location in POU Template
Policy Statement
Section LA
Purpose of the Plan
Section LB
Background
I Section LC
Risk Profile
Section I.D
Organization of the Plan
Section LE
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.0
Community Outreach
Section VI
The December 2020 California Wildfire Safety Advisory Board (WSAB) Publication, "Guidance
Advisory Opinion for the 2021 Wildfire Mitigation Plans of Electric Publicly Owned Utilities and
Cooperatives" identifies fourteen specific recommendations that POUs are requested to address
in their future WMPs.
As specified in Public Utilities Code § 8387(b) (1), each POU is required to perform a
comprehensive revision to the POU's WMP at least once every three years. Pursuant to this
guidance, the POUs will be updating their WMPs based on the direction of their local governing
boards within this 3 -year cycle. Because the WSAB's recommendations have been provided
after the initial WMP submission, the POUs will have varying capacities to fully address each
recommendation in their subsequent WMP revision cycles.
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This section lists the WSAB's recommendations. For each of these, LEU seeks to do one or more
of the following:
(1) Provide a narrative response to the recommendation
(2) Provide a cross-reference to the section in this WMP where the topic is addressed
(3) Describe why the recommendation is not applicable to LEU
(4) Inform the WSAB of the POU's intent to address the recommendation at the point of the
POU's next comprehensive revision.
WSAB Recommendation - 1: The Board requests that the WMP and Independent Evaluator
Reports be prominently displayed and easily located on the POU websites. To assist the Board
in its review, the WMP could also include an index or table that shows where each section of
the statute is addressed in the WMP.
In the WMP update, the Board hopes to receive context -setting information at the beginning of
each POU plan to help situate the Board's general understanding about each POU and
Cooperative's risk profile in accordance with the statutory requirements. Public Utilities Code
Section 8387(b) (2) details what risks are to be addressed including all wildfire risks, and drivers
for those risks, throughout the service territory such as the utility's grid configuration and
condition, climate threat and geographic location. Without this information, the Board is
unable to provide an individualized response to each filing. The goal would be to provide the
unique utility context in the WMP document up front with the following information:
Size of the utility territory in square miles; ❑ Asset identification including transmission,
distribution, and generation; ❑ Number of customers, which may differ from the number of city
or county residents; ❑ Types of customer classes served; ❑ Location and topography including
percentage urban, wildland, or wildland-urban interface; ❑ Typical prevailing wind directions
and speeds within the territory differentiated by season; ❑ Territory maps with CPUC High Fire
Threat Districts (HFTD) or California Department of Forestry and Fire Protection (CAL FIRE) Fire
and Resource Assessment Program (FRAP) Fire Threat Zones (FTZ) overlaid with distribution and
transmission assets, again, considering the limitations of Federal Infrastructure Protection
Protocols; ❑ Existing system hardening measures installed compared to non -hardened
infrastructure such as 1) miles underground or overhead, 2) number of wooden, steel, or
composite poles, 3) number of wooden, steel, fiberglass, or composite cross arms, and 4) miles
of covered conductor; ❑ Impact on the POU of another utility's Public Safety Power Shutoff
(PSPS) or similar wildfire related de-energization events, existing measures to mitigate the other
utility's PSPS, and whether the POU expects to call its own PSPS, or engages in the de-
energization of lines that are fire threatened. To simplify this requirement, the Board developed
a template for its own review and asks that it be applied to the POU WMPs:
unnty Name ueny Name
size In same Mlles wao enwe:
— otransmcsbn.—Ilion .Gema I
Numberof Witomas Served customers
Customer Glosses nRe9tlenfial O GovemmeM O AgncWNml
o smao/Metliam mane:: ❑commertwlnw.lzmal
locafion/1opoNmPHY o union o Wone UNan Interface
❑ Rural/Fared 0 n RVlal/Desert n Rual/Agnculhra
Percenil hRyih des mops %in -2 %ini 3
CPUC Hi., RleR,H osinch Intlu
CAL FIRE FRAP Mop Ra Threot Zones olnclu1, maps %Edrerro %Very High %Hj{h
EUMn9—Hortli Measures o Describes tlartlenetl 8 non—Rd inhashucNr
UHIHy Pre mreot Rnk level DHlgn n— oM'ved
Impoctetl byalwinaunffy'z P3PSe O Yes 0.
