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COUNCIL COMMUNICATION
AGENDA TITLE: Adopt a resolution accepting the independent third party audit of the Wildfire Mitigation
Plan performed by Guidehouse, Inc. of Folsom.
MEETING DATE: November 16, 2022
PREPARED BY: Electric Utility Director
RECOMMENDED ACTION: Adopt a resolution accepting the independent third party audit of the
Wildfire Mitigation Plan (WMP) performed by Guidehouse, Inc. of Folsom.
BACKGROUND INFORMATION: Senate Bill 901, enacted in 2018, amended the California Public Utilities
Code requiring electric utilities to prepare and submit an annual WMP that
meets various regulatory requirements.
SB 901 also requires electric utilities to contract with a qualified independent evaluator with experience in
assessing the safe operation of electrical infrastructure to review and assess the comprehensiveness of its
WMP on a three-year cycle. Upon Council approval to contract with Navigant (now Guidehouse, Inc.), the initial
audit was completed in 2019. To meet the regulatory requirements, staff recently contracted with Guidehouse,
Inc. to perform the second three-year audit of the WMP.
The audit finds that the WMP is comprehensive in accordance with regulatory requirements. Staff hereby
submits the independent audit evaluation report for council consideration.
FISCAL IMPACT: Not -to -exceed $10,000.
FUNDING AVAILABLE: Included in FY 2022/23 Budget Account No. 50061500.72450
Jeff Berkheimer (Nov 2, 2022 12:53 PDT)
Jeff Berkheimer
Electric Utility Director
APPROVED:
Stephen Schwabauer, City Manager
Guidehouse
Outwit Complexity
Wildfire Mitigation Plan Independent
Evaluation
Prepared for:
Lodi Electric Utility
Submitted by:
Guidehouse Inc.
4001 South 700 East
Salt Lake City, UT 84107
November 1, 2022
guidehouse.com
This deliverable was prepared by Guidehouse Inc. for the sole use and benefit of, and pursuant to a client relationship exclusively with Lodi
Electric Utility ("Client"). The work presented in this deliverable represents Guidehouse's professional judgement based on the information
available at the time this report was prepared. Guidehouse is not responsible for a third party's use of, or reliance upon, the deliverable, nor any
decisions based on the report. Readers of the report are advised that they assume all liabilities incurred by them, or third parties, as a result of
their reliance on the report, or the data, information, findings and opinions contained in the report.
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Table of Contents
ExecutiveSummary......................................................................................................1
1. Background............................................................................................................... 2
1.1 Wildfire Mitigation Plans.............................................................................................. 2
1.1.1 SB 901..............................................................................................................2
1.1.2 AB 1054 Statutory Modifications.......................................................................2
1.2 Lodi Electric Utility Plan Preparation............................................................................ 2
1.2.1 Independent Evaluation Services......................................................................3
2. Evaluation Scope and Approach.............................................................................4
2.1 Evaluation Parameters................................................................................................ 4
2.1.1 WMP Requirements..........................................................................................4
2.1.2 Industry Knowledge and Regulatory Proceedings.............................................5
2.2 Evaluation Approach................................................................................................... 6
2.2.1 Statutory Compliance........................................................................................6
2.2.2 Industry Wildfire Mitigation Practices Comparison............................................6
2.2.3 Value Determination of Plan Metrics.................................................................6
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3.1 Responsibilities of Persons Responsible for Executing the Plan .................................. 7
3.2 Objectives of the Plan................................................................................................. 7
3.3 Wildfire Prevention Strategies..................................................................................... 7
3.4 Metrics........................................................................................................................
8
3.5 Disabling Reclosers.....................................................................................................
8
3.6 De -Energizing Protocols..............................................................................................
9
3.7 Event Communication................................................................................................. 9
3.8 Vegetation Management............................................................................................. 9
3.9 Infrastructure Inspections..........................................................................................
10
3.10 Risk Assessment and Drivers..................................................................................
10
3.11 Asset Overview and Service Territory ......................................................................
10
3.12 Restoration..............................................................................................................
10
3.13 Monitoring and Auditing the Plan.............................................................................
11
3.14 Annual Review........................................................................................................
11
4. Results and Discussion..........................................................................................12
Appendix A. Statutory Compliance Matrix.............................................................. A-1
List of Tables
Table1 — POU Requirements................................................................................................... 4
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Table 2 — LEU Proposed Metrics.............................................................................................. 8
List of Figures
Figure 1 — Mitigation Strategy Overview.................................................................................... 6
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Executive Summary
Lodi Electric Utility (LEU) contracted with Guidehouse Inc. (Guidehouse) to engage in an
independent evaluation of its Wildfire Mitigation Plan (Plan or WMP). This independent
evaluation report (Report) describes the technical review and evaluation provided by
Guidehouse. Guidehouse performed this evaluation in October 2022 and finalized the Report on
November 1, 2022. Guidehouse's project team reviewed detailed information related to the Plan
and assessed LEU's procedures related to the Plan.
