HomeMy WebLinkAboutStaff Report 2301-09003.Staff Recommends the Utilities Advisory Commission Accept and Approve the 2023
Wildfire Mitigation Prevention Plan as Presented (Action 7:25 PM – 7:50 PM) Staff: Jim
Pachikara
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Utilities Advisory Commission
Staff Report
From: Dean Batchelor, Director Utilities
Lead Department: Utilities
Meeting Date: June 7, 2023
Staff Report: 2301-0900
TITLE
Staff Recommends the Utilities Advisory Commission Accept and Approve the 2023 Wildfire
Mitigation Prevention Plan as Presented
RECOMMENDATION
Staff recommends that the Utilities Advisory Commission receive the presentation of the 2023
Wildfire Mitigation Plan.
EXECUTIVE SUMMARY
The purpose of this report is to present to the UAC the annual Wildfire Mitigation Plan (Plan).
Following this public meeting and opportunity for public comment, staff will submit the Plan to
the California Wildfire Safety Advisory Board by July 1, 2023 as required by law. Attachment A is
the Plan and Attachment B is a report by an Independent Evaluator who reviewed the Plan.
BACKGROUND
State law1 requires electric Investor and Publicly Owned Utilities to annually develop and submit
a Plan setting out specific ways in which the utility will prepare for and mitigate against possible
wildfires ignited by its electric equipment. The Plans are limited in geographic scope to the areas
previously identified as a high fire threat area by the California Public Utilities Commission’s State
Fire map2. For Palo Alto, this is the Foothills area.
The City of Palo Alto Utilities Department (CPAU) submitted the initial Plan in 2020, with updates
following in 2021 and 2022.3 This year, CPAU staff presents a revision of the original Plan, in
1 State Law
https://leginfo.legislature.ca.gov/faces/codes_displaySection.xhtml?sectionNum=8387.&lawCode=PUC
2 CPUC State Fire Map https://www.cpuc.ca.gov/industries-and-topics/wildfires/fire-threat-maps-and-fire-safety-
rulemaking
3 The initial Plan was reviewed and approved by the City Council on January 21, 2020 [[internal note, MT number is
10670]]. The first update to the Plan was presented to the UAC on June 2, 2021 [[MT number 12190]], and the
second update was presented to the UAC on June 8, 2022 [[MT number 14175]]. Legally, review by the City Council
is not required and only occurred for the inaugural report. The legal statue does require presentation of each Plan
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accordance with state law requiring a ”comprehensive revision of the Plan” at least once every
three years. The term “comprehensive revision” is legally undefined and subject to
interpretation. Consistent with other Publicly Owned Utilities, CPAU understands the law to
intend for a complete, renewed review of the Plan, rather than the less intensive ongoing updates
required in other years.
As such, staff prepared the 2023 Plan anew while reviewing (1) statutorily mandated elements,
(2) general suggestions4 from the Wildfire Safety Advisory Board,5 (3) information about specific
projects, and (4) feedback from the Independent Evaluator’s Report. Regarding (4), CPAU
retained Dudek to independently review the Plan to determine its efficacy, legal compliance, and
provide suggestions for improvement. Retaining an outside expert to review this Plan is not a
legal mandate; however, CPAU felt doing so for our very first comprehensive revision was
prudent and in the best interests of the community.
Utilities key mitigation activity is undergrounding eleven miles of electric lines in the Foothills
area. This project involves installing substructure work, including boxes for electric and fiber
lines; removing electric lines and fiber lines from poles; and installing padmount equipment
where possible. This iterative project consists of multiple phases and is expected to be complete
in 2025. Staff has completed the installation of 2.38 miles of substructure and is designing the
next two. The actual undergrounding of some lines and pole removals is expected to begin
FY23/24.
FISCAL/RESOURCE IMPACT
Neither the UAC presentation nor the Wildfire Mitigation Plan itself have any immediate resource
impacts besides the staff time to coordinate and develop the plan and the corresponding
presentation. Ongoing and proposed activities listed in the Plan are and will be approved annually
through the Capital and Operating Budget processes.
STAKEHOLDER ENGAGEMENT
The annual presentation of the Plan in a publicly noticed meeting provides an opportunity to hear
and accept comments from the public, other local and state agencies, and interested parties.
ENVIRONMENTAL REVIEW
iteration in an appropriately noticed public meeting; as such, staff brings the latest Plan to the UAC each year.
There is no mandate for formal acceptance, a vote, or a resolution, just that the public is offered an opportunity to
comment.