AbHgofee iw,,t of omen unity's psn$ oyes 0 H
EsIe .nitrate mown -1 n yes o No
Prevaifrg wind direr , d maps olnWtleza descnpnon
& speeds Dy season ncu es
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LEU Response: LEU's WMP and Independent Evaluator Reports are prominently displayed and
easily located on LEU's website; they can also be found by conducting a web -search for "Lodi
Electric Utility Wildfire Plan." To assist the Board in its review, the WMP also includes an index or
table that shows where each section of the statute is addressed in the WMP. LEU has provided
some context -setting and risk discussion unique to LEU's territory, as well as the WSAB's
requested template. Please refer to Sec. I.D "Overall Risk Profile."
WSAB Recommendation - 2: In the WMP update, the Board recommends utilities provide a
paragraph describing the public review of the plan and how it is approved, if required. The
Board requests additional data on monitoring and auditing and how that information is
presented. A brief explanation on each POUs budget mechanism to be used to perform
wildfire mitigation would also be helpful to the Board.
LEU Response:
WSAB Recommendation - 3: In the future, the Board recommends IEs perform a robust
evaluation of the contents and substance of the POUs WMP. The Board especially appreciates
evaluations of how each POU compares to the IE's assessment of industry standards.
LEU Response:
WSAB Recommendation - 4: The 2021 POU WMPs and/or updates should be based on the
guidelines. It would be helpful to create a revised template that reflects the learnings from the
2020 initial effort. To develop that template in a timely manner, the Board invites the municipal
utility associations CMUA, the Southern California Public Power Association, the Northern
California Power Agency, and the Golden State Power Cooperative, to work collaboratively
with the WSAB to identify the utility groupings and develop a revised template for 2021. The
Board appreciated the discussion with the municipal utility and cooperative associations at the
workshop on November 18, 2020 and looks forward to further discussion at the final Board
meeting of 2020, scheduled for December 9, 2020 at 1 pm. The Board will continue to work with
these associations to develop future WMP guidelines within in the next 120 day or no later than
March 1, 2021. Of course, feedback from the individual agencies is also welcomed.
LEU Response:
WSAB Recommendation - 5: In the next round of WMPs, utilities should provide the context -
setting information discussed above. POUs should include a detailed protocol to address these
concerns in order for the Board to understand the strategic direction and effectiveness of each
POU and assist in furthering best practices.
LEU Response:
WSAB Recommendation - 6: For planning purposes, the Board understands that there is a
distinction between being a resident of a community and being customer of a utility. The utility
plan, while frequently a part of the municipal plan, should address the utility customer
dimensions of emergency preparedness planning with respect to PSPS and wildfires and the
unique concerns of more vulnerable customers such as: Access and Functional Needs,
medical baseline, non-English speakers, and those at risk of losing water or telecommunications
service. The Board recommends future WMPs continue to describe the specific methods,
content, and timing used to communicate with customers. Beginning with the 2021 WMPs, the
POUs should provide an evaluation of whether the current method of emergency
communication appears sufficient and, if not, what can be done to improve it, especially
protocols for notifying customers, essential service providers, and other critical facilities of IOU
or self -triggered PSPS events.
LEU Response:
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WSAB Recommendation - 7: The Board requests information from utilities on their existing and
planned system upgrades. In future WMPs, the Board would like to understand the details of
each utility's system hardening and grid design programs described in the WMP filing. Text of
the WMPs should indicate the goals of the programs and the risk any particular program is
designed to mitigate. The Board also wants to understand each POUs approach to PSPS
mitigation and prevention. Finally, POUs should identify any supply shortages.
LEU Response:
WSAB Recommendation - 8: To prevent unanticipated ignitions due to our changing
environmental circumstances, utilities should consider additional visual patrols on all potentially
impacted circuits annually. The Board requests that future WMPs describe the unique risks a
utility is inspecting for such as insect, wildfire incursion, wood split, woodpeckers, purposeful
insulator destruction, termites, etc., be included in the WMP text. WMPs should also describe
whether and how system inspections lead to system improvements.
LEU Response:
WSAB Recommendation - 9: The Board encourages POUs to consider different options for
surfacing for further consideration and remediation, previously unidentified risks that could lead
to catastrophic wildfires. POUs could work with the municipal and cooperative utility
associations and neighboring utilities or create their own engineering or risk management
teams.