The Plan was prepared as a response to Senate Bill (SB) 901. SB 901 and included a number
of provisions and directives, among which includes the requirement for electric utilities to
prepare and adopt WMPs and revise and update the Plan annually thereafter. These
requirements are codified in the California Public Utilities Code (PUC) Section 8387 for publicly
owned utilities (POUs).
Guidehouse evaluated the Plan based on the statutory requirements of PUC Section 8387 as it
relates to POUs. This PUC Section was amended in 2019 with the signing of California's
Assembly Bill (AB) 1054 into law. The POUs are now subject to the guidance provided by the
California Wildfire Safety Advisory Board and mandatory cyclical reviews, including a
comprehensive update every three years. The required elements for a WMP have not been
modified by this new legislation. This Report meets LEU's requirements under PUC Section
8387(c), which mandate an independent evaluation of LEU's WMP. The Report was developed
to satisfy the statutory requirement for public review. This Report underlies the required
evaluation by the Board of Directors at a public meeting, scheduled for November 16, 2022. The
Report includes the following:
• Background of the legislative history requiring WMPs and their independent evaluations
• Approach and methodology evaluating the WMP's comprehensiveness
• LEU's WMP elements and their compliance with SB 901 and PUC Section 8387 WMP
elements and directives
• An evaluation of the WMP's presented metrics to assess the effectiveness of the overall
WMP
• Determinations and results
Based on relevant experience in grid hardening and resiliency, natural disaster response, prior
experience in WMP development, and active tracking of wildfire legislative and regulatory
proceedings Guidehouse has concluded that LEU's WMP is comprehensive in accordance with
PUC section 8387.
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1. Background
In recent years, California has seen an increase in catastrophic wildfires, some of which were
caused by utility equipment. The unique geographic profile of California and the impacts of
climate change are creating elongated fire seasons with dry conditions, high winds, and
elevated heat. The state is also burdened with historically levels of vegetation fuel due to past
fire suppression efforts. This increasingly abundant dry vegetation is the leading driver of
wildfires.
The increase in utility -involved wildfire incidents and the significant financial and livelihood
impacts associated with them led to more formalized efforts to ensure safe operations of electric
utility equipment and greater investment in wildfire mitigation efforts.' Specifically, the state
adopted legislation and regulations to strengthen oversight of utility wildfire prevention and
mitigation.
1.1 Wildfire Mitigation Plans
1.1.1 SB 901
In an effort to minimize future devastating occurrences through risk -driven wildfire prevention,
electric utilities, including publicly owned utilities (POUs), were mandated, by Senate Bill (SB)
901 to prepare and annually adopt a WMP. The WMPs must Include several mitigation and
response elements in each utility's strategies, protocols, and programs. The requirements for
POUs are codified in Public Utilities Code (PUC) Section 8387. Details relating to POU
requirements are discussed in Section 2 of this WMP evaluation report (Report).
1.1.2 AB 1054 Statutory Modifications
In 2019, Assembly Bill (AB) 1054 was signed into law, modifying the requirements for POU
WMPs. AB 1054 aims to mitigate the intensity of wildfire impacts through several initiatives
separate from those actions required of electric utilities. AB 1054 includes directives to establish
the Wildfire Safety Division at the California Public Utilities Commission and the state's Wildfire
Safety Advisory Board (WSAB). AB 1054 requires POUs submit their WMPs by July 1 of each
year for review by and recommendations from WSAB and requires POUs to comprehensively
update their WMPs at least every three years.
1.2 Lodi Electric Utility Plan Preparation
Lodi Electric Utility (LEU) is a department within the City of Lodi. Its service territory is contained
entirely within the City limits. LEU's primary goal is to provide safe, reliable, and cost-effective
electricity while also anticipating and meeting customer needs. As a POU, LEU has no fiduciary
obligations to shareholders and its actions and decisions are governed by City Manager and the
City Council and ultimately to the citizens of Lodi.
' California Public Utilities Commission, 2019. "Fire Incident Data Reports for Investor -Owned Utilities,"
https://www.cpuc.ca.gov/fireincidentsdata/
2 Oversight and responsibility for the Wildfire Safety Division was transferred from the California Public Utilities
Commission to the California Natural Resources Agency on July 1, 2021 and is now known as the Office of Energy
Infrastructure Safety.
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LEU prepared its first WMP pursuant to SB 901 directives in 2019. This initial WMP was
independently evaluated by Guidehouse, and the report was presented to the City Council and
made publicly available on LEU's website along with LEU's WMP. The WMP addresses each of
the required elements presented by PUC Section 8387 and reduces the risk of contributing to
utility -involved wildfire events through WMP execution and metric tracking.
1.2.1 Independent Evaluation Services
PUC Section 8387(c) directs POUs to procure a independent evaluation (IE) of the
comprehensiveness of the WMP. The provisions of PUC Section 8387 state that the "qualified
independent evaluator" shall be experienced in "assessing the safe operation of electrical
infrastructure" and will perform an assessment to determine the comprehensiveness of the
WMP.3
LEU sought out IE services to assess the comprehensiveness of its WMP pursuant to PUC
Section 8387(c). Accordingly, LEU issued a request for proposals from IEs and selected
Guidehouse to perform this assessment based on Guidehouse's prior experience with
assessing the safe operation of electrical infrastructure, including grid -hardening and WMPs,
with an emphasis on electrical equipment, public, and personnel safety. Guidehouse has
conducted over 10 independent evaluations of POUs across California and is an Energy Safety -
designated qualified independent evaluator for the last two years, and as such has conducted
six independent evaluations of three CA IOUs.