4 California Wildfire Safety Advisory Board https://energysafety.ca.gov/wp-content/uploads/wsab-wmp-pou-
guidance-advisory-opinion-adopted.pdf
5 Staff notes that in its Guidance Advisory Opinion for the 2023 Wildfire Mitigation Plans of Electric Publicly Owned
Utilities and Rural Electric Cooperatives, the Wildfire Safety Advisory Board (Board) offered no substantive
comments for improvement for CPAU. In fact, on page 10, the Board commended CPAU and a few other POUs “for
providing detailed and comprehensive [Plans] providing specific information above and beyond the template used
by many POUs.” And on pages A3-42 and 43, the Board “appreciates,” “thanks, “applauds,” and “greatly
appreciates” CPAU’s Plan multiple times.
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The UAC’s receipt of this report is not a project requiring California Environmental Quality Act
review, because it is an administrative governmental activity which will not cause a direct or
indirect physical change in the environment.
ATTACHMENTS
Attachment A: 2023 Wildfire Mitigation Plan
Attachment B: Independent review report from Dudek
Attachment C: Presentation
APPROVED By:
Dean Batchelor, Director of Utilities
Staff: Jim Pachikara, Acting Electric Engineering Manager
2023 Utilities Wildfire Mitigation Plan
Adopted by the Utilities Advisory Commission on June 7, 2023
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TABLE OF CONTENTS
I. Utility overview and context...................................................1
A. Context table ...........................................1
B. Statutory cross-reference table ..................2
C. Process for WMP adoption ........................2
D. Plan location on the website......................3
II. Plan purpose and objectives................................................3
A. Summary .................................................3
B. Scope ......................................................4
C. Plan objectives .........................................5
III. Roles and responsibilities .....................................................6
A. City of Palo Alto Utilities Department .........6
B. Coordination with other departments ........7
C. Deenergization-related communication ......9
IV. Electric-line ignited wildfire risk drivers with prevention and
mitigation efforts ..........................................................................9
A. Primary risk drivers and specific mitigation efforts..9
B. Primary risk driver and specific mitigation effort…..10
C. Other electric equipment-specific mitigation strategies…11
D. Enterprise-wide Safety Risks ....................13
E. Current and prior activities ......................13
V. Monitoring the plan.............................................................14
A. Measuring Plan and inspection performance……..14
B. Performance and outcome metrics ..........14
C. Applying previous Plan metrics to this Plan15
D. Independent evaluation of this 2023 Plan.16
Appendix A: Wildfire-related activities.......................................17
Appendix B: Independent evaluator report ...............................20
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2023 Wildfire Mitigation Plan
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I. UTILITY OVERVIEW AND CONTEXT
A. Context table
City of Palo Alto
Size in Square Miles 26 square miles
Assets Distribution
Number of Customers Served 29,849 residential and business customer accounts
Customer Classes Residential and Small/Medium Business
Location/Topography Urban
Percent Territory in
CPUC High Fire Threat Districts 40% in Tier 2 0 % in Tier 3 (PUC ArcGIS map)
CAL FIRE FRAP Map Fire Threat
Zones
40% High Approx. based on visual interpretation of map.
Existing Grid Hardening Measures Undergrounding
Impacted by another utility’s PSPS? Yes, as a transmission dependent utility, Palo Alto could be impacted by a
PG&E PSPS.
Mitigates impact of another utility’s
PSPS? Yes
Expects to initiate its own PSPS?
At this time, no. But as this report covers a one-year period, we cannot say
for certain. The last PSPS event Palo Alto initiated was on September 6,
2022, affecting approximately 1,700 customers for about 30 minutes. We
reenergized lines quickly upon learning that the deenergizing request was
made after a miscommunication between CAISO and NCPA.
Prevailing wind directions
& speeds by season
Please refer to Cal Fire’s Santa Clara Unit 2021 Strategic Fire Plan for
information about wind regional wind conditions
2023 Wildfire Mitigation Plan
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B. Statutory cross-reference table
Code section Pertaining to Page
8387(b)(2)(A)Accounting of responsibilities 6
8387(b)(2)(B)Plan objectives 5
8387(b)(2)(C)Preventive strategies and programs to minimize risk 9
8387(b)(2)(D)Metrics used to evaluate Plan’s performance 14
8387(b)(2)(E)Current Plan informed by previous Plan’s metrics 14
8387(b)(2)(F)Protocols related to deenergizing and public safety impacts 11
8387(b)(2)(G)Customer notification around deenergizing 9
8387(b)(2)(H)Vegetation management 10
8387(b)(2)(I)Electrical infrastructure inspection plans 14
8387(b)(2)(J)A list of wildfire risks and drivers 9
8387(b)(2)(K)Area that is a particularly high wildfire threat 4
8387(b)(2)(L)Wildfire and safety risk methodology 9
8387(b)(2)(M)Restoring service after a wildfire 12
8387(b)(2)(N)Process to monitor Plan, identify any execution deficiencies, and audit
inspection effectiveness
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8387(b)(3)Present Plan in an appropriately noticed public meeting 2
C. Process for WMP adoption
Palo Alto is a bit unique among POUs in that we have a Utilities Advisory Commission (UAC). This
commission is comprised of residents who meet monthly to provide advice to our City Council and
staff on utilities-related matters, including our Wildfire Mitigation Plan (Plan). A Brown Act body,
the UAC agendas are published in advance of each public meeting and opportunities for comment
are provided. Each year, Palo Alto staff presents our Plan at a UAC meeting where we accept any
com
2023 Wildfire Mitigation Plan
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ments and receive feedback from Commissioners.1 Minutes and videos of past meetings are
available on the City’s website. This Plan revision and accompanying independent evaluation report
was presented at the June 7, 2023 UAC meeting.