LEU Response:
WSAB Recommendation - 10: The Board recommends the WMPs state the particular wildfire
risks associated with system design and construction such as topography and location near a
HFTD of another utility. The Board would also like information about G.O. 95 exempt assets and
possible updates to G.O. 95 that could facilitate more resilient utility transmission and
distribution assets.
LEU Response:
WSAB Recommendation - 11: To understand the engineering needs and wildfire risk, the Board
requests POUs include context setting information in the WMPs including information about the
prevailing wind directions and speeds, differentiated by season, along with average weather
conditions by season. The Board requests information on how and why situational awareness
technology is installed, and where on the system. The Board would also like insight into
decisions that are made not to install situational awareness technology. Are there constraints
such as budgets, availability of equipment, knowledge to effectively deploy, or qualified
personnel to install and monitor effectively? The Board also requests information about
whether this modeling data is received from or shared with other agencies, utilities, or fire
professionals.
LEU Response:
WSAB Recommendation - 12: The Board recommends the 2021 WMP Updates describe
treatment plans for all types of vegetation associated with utility infrastructure, from the ground
to the sky, which includes vegetation above and below electrical lines. In order to understand
current and future risk profiles for each POU, the WMPs should highlight:
❑ The reasoning behind each treatment plan and the ecological impact of the treatment
options chosen; ❑ How vegetation management in the HFTD or Fire Threat Zones differs from
other areas, including within private property and urban landscaping; ❑ The difference
between any enhanced vegetation management and the vegetation management
that meets the G.O. 95 standard; ❑ A list of native and non-native species and describe how
treatment methods vary; and ❑ The new growth that occurs in areas that has previously been
cleared or treated, and how the POUs tracks growth.
LEU Response:
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WSAB Recommendation - 13: The Board recommends the POU WMPs list the qualifications of
any experts relied upon, such as scientific experts in ecology, fire ecology, fire behavior,
geology, and meteorology. The WMPs should specify the level of expertise of the POU staff that
manages the contractors performing vegetation management.
The Board also recommends the WMPs describe measures each POU takes to ensure that POU
staff and contractors comply with or verify compliance with Cal/OSHA standards on Minimum
Approach Distances (MAD). Ensuring that on Qualified Electrical Workers treat vegetation
within the MAD of an energized utility line as required by Cal/OSHA, is critical to fostering a
strong safety culture.
LEU Response:
WSAB Recommendation - 14: The Board recommends WMPs describe whether the POU has
considered innovative and alternative approaches to vegetation management such as, but
not limited to requiring property owners to manage vegetation a certain distance from
structures or utility lines, and pilot programs in home hardening.
LEU Response:
Please note that with the 2021 restructuring of the WSAB to be under the Office of Energy
Infrastructure Safety, the link on the CPUC's website43 to find "The Board's Guidance Advisory
Opinion is available at....." is broken as of 11 /2021, as is the following page,
https://www.cpuc.ca.gov/wsab.
43 CPUC site: https://www.cpuc.ca.gov/news-and-updates/all-news/wsab-approves-,guidance-advisor pinion-for-
the-2021-camps-of-electric-pous-and-cooperatives
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RESOLUTION NO. 2022-281
A RESOLUTION OF THE LODI CITY COUNCIL ACCEPTING
LODI ELECTRIC UTILITY'S 2022 WILDFIRE MITIGATION PLAN
WHEREAS, in September 2018, California adopted SB 901, amending PUC 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 their 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 in Resolution No. 2019-24;
and
WHEREAS, SB 901 requires annual updates to the WMP, the third of which update LEU
has now completed; and
WHEREAS, the 2022 WMP has been audited by an independent third -party auditor.
NOW, THEREFORE, BE IT RESOLVED that the Lodi City Council does hereby accept
the Lodi Electric Utility 2022 Wildfire Mitigation Plan.
Dated: November 16, 2022
I hereby certify that Resolution No. 2022-281 was passed and adopted by the City Council
of the City of Lodi in a regular meeting held on November 16, 2022 by the following vote:
AYES: COUNCIL MEMBERS — Hothi, Khan, Kuehne, Nakanishi, and
Mayor Chandler
NOES: COUNCIL MEMBERS — None
ABSENT: COUNCIL MEMBERS — None
ABSTAIN COUNCIL MEMBERS — None
OLIVIA NASHED
City Clerk
2022-281