This Report presents the results of Guidehouse's WMP IE.
3 It is recognized that this requirement does not yet include a clear definition of comprehensiveness.
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Wildfire Mitigation Plan Independent Evaluation
2. Evaluation Scope and Approach
Guidehouse completed this evaluation based on industry standard practices, our experience
developing and reviewing WMPs and other grid hardening activities, our active tracking of
wildfire legislative and regulatory proceedings and, most importantly, a comparison of the
specific criteria in PUC Section 8387(b)(2) to the specific wildfire -related plans outlined in LEU's
WMP.
2.1 Evaluation Parameters
2.1.1 WMP Requirements
Table 1 lists the requirements for the statutory requirements for POUs to address in their
WMPs.
Table 1 — POU Requirements
(a) Each local publicly owned electric utility and electrical cooperative shall construct, maintain, and operate its
electrical lines and equipment in a manner that will minimize the risk of wildfire posed by those electrical lines
and equipment.
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(b) (1) The local publicly owned electric utility or electrical cooperative shall, before January 1, 2020, prepare a
wildfire mitigation plan. After January 1, 2020, a local publicly owned electric utility or electrical cooperative shall
prepare a wildfire mitigation plan annually and shall submit the plan to the California Wildfire Safety Advisory
Board on or before July 1 of that calendar year. Each local publicly owned electric utility and electrical
cooperative shall update its plan annually and submit the update to the California Wildfire Safety Advisory Board
by July 1 of each year. At least once every three years, the submission shall be a comprehensive revision of the
plan.
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(2) The wildfire mitigation plan shall consider as necessary, at minimum, all of the following:
(A) An accounting of the responsibilities of persons responsible for executing the plan.
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(B) The objectives of the wildfire mitigation plan.
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(C) A description of the preventive strategies and programs to be adopted by the local publicly owned electric
utility or electrical cooperative to minimize the risk of its electrical lines and equipment causing catastrophic
wildfires, including consideration of dynamic climate change risks.
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(D) A description of the metrics the local publicly owned electric utility or electrical cooperative plans to use to
I evaluate the wildfire mitigation plan's performance and the assumptions that underlie the use of those metrics.
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(E) A discussion of how the application of previously identified metrics to previous wildfire mitigation plan
performances has informed the wildfire mitigation plan.
4i
(F) Protocols for disabling reclosers and deenergizing portions of the electrical distribution system that consider
the associated impacts on public safety, as well as protocols related to mitigating the public safety impacts of
those protocols, including impacts on critical first responders and on health and communication infrastructure.
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(G) Appropriate and feasible procedures for notifying a customer who may be impacted by the deenergizing of
electrical lines. The procedures shall consider the need to notify, as a priority, critical first responders, health
care facilities, and operators of telecommunications infrastructure.
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(H) Plans for vegetation management.
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Plans for inspections of the local publicly owned electric utility's or electrical cooperative's electrical
infrastructure.
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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:
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Risks and risk drivers associated with design, construction, operation, and maintenance of the local publicly
owned electric utility's or electrical cooperative's equipment and facilities.
F a
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.
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Identification of any geographic area in the local publicly owned electric utility's or electrical cooperative's
service territory that is a higher wildfire threat than is identified in a commission fire threat map, and identification
of where the commission should expand a high fire -threat district based on new information or changes to the
environment.
A methodology for identifying and presenting enterprise wide safety risk and wildfire -related risk.
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A statement of how the local publicly owned electric utility or electrical cooperative will restore service after a
wildfire.
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A description of the processes and procedures the local publicly owned electric utility or electrical
cooperative shall use to do all of the following:
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(i) Monitor and audit the implementation of the wildfire mitigation plan.
(ii) Identify any deficiencies in the wildfire mitigation plan or its implementation, and correct those deficiencies.
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(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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(3) The local publicly owned electric utility or electrical cooperative shall, on or before January 1, 2020, and not
less than annually thereafter, present its wildfire mitigation plan in an appropriately noticed public meeting. The
local publicly owned electric utility or electrical cooperative shall accept comments on its wildfire mitigation plan
from the public, other local and state agencies, and interested parties, and shall verify that the wildfire mitigation
plan complies with all applicable rules, regulations, and standards, as appropriate.
(c) The local publicly owned electric utility or electrical cooperative shall contract with a qualified independent
evaluator with experience in assessing the safe operation of electrical infrastructure to review and assess the
comprehensiveness of its wildfire mitigation plan. The independent evaluator shall issue a report that shall be
made available on the internet website of the local publicly owned electric utility or electrical cooperative, and
shall present the report at a public meeting of the local publicly owned electric utility's or electrical cooperative's
governing board.