D. Plan location on the website
Palo Alto’s Plan is the first substantive item found on our Utilities Department safety webpage.
Navigating to this page from our main department page takes only two clicks and is intuitive. Users
click on “Utilities Services and Safety,” then “Wildfire Mitigation.” This year, we streamlined the
information on the webpage to make it more easily readable by listing the specific links to current
and past plans. Because our city also has a Fire Department and an Office of Emergency Services
that respond to fires and other emergencies, we briefly note for readers how this wildfire Plan
differs from others.
II. PLAN PURPOSE AND OBJECTIVES
A. Summary
This Plan is written in compliance with Public Utilities Code section 8387 and describes how the City
of Palo Alto’s Utilities Department (CPAU) maintains and operates our electrical lines and
equipment in a manner that minimizes the risk of wildfire posed by those lines and equipment. As a
comprehensive revision to our prior Plans, we took a fresh look at how best to produce this report
and provide relevant information. As such and as the Wildfire Safety Advisory Board correctly
predicted in its 2022 guidance opinion, we do not include redlines from our 2022 Plan. All the
content in this Plan is new.
1 We note that while the Board asks on page A1-1 of its 2023 POU WMP Guidance Advisory Opinion that POUs “describe the
process by which the governing body” adopts Plans, such is not legally required. PUC 8783(b)(3) requires a POU to “present
its wildfire mitigation plan in an appropriately noticed public meeting…[and] shall accept comments on its wildfire
mitigation plan from the public….” While not our governing board, the UAC meetings meet the legal requirement of a
noticed public meeting where comments from the public are accepted.
2023 Wildfire Mitigation Plan
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B. Scope
The scope of this Plan is limited to providing information about mitigating electric line-ignited
wildfires. We make a distinction between mitigating for possible electric line-ignited wildfires
versus wildfires or wildfire suppression generally. The latter two are in the scope and under the
purview of trained fire experts, such as our city’s Fire Department, and not within the expertise of
utility engineers and technicians.2 The former is within the scope of CPAU responsibilities and is the
subject of the state code section mandating this Plan. Therefore, it is our sole focus.
Additionally, this Plan applies to the only area in our city identified as a high fire threat area in the
California Public Utilities Commission (CPUC) State Fire Map. As of 2022, the high fire threat area in
Palo Alto is all areas with the city limits west of Highway 280, which we refer to as the Foothills
Area. (See below image). This area is about 8-square miles, is sparsely populated, and consists
primarily of open space.
Lastly and per the Board’s request of all POUs, in this updated Plan we deliberately omit general
information the Board already understands in favor of specific information about our territory, our
infrastructure, and our projects. For example, the Board already knows that CPAU, and other POUs,
meet all applicable GO 95 standards; we do not reiterate that here. To avoid redundancy, we also
do not include appendixes submitted in prior years, although we may refer to them. This is not to
short shrift our efforts, but rather to acknowledge that both CPAU and the Board have limited
resources to write and review Plans, the Board has already reviewed the appendixes and offered
guidance, and recycling past information is not as helpful as providing new information.
2 In our 2021 report, we attached as “Appendix A” our Fire Department’s Palo Alto Foothills Fire Management Plan Update;
it can be viewed at: https://www.cityofpaloalto.org/files/assets/public/oes/plans/foothills-fire-management-plan-update-
2016-final.pdf
2023 Wildfire Mitigation Plan
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C. Plan objectives
The Plan’s primary objective is to help guide CPAU staff in minimizing the probability that our
distribution system may be an original or contributing source for wildfire ignition. We strive to
ensure that our infrastructure is safe and resilient by taking proactive actions to maintain our
equipment, refine our existing Public Safety Power Shutoff protocols as needed, and underground
the electric lines in our single high fire threat area.
