Wildfire Safety Advisory Board Approves Recommendations on the 2022 Wildfire Mitigation Plan Guidelines, Performance Metrics, and Safety Culture Assessment

The Wildfire Safety Advisory Board (the Board) approved Recommendations on the 2022 Wildfire Mitigation Plan (WMP) Guidelines, Performance Metrics, and Safety Culture Assessment at its June 28, 2021, Board meeting.

Assembly Bill 1054, signed into law in July 2019, created the California Wildfire Safety Advisory Board, a board of independent expert advisors, with two primary functions:  First, to advise the new Wildfire Safety Division (WSD) within the California Public Utilities Commission (CPUC) on wildfire safety measures, including plans written by utilities, so the CPUC could more effectively regulate the safety of investor-owned utilities. Second, to review the WMPs submitted by the electric publicly owned utilities and cooperatives (together POU) and provide an advisory opinion. The Wildfire Safety Advisory Board also serves as an additional forum for the public to provide input on the important topic of wildfire safety.

The Board’s approved Recommendations on the 2022 WMP Guidelines, Performance Metrics, and Safety Culture Assessment are available at www.cpuc.ca.gov/wsab.

The Board’s recommendations address eight different topics, and a brief overview is provided below.

1 - STRUCTURE AND SCOPE

• Coordination post- transition: Ensure coordination of WMP evaluation efforts after its transition from the CPUC to the California Natural Resources Agency. Create a team of staff to provide advice to other internal WSD staff and to CPUC decision-makers.
• Topical organization: Restructure the organization of the WMPs around the different mitigation initiatives. 
• Visual aids and illustrative examples: Include illustrative examples, summary tables, and other visual aids to assess the objectives, inputs, outputs, and results of the different mitigation approaches.
• Specific guidance to Small and Multi-Jurisdictional Utilities and Independent Transmission Owners (SMJU) and (ITO): Include separate guidelines for the SMJUs and ITOs and consider relieving them of some of the reporting requirements.

2 - RISK ASSESSMENT

• Data collection, reporting, and Geographical Information Systems: Require utilities to explain how each of the reporting elements fit together and how their departments coordinate data collection amongst each other.
• Reporting modeling methods, assumptions, inputs, and outputs: Require improved reporting on modeling methods, assumptions, inputs, outputs, and decision-making. 
• Reporting decision-making processes: Require more detail about the utilities’ prioritization criteria and how risk modeling outputs are used to make decisions, including specific examples of how mitigation measures were prioritized based on these models. 
• Scientific review and common data platform: Establish a formalized scientific review process and a common data system or platform.

3 - PUBLIC SAFETY POWER SHUTOFFS (PSPS) 

• Risk-Spend Efficiency (RSE) and reducing PSPS: Complete a RSE analysis for each mitigation measure, at the circuit level. Treat PSPS as a risk for the purposes of the RSE calculations.
• Studying the effects of risk toleration above zero: Begin a dialog to determine the appropriate level of risk tolerance so that systems can be engineered to lower the risk of consequence of PSPS. Require the utilities share the methodologies used to determine the level of risk and consequences reduction of PSPS and/or wildfire for each mitigation measure.
• Consequence mapping to reduce risk: Require the use geographical consequence mapping to identify the areas of lower risk to avoid building new overhead lines in highest risk areas within high fire threat districts.
• Evaluation of mitigation efforts and PSPS: Evaluate wind threshold and risk tolerance for lines that have been hardened. Require the utilities conduct independent short and long-term studies that focuses on areas where mitigation efforts have taken place and evaluate the data collected during patrols after a PSPS event.

4 - VEGETATION MANAGEMENT

• Ecosystem and climate change impacts of tree removals: Require the utilities to evaluate tree removal practices. Require consultation with ecologists to reduce environmental impact.
• Environmental impact of vegetation management practices: Require the utilities to evaluate the hazards created by vegetation management programs including vegetation left behind, herbicides, and tree growth regulators.  Include notices of violation from other regulatory agencies in the WMPs.
• Database of tree species: Require the utilities to work together to create a centralized database to track tree species characteristics along different environmental gradients.

5 - SYSTEM DESIGN AND GRID HARDENING

• Emerging Technology: Require the utilities to increase the scope of pilots.
• Workforce protection: Require the utilities to describe their protocols to ensure workforce safety of their workforce.
• Workforce training and Qualified Electrical Workers (QEW): Require more information to evaluate the utilities’ training programs. Require QEWs, or their equivalent, as the minimum qualification for inspections and mitigation efforts concerning utility infrastructure.
• Idle lines and equipment: Require the utilities to evaluate the feasibility of de-energizing idle lines.
• General Order (G.O.) 95 exempt equipment: Track equipment that is exempt from G.O.95 in the WMPs and require more information on wildfire mitigation measures for this equipment.
• Asset inspection cycles and safety: Require the SMJUs to follow the POUs and IOUs best practices for visual and detailed inspections, including, requiring more frequent detailed, invasive inspections.

6 - EMERGENCY PLANNING AND COMMUNICATION

• Stakeholder outreach: Incorporate the outcome of the PSPS proceedings (I.19-11-013 and R.18-12-005) in stakeholder outreach. Utilize the PSPS reporting framework established in I.19-11-013.
• Measuring effectiveness of outreach efforts: Analyze the correlation between the quantity of contacts and effectiveness of the outreach methods. 
• Community outreach performance metrics: Include additional performance metrics to measure the success of community outreach efforts.

7 - SAFETY CULTURE ASSESSMENT

• Survey key players: Ensure contractor supervisors and managers complete the self-assessment. Interview a variety of stakeholders including utility managers, contractor managers, utility employees, and contractor workers.
• Pricing structure: Evaluate whether production-based pricing structures leads to more accidents compared to hourly pricing structures.

8 - EXPERTISE TO SUPPORT WILDFIRE SAFETY

• Expertise in utility equipment and climate change: Expand staff expertise and begin evaluating the CPUC General Orders and the requirements for the equipment attached to the electric transmission and distribution infrastructure. Begin evaluating the greenhouse gas impact of wildfire mitigation activities to reduce the impacts of climate change.
• Develop staff expertise: Continue to develop in-house expertise to perform critical analysis and review of the WMPs, conduct safety culture assessments, and ensure compliance with the WMPs.

The June 28, 2021 Board Meeting can be viewed at www.adminmonitor.com/ca/cpuc/wildfire_safety/20210628. 

Additional information is available at www.cpuc.ca.gov/wsab or by emailing WildfireSafetyAdvisoryBoard@cpuc.ca.gov.

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Press Release