2.1.2 Industry Knowledge and Regulatory Proceedings
The state's priority towards abating future catastrophic wildfire events is demonstrated through
aggressive measures, directing utilities to enhance their protocols for fire prevention, public
communications, and response. That collection of information is presented in a comprehensive
WMP. Guidehouse tracks state proceedings and routinely advises, assesses, and guides utility
wildfire mitigation efforts. Accordingly, we reviewed LEU's WMP against the provisions in PUC §
8387 and relative to its risk profile which includes, but is not limited to, its topography, climate,
assets, and structure.
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2.2 Evaluation Approach
To perform an assessment of the comprehensiveness of the Guidehouse assessed the
comprehensiveness of the plan against the applicable regulations.
2.2.1 Statutory Compliance
Guidehouse sought to determine compliance with the provisional requirements laid out in
SB901 as codified in PUC Section 8387. The WMP's alignment with the statutory requirement is
presented in Appendix A. LEU's mitigation measures are not required to exceed the statutory
requirements.
2.2.2 Industry Wildfire Mitigation Practices Comparison
Guidehouse's understanding of an effective WMP draws on comparisons from existing WMPs
and industry practices, WSAB guidance, risk profile, and mitigation strategy. This mitigation
strategy analysis is visually summarized in Figure 1.
Design & Construction:
System, equipment, and
structure design and
technical upgrades
designed to improve
system hardening to
prevent contact between
infrastructure and fuel
sources, such as
vegetation.
Inspection & Maintenance:
Assessment and diagnostic
activities as well as
associated corrective
actions aimed to ensure all
infrastructure is in working
condition and vegetation
adheres to defined
minimum distance
specifications.
Operational Practices:
Proactive, day-to-day
actions taken to mitigate
wildfire risks aimed to
ensure the POU is prepared
in high-risk situations, such
as dry, windy
environmental conditions.
Methods to improve
system visualization and
awareness of
environmental conditions
aimed to provide tools to
improve the other
components of the plan.
Figure 1 — Mitigation Strategy Overview
Response & Recovery:
Procedures to react to de-
energization, wildfire, or
other related emergency
conditions, aimed to
formalize protocols for
these situations, so the
POU can provide an
adequate response and
recovery.
Expertise in these critical elements facilitated Guidehouse's review of the comprehensiveness of
LEU's WMP. While not all of these strategies are present in or applicable to LEU's WMP, due to
LEU's size, location, and operational characteristics.
2.2.3 Value Determination of Plan Metrics
Metrics for tracking the WMP's progress intend to allow the utility to refresh information as
trends become clearer.
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3. LEU WMP Elements
Guidehouse reviewed the WMP elements and determined whether the activities achieve the
objective of WMP "comprehensiveness" of PUC Section8387. This determination incorporates
individual elements as well as underlying data sources that further describe data collection
methodologies and implementation procedures to ensure measures are carried out and also
tracked.
Guidehouse determined LEU's WMP meets the requirement of comprehensiveness PUC
Section 8387. In this section, we review the WMP's elements and their purpose relative to the
development and successful execution of the WMP. A table comparing each subsection of PUC
Section 8387 to the significant sections of the WMP can be found in Appendix A.
3.1 Responsibilities of Persons Responsible for Executing the Plano
Section IIIA, and to a lesser extent Section 111.13, identify the organization of LEU within the City
of Lodi and identifies those responsible for the execution of the activities detailed in the plan.
Specifically, the WMP assigns duties to the Electric Utility Director, Engineering & Operations
Manager, and Electric Superintendent and clarifies how LEU interacts with other Lodi
departments.
3.2 Objectives of the Plans
LEU has clearly stated objectives in Section II of the WMP. LEU's primary goal is to "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." The secondary objective is to improve the resiliency of LEU's electric
system
3.3 Wildfire Prevention Strategiess
Section V of LEU's WMP describes in detail LEU's preventative strategies and programs, which
includes understanding risks through efforts to participate in and understand the designations of
the CPUC Fire Threat Map, weather monitoring design and construction standards, vegetation
management, system maintenance and inspections, reclosing policy, and de-energization. The
following are discussed in more detail in the sections below:
Section 3.5
Section 3.6
Section 3.8
Section 3.9
4 PUC Section 8387(2)(A)
5 PUC Section 8387(2)(B)
6 PUC Section 8387(2)(C)
Disabling Reclosers
De -Energizing Protocols
Vegetation Management
Infrastructure Inspection
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3.4 Metrics'
This section provides an assessment of the proposed metrics in Section VIII.A of LEU's WMP.
The statutory requirements for the inclusion of metrics are found in PUC Section 8387(b)(2)(D)
and (E) where utilities are directed to present these metrics and address how prior metrics
impact the proposed metrics for the next version of the WMP. The four proposed metrics in
LEU's 2022 WMP are shown in Table 2 — LEU Proposed Metrics . These metrics represent
LEU's approach to track fire ignitions related to its electrical infrastructure and to track the
progress of its vegetation management and inspection programs. The underlying assumptions
suggest that monitoring the frequency and cause of ignition events as well as the status of its
programs will shape the direction of mitigation strategies as this information is collected and
analyzed. These proposed metrics meet the regulatory objective and will assist in providing
insight on the effectiveness of the WMP in future years.