High fire threat area also known as the Foothills area.
2023 Wildfire Mitigation Plan
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A secondary objective is to improve the resiliency of our distribution system and a final goal, to
measure the efficacy of our mitigation strategies. Please see Appendix A for a listing of mitigation
projects.
III. ROLES AND RESPONSIBILITIES
A. City of Palo Alto Utilities Department
Palo Alto residents and businesses
Palo Alto City Council
Palo Alto City Manager
Director, Utilities Department
Manager,
Electric
Operations
Senior Electric
Engineer
Asist. Director, Electric Division
Power
Engineers
Utilities
Supervisors
Utilities Advisory Commission
Manager, Communications Manager, Compliance
Communications
Coordinator
This chart reflects only the CPAU
positions with a role related to the
subject of this Plan.
2023 Wildfire Mitigation Plan
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In Palo Alto, the City Council is our governing body. As noted above, the UAC is the Brown Act body
that provides advice on utilities-related matters. CPAU operates and maintains all the utilities in the
city, including electric, water, gas, fiber, and wastewater. The Department also employs
communications staff to engage with the community and a Compliance Manager who, among other
duties, ensures reports such as this Plan are completed timely and appropriately.
The electric staff noted above all play a role in preventing electric-line ignited wildfires. Specifically, our
engineers produce safe and resilient designs and oversee fire mitigation projects.3 Our operators
inspect, repair, and maintain our equipment while flagging any potential causes for concern. Our
communications team produces safety communication material to our community and our compliance
manager ensures we meet or exceed laws and regulations.
B. Coordination with other departments
As one part of a larger body, CPAU works closely with other departments and internal divisions. These
include our Public Works Department and its Urban Forestry and Environmental Services Divisions, the
Fire Department, the Office of Emergency Services, and the Engineering and Operations team for our
water utility. Together, these departments and divisions proactively prepare for wildfires, act to
mitigate climate and fire-related risks, maintain electric and water infrastructure, develop plans for
deenergization events, ensure appropriate vegetation management, and lead Palo Alto’s robust
climate action efforts. As these divisions, departments, and teams are under the umbrella of one City,
there is a strong history of working together closely.
For example, during the January 2023 storm events, the above departments held daily calls to share
information on immediate needs, infrastructure repairs, and communication received from external
agencies. In less urgent times, these departments work together to prepare reports, conduct inter-
division meetings on the status of projects of joint interest, and collaborate on how best to engage the
community to proactively provide utilities-related information.
3 To keep the public informed of CPAU’s capital improvement projects, we place related information on our website. This
information includes the name(s) of those responsible for the projects.
2023 Wildfire Mitigation Plan
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Public Works’ Urban Forestry
Division employs Foresters
who work with Utilities to
ensure appropriate tree
clearance standards.
The staff of the City’s Office of
Emergency Services work to
prevent, mitigate against, and
prepare for hazards of all types.
They are trained to communicate
with the community and other
agencies during emergencies in
ways Utilities staff is not.
The Fire Department not only plans for and responds to wildfires but is also trained on best practices in
communicating with the community and other agencies during wildfires.
2023 Wildfire Mitigation Plan
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C. Deenergization-related communication
CPAU’s communications staff is responsible for engaging the community about deenergization events.
In doing so, and in deciding whether to deenergize lines, CPAU utilizes the “Utilities Wildfire Mitigation
Response and Communications Procedure for Public Safety Power Shutoff.”4 This procedure includes
proactively sending to customers a specific recorded message to customers living in the Foothills area,
and a more general but still targeted message to all customers. These messages are sent prior to
deenergizing lines, to allow residents time to act, if necessary.
Palo Alto also sends emails to Foothills residents, with specific information about conditions that may
prompt deenergization, the anticipated dates and times of a shutoff, how to prepare, and where to
find more information. During a deenergization event, CPAU continues to email and call customers.
The calls and emails prior to and during any shutoffs are supplemented with frequent information
posted on CPAU’s website and social media accounts.
IV. ELECTRIC-LINE IGNITED WILDFIRE RISK DRIVERS
WITH PREVENTION AND MITIGATION EFFORTS
A. Primary risk drivers and specific mitigation efforts
Palo Alto recognizes that the Board is most interested in specific risks unique to each POU and its
service territory rather than general risks carried by all electric utilities. As such and as we are in the
process of undergrounding the lines in our only high fire threat area, we note only the risk associated
with the equipment in the Foothills area. The more general risks Palo Alto regularly mitigates, but does
not belabor here, include:
Electric system operating, management, and construction practices
4 This document was previously provided to the Board as Attachment G in Palo Alto’s 2022 Plan. As a newer procedure that
remains accurate, it has not been updated since our submittal.
2023 Wildfire Mitigation Plan
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Weather, including high winds
Extended drought
With regard to weather monitoring, Palo Alto installed a weather station in the Foothills area, allowing
staff direct, localized weather data. CPAU staff also monitor regional conditions, receive red flag
warnings, and communicate with our first-responder departments on any actions needed due to
weather conditions.
B. Primary risk driver and specific mitigation effort
Vegetation type, density, and management practices. Risks include vegetation intruding into power
lines, falling onto lines, or roots damaging undergrounded equipment. Mitigation efforts include
ongoing physical inspections, ensuring the proper type of vegetation is placed at the correct distance
from equipment, and adherence to our City’s Line Clearing Program and our Tree Technical Manual for
proper care of trees. Palo Alto is fortunate to have a dedicated Urban Forestry Division within our
Public Works Department, staffed by trained and experienced urban foresters. These individuals
regularly evaluate every tree twice each year in our high fire threat area with a potential for contact
with our electric lines.
In addition, for the foothills area, Urban Forestry uses an enhanced vegetation management buffer as
shown in the diagram below:
This practice exceeds GO 95
minimum standards for the
voltage. Specifically, a 4-foot
radial clearance is the
minimum required in high
fire danger areas for lines
between 750 volts and
300kv; Palo Alto has a
minimum of 10 feet and a
target of 12 feet for all
circuits in the foothills.
2023 Wildfire Mitigation Plan
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Additionally, other jurisdictions sharing a border with our high fire threat area are just as interested in
vegetation management. For example, in November and December 2022, the Los Altos Hills County
Fire District engaged in a project to clear vegetation along a two-mile route adjacent to a road running
through both Palo Alto and Los Altos. This project involved pruning trees and clearing the area of
vegetation and debris to ensure a safe evacuation route in the event of a wildfire, while providing safe
entry and exit points for first responders.
Palo Alto utilizes a variety of vegetation treatment methods to reduce the risk of wildfire, including
tree or branch removal, trimming, mowing, brush cutting, discing, and herbicide use. Our Urban
Forestry Department is planning a program to help remove potential fall-ins from trees outside of Palo
alto’s maintenance envelope. In the future, to help staff track and manage flammable new growth,
Palo Alto may utilize GIS and growth modeling. Currently, this work is performed manually with
physical inspections.
C. Other electric equipment-specific mitigation strategies
Disabling certain reclosures. In the Foothills area, we have two reclosers on the distribution line
that automatically open when they sense a large amount of current flowing due to a fault. After
a preset delay, they both can automatically reclose; however, as a method to minimize fire risk,
the reclosing function is permanently disabled on both reclosures and at the circuit breaker of
the substation serving this area. Restoring service intentionally requires manual reclosing,
which occurs only after staff have physically inspected the lines, performed any needed repairs,
and ensured that the outage cause is removed. While this practice means potentially longer
outage times, it is an important risk mitigation activity.
Utilizing specific fuses. We utilize non-expulsion fuses in our high fire threat area. Specifically,
CPAU utilizes Eaton’s Cooper PowerE series ELFE fuse, a full range, current-limiting dropout
fuse with a self-contained design that eliminates noise and expulsive showers. If these fuses
explode, any hot metal is contained within the fuse holder, preventing contact with vegetation.
Deenergizing, then reenergizing when prudent. We consider deenergizing our lines as a last
resort, realizing that while the lack of power could be an inconvenience for some, it can also
cause significant health and safety concerns for others. However, we will utilize this option
when necessary to minimize the risk of an electric-line ignited wildfire in our high fire threat
area. Factors we consider when determining whether to deenergize include:
o The possible safety impacts to our customers
o Any fire activity in the vicinity
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o Any evacuation orders and other information from emergency personnel
o Information from local fire agencies, vegetation staff, and our own operators
o Local and regional weather conditions including wind, humidity, precipitation and any
red flag warnings
o The state of vegetation in the area (ie: very dry)
Restoring power after a wildfire or deenergization event. Lines will only be reenergized
when (1) the risk has passed, (2) the lines are inspected, and (3) any needed repairs
are complete. CPAU utilizes a Public Safety Power Shutoff (PSPS) policy and
procedure5 when determining whether to deenergize lines because of a wildfire risk.
Our written protocol also includes customer notification procedures and
reenergization information. In addition to customer notification from the Utilities
Department, PSPS communication is also coordinated with staff of Palo Alto’s Office of
Emergency Services. The decision to institute a PSPS also includes working with
CPAU’s water utility staff to determine if we should pump water up to the reservoirs
located in the Foothills area in advance of shutting off power to ensure there is
sufficient water and water pressure for any firefighting activities.