Table 2 — LEU Proposed Metrics
Fire Ignitions Count of Events No material increase
(1) LEU facility was associated with origin of
the fire
(2) Fire was self -propagating and of a
material other than electrical and/or
communication facilities
(3) Resulting fire traveled greater than one
linear meter from ignition point
(4) LEU has knowledge fire occurred
3.5 Disabling Reclosers$
Section V.F of the WMP states that LEU does not have any reclosers deployed downstream of
its substations, and accordingly, does not have a protocol for disabling reclosers at its
substations. This decision is explained in detail and is based on the low-risk nature of LEU's
power system and the negative impacts to public safety, critical first responders, and on health
and communication infrastructure expected under extended outages.
PUC Section 8387(2)(D) and PUC Section 8387(2)(E)
8 PUC Section 8387(2)(F)
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Any instance where an electric transmission
Wire Down Events
Count of Events
No material increase
or primary distribution conductor falls to the
ground or on a foreign object
Inspection -Cycle
% Grid
100% complete per GO
LEU service territory is divided into 66
Completion
Completion
165 timelines
smaller grids and each grid is inspected per
the GO 165 timeline
Vegetationo
LEU service territory is divided into 66
Management
o
�o Grid
50-66% complete every
smaller grids and the vegetation near LEU
Cycle Completion
Completion
12 months
assets is trimmed, removed, or managed in
each grid every 18-24 months
3.5 Disabling Reclosers$
Section V.F of the WMP states that LEU does not have any reclosers deployed downstream of
its substations, and accordingly, does not have a protocol for disabling reclosers at its
substations. This decision is explained in detail and is based on the low-risk nature of LEU's
power system and the negative impacts to public safety, critical first responders, and on health
and communication infrastructure expected under extended outages.
PUC Section 8387(2)(D) and PUC Section 8387(2)(E)
8 PUC Section 8387(2)(F)
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3.6 De -Energizing Protocols9
Wildfire Mitigation Plan Independent Evaluation
Section V.G of the WMP identifies that while LEU has the authority to de -energize portions of its
electric system for fire -threat conditions, it is not proposing to implement de-energization
(commonly known as Public Safety Power Shutoff or PSPS) protocols for wildfire prevention As
with the decision not to disable LEU's reclosers, because LEU operates entirely within a Tier 1,
low risk area LEU considered the harm from preemptory and longer duration power outages
exceeds the low likelihood LEU's system may ignite a wildfire. LEU discusses several reasons
related to public safety, critical first responders, and on health and communication infrastructure
for not developing such a protocol.
This section also addresses that if power fed into LEU's system is cut by a public safety power
shutoff (PSPS), LEU would enact its communication and notification capabilities to alert the
community of the PSPS.
3.7 Event Communication10
LEU sets forth several communication channels in Section III (notably parts D, E, and F) of the
WMP for use in an emergency situation to notify the public. These include the County of San
Joaquin's emergency alert system and cell -phone triangulation system, AM broadcasting, the
company website, and Lodi Unified School District's public -messaging capabilities. LEU also
implemented an Outage Management System and an Interactive Voice Response system to
assist with customer notification. In addition, the utility complies with the California Office of
Emergency Services' Standardized Emergency Management System (SEMS) Regulations and
is a participant in the Western Energy Institute's Western Region Mutual Assistance Agreement.
The WMP states that these communication channels and resources are available to LEU during
an emergency event and would be used in the event of de-energization of an upstream feed to
LEU (operating beyond its control).
3.8 Vegetation Management"
In Section V.D, LEU describes its vegetation management plan that implements standards
based on, and exceeding, the minimum requirements in CPUC GO 95. LEU's standard practice
for trimming is to cut at least a five-foot clearance around secondary voltage overhead
infrastructure, a ten -foot clearance around all primary voltage overhead infrastructure, and a 15 -
foot clearance around all sub -transmission and transmission overhead infrastructure. The
vegetation within LEU's service territory is reflective of those typically found in an urban or
suburban setting.
All trees in proximity to LEU electric infrastructure are visited at least every 18-24 months.
Dense -vegetation areas are prioritized, and fast-growing or invasive species are removed,
subject to the permission of the tree's owner. LEU uses contractors for this service but also has
two dedicated tree crews with the ability to quickly scale up if needed.
9 PUC Section 8387(2)(F)
10 PUC Section 8387(2)(G)
" PUC Section 8387(2)(H)
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3.9 Infrastructure Inspections12
Wildfire Mitigation Plan Independent Evaluation
Section V.E of the WMP describes LEU's infrastructure inspection program. LEU seeks to meet
or exceed the inspection requirements in CPUC GO 95 Rule 18 and GO 165. LEU staff also
leverage their knowledge of the system and geographical conditions to determine when certain
areas require more frequent inspections.