Coordination with PG&E. As a transmission-dependent utility, CPAU communicates with
PG&E regarding their potential deenergization events that may impact our service
territory.
Studying device coordination strategies. Staff has engaged in protective device coordination
studies to ensure that any fault is isolated quickly and any impact limited. Based on these
studies, we changed our fuse type and size, as noted above, on distribution lines and changed
relay settings for reclosers and a station circuit breaker.
5 The Draft PSPS Policy and Process was included as Appendix G in our 2019 Wildfire Mitigation Plan and the final version
was included as Appendix F in our 2022 update. As noted above and as the Board has received the same information twice
already, we do no re-submit it here for a third time. Information on PSPS events can also be found on our webpage here.
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D. Enterprise-wide Safety Risks
Palo Alto’s protocol for identifying and addressing enterprise-wide safety risks is a collaborative
effort with various City departments. Together the goal is to prevent, protect from, mitigate,
respond to, and recover from hazards and threats. The City’s Office of Emergency Services (OES)
leads that coordination with City departments with the goal of developing, maintaining, and
sustaining a citywide, comprehensive, all hazard, risk-based emergency management program that
engages the whole community. The following reports and plans have been developed and are
updated to provide information regarding the risks in Palo Alto and the necessary actions to take.
- Threat and Hazard Identification and Risk Assessment Report6 - The result of the THIRA
process is an organized evaluation of vulnerability and implementation measures based on the
necessary capabilities to deal with the natural and non-natural hazards and threats of most
concern.
- Local Hazard Mitigation Plan7 - Identifies and prioritizes potential and existing hazards across
jurisdictional borders, including hazards that may be further amplified by climate change, and
provides mitigation objectives with prioritized actions.
- Foothills Fire Management Plan8 - Addresses a broad range of integrated activities and
produced planning documents to address and mitigate the impacts of fire hazards in the Palo
Alto Foothills Area.
E. Current and prior activities
Our earlier Plans note mitigation tasks our city has already completed, such as preparing a Foothills
Fire Mitigation Plan and acting as “territory lead” for the CPUC’s fire threat map. Additionally, prior
Plans note ongoing efforts, which continue. These include regular vegetation management, inspection
and maintenance of our electric system, and electric infrastructure designs that consider fire safety.9
Attachment A shows the status of our mitigation-related activities.
6 The Threat and Hazard Identification and Risk Assessment Report can be found here.
7 The Local Hazard Mitigation Plan can be found here.
8 The Foothills Fire Management Plan can be found here.
9 See Palo Alto’s 2022 Wildfire Mitigation Plan, pages 13-18 for more information.
2023 Wildfire Mitigation Plan
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V. MONITORING THE PLAN
A. Measuring Plan and inspection performance
In preparing our annual Plans, we take the opportunity to evaluate our current Plan for any
deficiencies, or if any best practices have changed. In doing so, we consider what, if anything, related
to wildfires occurred in our high fire threat area. Any events related to wildfires or our electric
infrastructure in this area could inform our future Plans and help us understand the effectiveness of
our current Plan.
Since we began submitting these annual reports, we have had no wildfires in our high fire threat area.
We have had zero wires down events, and no incidences that required an unplanned inspection. We
also had no incidents in the Foothills area during the January 2023 storms.
With regard to inspections, we examine our electric equipment in our high fire threat area more
frequently than in other areas of our service territory. We strive to ensure that all inspections are
completed by June, before the historic start of fire season, or earlier, depending on drought conditions.
Inspections are completed manually. Staff analyzes the results of the inspections for trends of any
failures or maintenance needs, which can inform future design changes. Staff also monitors the
performance of equipment during windy and raining weather as described in the metrics below.
B. Performance and outcome metrics
CPAU audits the effectiveness of our Plan’s mitigation and prevention efforts by using two broad
metrics: performance and outcomes. Information specific to each are below:
i. Performance metrics
a. Vegetation management. This metric includes the amount of vegetation cleared or
number of trees trimmed in the high first threat area.
b. Infrastructure maintenance in high fire threat area. Includes the number of
equipment and lines inspected and repaired (if needed) in the high fire threat area.
c. Project status. This metric involves monitoring the progress of any projects related
to preventing electric-line ignited wildfires in our high fire threat area and ensuring
that projects progress on the proper timeline.
2023 Wildfire Mitigation Plan
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ii. Outcome metrics
a. Electric-line ignited wildfire. This metric includes any fire started by CPAU’s electric
equipment in our high fire threat area that traveled greater than one linear meter
from the ignition point. In at least the past 20 years, there have been zero such fires.
b. Downed lines in our high fire threat area. For purposes of this Plan, a wires down
event includes any instance where an electric line in the high fire threat area of our
service territory falls to the ground or on to a foreign object. CPAU will not normalize
this metric by excluding unusual events, such as severe storms. Instead, we will
supplement this metric with a qualitative description of any such unusual events.
C. Applying previous Plan metrics to this Plan
Our initial Plan specified two metrics for evaluating performance. Below, we discuss each and how
they have informed this revised Plan:
i. Outages to the overhead lines in the high fire threat area
In our 2020 Plan, we described how we would evaluate any outages in our high fire threat area.
(Page 21). We also noted a related project in Appendix F, rebuilding the overhead lines, the status of
which is presented below in Appendix A. Our evaluation of any outages in the high fire threat area
described in 2020 remain: Determine if our activities (a) should have prevented any outages, (b)
were adequate to prevent an outage, (c) could be improved, and (d) could not have prevented an
outage. This evaluation and this metric remain for 2023 because they properly inform our efforts in
preventing outages.
Since January 1, 2020, we have had 10 outages in the Foothills area. None were a result of a PSPS
event or weather-related. Most were caused by animal activity in this heavily wooded area or a car
hitting a pole. However, trees contacting equipment also caused outages.
ii. Fire ignitions
An important metric, we stated in our 2020 Plan that we would provide the number of fires
occurring in our high fire threat area that were less than 10 acres in size, specifically describing any
fires larger than 10 acres. Since January 1, 2020, we have had zero wildfires in our high fire threat
area over 10 acres with no calls to 911 to report of a fire of any size. We have had four smaller fires
with ignition sources that do not include City infrastructure, but from sources such as vehicle fires or
2023 Wildfire Mitigation Plan
16
hot coals thrown in a dumpster. All fires were quickly extinguished by either private individuals or
City personnel.
If we experience any wildfires in this area, whether ignited by our electric infrastructure or not, we
will work with our Fire Department, Office of Emergency Services, and any related local government
agency to review the cause, how or if our equipment related to the cause or was impacted, and
collaborate on any after-action activities.
With this new Plan, we add one more metric:
iii. Wires down
This metric includes instances of any electric lines or conductors that fall to the ground or comes in
contact with a foreign object in our high fire threat area. For each wires down event, CPAU will
utilize an evaluation system similar to our outage evaluation, reviewing the cause, what actions may
have prevented the event, and if there are areas for improvement.
D. Independent evaluation of this 2023 Plan
CPAU contracted with Dudek to perform a comprehensive evolution of this Plan. The final
evaluation report, included here as Attachment B, was presented at a public UAC meeting on June 7,
2023.
CPAU staff realize that there is no legal mandate to retain an independent evaluator on an ongoing
basis. We do so this year as this Plan is our first comprehensive revision and we find value in a
review the first time we fully revise this document. However, this does not convey an intent to
continue the practice going forward, not when we can utilize internal resources in the form of
specially trained fire and vegetation staff. The decision about contracting for an independent
review in the future will depend on factors such as CPAU’s resources, any events in our high fire
threat area, the status of our undergrounding project, any significant changes to our Plan, and so
on.
2023 Wildfire Mitigation Plan
17
APPENDIX A: WILDFIRE-RELATED ACTIVITIES
Our key mitigation activity is undergrounding
eleven miles of electric lines in the Foothills
area. This project involves installing
substructure work, including boxes for electric
and fiber lines; removing electric lines and
fiber lines from poles; and installing pad-
mount equipment where possible.
This iterative project consists of multiple
phases and is expected to be complete in
2025. CPAU already installed two of four
required substructures and is designing the
next two. The actual undergrounding of lines is
expected to begin mid-2023.
Image is a high-level visual representation of
the project area, timeline, and how many feet
below the surface equipment will be placed.
2023 Wildfire Mitigation Plan
18
ADDITIONAL MITIGATION ACTIVITIES
Activity Description Status Projected
completion date
Utilizing fiberglass Some poles will remain in our high fire threat
area once lines are all underground. We will use
new fiberglass crossarms when replacement is
needed to enhance resiliency.
CPAU engineering staff finalized the
design and specifications for
fiberglass crossarms and ordered
the necessary materials. Shipping
constraints delayed shipment;
materials were received in the
Spring of 2023.
2024
Fiber optic extension Concurrently with the above project, we will
design and install new fiber optic cable to
enhance the communications capability in our
high fire threat area.
Segments of underground
communication conduit are being
installed along with the electric
substructure work, phase by phase.
Two phases are complete with two
more in development.