3.10 Risk Assessment and Drivers 13
Section IV of LEU's WMP elaborates the risk analysis and risk drivers that guide the
development of LEU's wildfire prevention practices. LEU identifies vegetation mortality,
extended drought, and high winds as the primary risk drivers in this section. It also identifies
indirect risks associated with dynamic climate change risk such as resource limitations if they
are redirected to wildfire -related efforts outside of LEU service territory. This section also sets
forth LEU's methodology for identifying enterprise -wide and wildfire -related risk includes
overlaying its service territory on the CPUC's Fire -Threat Map. This exercise identified that LEU
service territory currently and correctly falls under the category of Tier 1 or low risk under the
CPUC Fire -Threat Map. Additionally, LEU's system and service area characteristics (primarily
urban, flat, compact, and without any unmanaged wildlands) demonstrate LEU poses a low risk
of providing an ignition source for a wildfire.
LEU also discusses the specific design and construction standards it has implemented (e.g.,
use of undergrounding, covered wire, bushing covers, dead -front transformers, less flammable
transformer oil) to minimize fire risk in Section V.0 of the WMP. This section details the use of
insulated wires, transformer selection, use of high flashpoint transformer oil, and use of
undergrounding for new subdivisions and large commercial customers.
3.11 Asset Overview and Service Territory14
As described in Section IV of the WMP, LEU service territory falls under the Tier 1, low risk area
of the CPUC fire threat map. LEU does not propose any changes to the map at this time as
mentioned in section N.C.
3.12 Restoration15
Section VII of the WMP states LEU will restore service following an outage based on the circuit
prioritization outlined in its Electricity Emergency Plan (EEP). Lodi restores vital loads first,
before the restoration of non -vital loads. During and following wildfire conditions the WMP also
discusses how the system will be inspected for visual damage and hazards prior to
energization.
12 PUC Section 8387(2)(1)
13 PUC Section 8387(2)(J)(i); PUC Section 8387(2)(J)(ii); PUC Section 8387(2)(L)
14 PUC Section 8387(2)(K)
15 PUC Section 8387(2)(M)
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3.13 Monitoring and Auditing the Plan 16
LEU conducts an internal audit for completeness, effectiveness, and implementation annually
with corrective actions associated with deficiencies implemented as necessary. In addition to
the internal audit LEU will have an independent evaluator review the WMP, every three years. In
addition, LEU will monitor the effectiveness of its asset inspections through its Computer
Maintenance Management System, which tracks issues and deficiencies identified during the
inspections and ensures they are addressed. The details of these efforts are described in
Section VIII.B-E.
3.14 Annual Review 17
The WMP will be reviewed at least annually. The review will include assessments of the WMP's
programs and performance. As part of this process LEU will monitor and audit the
implementation of the WMP, identify and correct deficiencies, and monitor and audit the
effectiveness of electrical line and equipment inspections, including inspections carried out by
contractors. The findings of these audits will be presented at a public meeting of the Lodi City
Council in accordance with Section VI. of the WMP.
16 PUC Section 8387(2)(N)(i) and PUC Section 8387(2)(N)(ii)
17 PUC Section 8387(2)(N)(iii)
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4. Results and Discussion
Wildfire Mitigation Plan Independent Evaluation
Guidehouse finalized this assessment on November 1, 2022. Over the course of reviewing
LEU's WMP and supporting documentation, Guidehouse captured takeaways and findings that
align the WMP with state laws and effective wildfire measure demonstration for a utility of LEU's
size and low-risk profile. LEU's WMP appropriately responds to each of the required elements of
PUC Section 8387, which is detailed in Appendix A. The following describes the assessment
and resulting findings of the WMP's proposed and established mitigation measures as it applies
to safe, reliable operation of all electric infrastructure and wildfire prevention and response.
Report Conclusions
After internal review of the latest version of the WMP and associated data collection products,
Guidehouse concludes this Report with the following:
LEU's WMP aligns appropriately with PUC Section 8387 and includes all required
elements. 18
• LEU's WMP is comprehensive as described through this Report for an electric utility
operating completely within CPUC -designated Tier 1 fire risk areas.
'$ Following acceptance of this Report, LEU will post the Report and results online for public view. The Report is
scheduled for presentation to the City Council at a public meeting in November 2019. Accomplishing these follow-up
tasks will meet all required statutory provisions up until presenting the final WMP to the City Council.
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AGuidelhouse
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Wildfire Mitigation Plan Independent Evaluation
Appendix A. Statutory Compliance Matrix
—1�%�ecti'on
Required Statutory Element I Section ..an Elements lements
Reference(s) (Summarized) (Determination
Each local publicly owned
electric utility and electrical
cooperative shall construct,
maintain, and operate its
electrical lines and equipment in
a manner that will minimize the
risk of wildfire posed by those
electrical lines and equipment.
(b) (1) The local publicly owned
electric utility or electrical
cooperative shall, before January
1, 2020, prepare a wildfire
mitigation plan. After January 1,
2020, a local publicly owned
electric utility or electrical
cooperative shall prepare a
wildfire mitigation plan annually
and shall submit the plan to the
California Wildfire Safety Advisory
Board on or before July 1 of that
calendar year. Each local publicly
owned electric utility and
electrical cooperative shall
update its plan annually and
submit the update to the
California Wildfire Safety Advisory
Board by July 1 of each year. At
least once every three years, the
submission shall be a
comprehensive revision of the
Ian.
(2) The wildfire mitigation plan
shall consider as necessary, at
minimum, all of the following:
LEU has a Roles and Responsibilities
section in its plan with descriptions of
the roles of the Electric Utility Director,
Engineering and Operations Manager,
and Electric Superintendent as well as
An accounting of the
each City Department.
responsibilities of persons
Section III
While the WMP identifies the Fire
Yes
responsible for executing the
A B & C
'
Chief as the person responsible for
plan.
implementing the Incident Command
Structure protocols, the identification
of other roles with respect to the
Incident Command Structure during a
potential wildfire emergency may be
helpful.
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LEU has clearly stated objectives in
its plan. LEU's primary objective
refers to reducing, eliminating,
minimizing or mitigating the risk of
The objectives of the wildfire
Section II
wildfires caused by or exacerbated by
Yes
mitigation plan.
the entity's electrical system. The
secondary goal of improving system
resilience in the context of wildfire risk
is also a valid objective.
A description of the
Section V provides a detailed
preventive strategies and
description of LEU's preventative
programs to be adopted by the
strategies with specific subsections on
local publicly owned electric utility
its low-risk service territory, weather
or electrical cooperative to
monitoring, design and construction
minimize the risk of its electrical
Section V
standards, vegetation management
Yes
lines and equipment causing
and maintenance and inspection. LEU
catastrophic wildfires, including
also states that it has not identified
consideration of dynamic climate
any direct impacts on its territory from
change risks.
dynamic climate change risks.
A description of the metrics
The four metrics identified represent
the local publicly owned electric
measurements of WMP effectiveness,
utility or electrical cooperative
including metrics that track wires
plans to use to evaluate the
Section VIII
down, fire ignitions, the completion
Yes
wildfire mitigation plan's
A
rate of its inspection, and vegetation
performance and the
management cycles.
assumptions that underlie the use
of those metrics.
As with many other WMPs prepared
A discussion of how the
for 2020, LEU's plan does not discuss
application of previously identified
the impact of previous metrics
metrics to previous wildfire
Section VIII
because those metrics have not been
there
Yes
mitigation plan performances has
B
monitored and was no previous
informed the wildfire mitigation
wildfire mitigation plan to assess
plan.
performance. The WMP clearly states
LEU has not monitored these metrics
in the past.
A section on reclosers is included in
Protocols for disabling
the plan and clearly states that LEU
reclosers and deenergizing
does not currently have a protocol for
portions of the electrical
blocking the reclosing of lines
distribution system that consider
because it is in a low-risk area and it
the associated impacts on public
Section V
would have significant adverse
impacts on customers.
safety, as well as protocols
F & G
Yes
related to mitigating the public
Similarly, de-energization is not being
safety impacts of those protocols,
implemented by LEU at this time and
including impacts on critical first
the discussions and justification are
responders and on health and
explained in detail. LEU will review
communication infrastructure.
this decision in the future iterations of
the WMP.
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Appropriate and feasible
procedures for notifying a
customer who may be impacted
While LEU's stated policy is NOT
by the deenergizing of electrical
lines. The procedures shall
Section III
performing de-energization, it would
consider the need to notify, as a
c
E
use the communication procedures
Yes
priority, critical first responders,
noted in Section III.E to notify
health care facilities, and
customers.
operators of telecommunications
infrastructure.
Details of tree trimming activities are
adequate and include minimum
Plans for vegetation
Section V D
distances and frequency of vegetation
Yes
management.
work. LEU may wish to consider
appending additional vegetation
management program details.
LEU's WMP states that it meets or
(1) Plans for inspections of the
exceeds the inspection cycles and
local publicly owned electric
Section V E
requirements provided in GO 95 and
Yes
utility's or electrical cooperative's
165. LEU may wish to consider
electrical infrastructure.
appending additional vegetation
management program details.
A list that identifies, describes,
In general, this section identifies
and prioritizes all wildfire risks,
LEU's risk and risk drivers and
and drivers for those risks,
addresses the topics of design,
throughout the local publicly
Section IV
operation, and construction, as well as
Yes
owned electric utility's or electrical
A & B
topographic and climatological risk
cooperative's service territory.
factors.
The list shall include, but not be
limited to, both of the following:
Risks and risk drivers
LEU states that specific risks from
associated with design,
these risk -drivers include increased
construction, operation, and
Section IV
vegetation mortality, contributing dry -
maintenance of the local publicly
A & B
fuels to the region, as well as
Yes
owned electric utility's or electrical
vegetation in a weakened -state
cooperative's equipment and
potentially falling into energized lines
facilities.
during high -wind events.
Particular risks and risk
In general, this section identifies
drivers associated with
LEU's risk and risk drivers and
topographic and climatological
factors throughout the
Section IV
addresses the topics of design,
Yes
risk
different parts of the local publicly
A & B
operation, and construction as well as
owned electric utility's or electrical
topographic and climatological risk
cooperative's service territory.
factors.
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Identification of any
geographic area in the local
publicly owned electric utility's or
LEU's WMP confirms that its system
electrical cooperative's service
is located completely in a low (tier 1)
territory that is a higher wildfire
fire threat zone.
threat than is identified in a
Section IVB
YeS
commission fire threat map, and
LEU states it does not propose
identification of where the
changes to the CPUC fire threat map
commission should expand a
at this time.
high fire -threat district based on
new information or changes to
the environment.
LEU includes a map overlay exercise
A methodology for identifying
as its methodology to identify and
and presenting enterprise wide
Section IV B
present wildfire -related risk. LEU
should consider adding a formal risk
Yes
safety risk and wildfire -related
assessment process to identify and
risk.
present enterprise safety and wildfire -
related risks.
A statement of how the local
LEU's WMP provides a statement of
publicly owned electric utility or
how it plans to restore service after a
electrical cooperative will restore
Section VII
wildfire, including a discussion of
Yes
service after a wildfire.
efforts to inspect the condition of the
system prior to energization.
A description of the
processes and procedures the
local publicly owned electric utility
or electrical cooperative shall use
to do all of the following:
LEU states it will conduct both internal
and external (independent) audits of
the plan to identify deficiencies. LEU
has stated that the Electric Utility
Director is responsible for the internal
review and audit of the plan as well as
the identification and tracking of
deficiencies in the WMP's
implementation and direct corrective
Monitor and audit the
Section VIII
actions for any plan or implementation
deficiencies identified by LEU, its
implementation of the wildfire
C, D &
contractors or any external auditing
Yes
mitigation plan.
parties. LEU also plans to monitor and
audit the implementation of the plan
by evaluating the progress of its
vegetation management and
inspection programs. LEU could
expand upon this by instituting
monthly or quarterly assessments that
track LEU investments and activities
proposed in the plan or directed to
minimize wildfire risks.
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LEU has stated that the Electric Utility
Director is responsible for the internal
review and audit of the plan as well as
Identify any deficiencies in the
the identification and tracking of
wildfire mitigation plan or its
Section VIII
deficiencies in the WMP's
Yes
implementation, and correct
C, D & E
implementation and direct corrective
those deficiencies.
actions for any plan or implementation
deficiencies identified by LEU, its
contractors or any external auditing
parties.
LEU also plans to monitor and audit
Monitor and audit the
the effectiveness of its vegetation
effectiveness of electrical line and
management and inspection
equipment inspections, including
Section VIII
programs through two of the metrics it
has established in its WMP. LEU
inspections performed by
C, D & E
could expand upon this by instituting
Yes
contractors, that are carried out
monthly or quarterly assessments that
under the plan, other applicable
track LEU investments and activities
statutes, or commission rules.
proposed in the plan or directed to
minimize wildfire risks.
(3) The local publicly owned
electric utility or electrical
cooperative shall, on or before
January 1, 2020, and not less
than annually thereafter, present
its wildfire mitigation plan in an
appropriately noticed public
meeting. The local publicly owned
LEU will present its WMP to the City
electric utility or electrical
cooperative shall accept
Section VIII
Council at a public meeting in
Yes
comments on its wildfire
November 2019.
mitigation plan from the public,
other local and state agencies,
and interested parties, and shall
verify that the wildfire mitigation
plan complies with all applicable
rules, regulations, and standards,
as appropriate.
(c) The local publicly owned
electric utility or electrical
cooperative shall contract with a
qualified independent evaluator
with experience in assessing the
safe operation of electrical
infrastructure to review and
assess the comprehensiveness
LEU contracted with Guidehouse
of its wildfire mitigation plan. The
Consulting, Inc. to perform an
independent evaluator shall issue
Section IX
independent evaluation of its WMP.
Yes
a report that shall be made
Qualifications are described in Section
available on the internet website
1.
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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RESOLUTION NO 2022-282
A RESOLUTION OF THE LODI CITY COUNCIL ACCEPTING THE
THIRD -PARTY AUDIT OF THE WILDFIRE MITIGATION PLAN PERFORMED
BY GUIDEHOUSE, INC., OF FOLSOM
------------------------------------------------------------------------
------------------------------------------------------------------------
WHEREAS, Senate Bill 901, enacted in 2018, amended the California Public Utilities Code
requiring electric utilities to prepare and submit an annual Wildfire Mitigation Plan ((WMP) that
meets various regulatory requirements; and
WHEREAS, SB 901 also requires electric utilities to contract with a qualified independent
evaluator with experience in assessing the safe operation of electrical infrastructure to review and
assess the comprehensiveness of its WMP; and
WHEREAS, Lodi Electric Utility (LEU) contracted with Guidehouse, Inc., to provide WMP
Independent Evaluation Services; and
WHEREAS, the evaluation of the WMP finds that it is comprehensive in accordance with
regulatory requirements.
NOW, THEREFORE, BE IT RESOLVED that Lodi City Council does hereby accept the
WMP audit report prepared by Guidehouse, Inc., of Folsom, California.
Dated: November 16, 2022
1 hereby certify that Resolution No. 2022-282 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
2022-282