Summer 2025
Emergency generators Installing emergency backup generators at the
water pumping stations and wastewater lift
station in our high fire threat area.
Staff is working on the requirements
for each site. Staffing shortages
have delayed this project.
2024/2025
Wood pole inspection To ensure proper infrastructure maintenance,
this project involves inspecting, testing,
This is a regular, reoccurring project. June 2023
2023 Wildfire Mitigation Plan
19
treating, and reinforcing 700 wood utility poles
through our territory.
SCADA switch to
facilitate
deenergization
To facilitate the ability to quickly shut off power
on the line serving our high fire threat area,
CPAU staff will install a remotely operable
switch, providing Electric Dispatch Operators at
our Utility Control Center the capability to
deenergize the line immediately.
We have selected the location of
the remote switch and will install it
while completing the above-
mentioned undergrounding project
Early 2025
Outage Management
System
To provide enhanced customer communication
during outages, CPAU is updating our Outage
Management System. The upgrades will provide
additional functionalities, including the ability to
notify customers and mobilize resources in
response to outages and emergencies, send
updates by email, text, and social media outlets,
and improve customer service.
Implementation of the new System
is underway.
August 2023
2023 Wildfire Mitigation Plan
20
APPENDIX B: INDEPENDENT EVALUATOR
REPORT
See attachment B
May 9, 2023, 12108.09
Mr. Jim Pachikara & Mrs. Tabitha Boatwright
City of Palo Alto Utilities Department
1007 Elwell Court
Palo Alto, CA 94303
Subject: Independent Evaluat or’s Report of the City of Palo Alto Utilities Department 2023 Wildfire
Mitigation Plan
1 Introduction
The City of Palo Alto Utilities Department (CPAU) contracted with Dudek to engage in an independent evaluation of
its 2023 Wildfire Mitigation Plan (WMP). This independent evaluation report (Report) describes the technical
review and evaluation of the WMP prepared by the CPAU. The WMP requirements are codified in California Public
Utilities Code (PUC) §8387(b)(2) for publicly owned electric utilities (POUs). PUC §8387(c) requires that an
independent evaluator review and assess the comprehensiveness of a POU’s WMP and issue a summary report. Two
thousand twenty-three is a particularly important year for publicly owned utilities since they are required by PUC
§8387(b)(1) to “At least once every three years, the submission shall be a comprehensive revision of the plan.”
Dudek conducted a review of CPAU’s 2023 WMP from December 6, 2023, to March 20, 2023. The focus of the
evaluation was to determine the comprehensiveness of the City of Palo Alto Public Utilities Department’s WMP
and ensure that the WMP included all elements required under PUC §8387(b)(2) (listed in Attachment A).
In addition to evaluating the elements required by the California Public Utility Code, Dudek reviewed the Wildfire
Safety Advisory Board’s (WSAB) specific guidance for the City of Palo Alto Public Utilities Department published in
their Guidance Advisory Opinion for the 2023 Wildfire Mitigation Plans of Electric Publicly Owned Utilities and
Rural Electrical Cooperatives. ( (Wildfire Safety Advisory Board, 2022)).
This Independent Evaluator’s report contains the following elements: 1.) An overview of the City of Palo Alto
Utilities Department, 2.) A review of the statutory requirements in PUC §8387(b)(2) for publicly owned electric
utilities, 3.) A review of the specific recommendations published by the WSAB for the CPAU 2022 WMP, 4.) the
2022 wildfire mitigation and prevention accomplishments of the CPAU, 5.) An overview of the metrics used in the
CPAU’s WMP, and 6.) A comparison of wildfire risk reduction strategies used by the CPAU to similar utilities and
municipal utility industry standards.
TO: JIM PACHIKARA
SUBJECT: CITY OF PALO ALTO UTILITIES WILDFIRE MITIGATION PLAN INDEPENDENT EVALUATOR’S REPORT
12108.09 2 MAY 2023
2 An Overview of the City of Palo Alto Public Utilities
Department
The City of Palo Alto Utilities Department service territory covers 26 square miles within the Palo Alto city limits in
the southeastern section of the San Francisco Peninsula. While the city limits stretch from the San Francisco Bay
to the ridgelines of the Santa Cruz Mountains, the CPAU services territory is concentrated in urban areas in the
northeast section of the city. The city is bordered by the northeast facing foothills and mountains to the west and
southwest, to the north and south is the densely urban areas of the San Jose valley and San Francisco Peninsula,
and to the east is the San Francisco Bay. The CPAU serves approximately 30,000 customers within the City of
Palo Alto, primarily residential and small/medium business customers. The CPAU’s service territory can be divided
into two categories; the fully developed, urban area east of Interstate 280 (I-280) and the more sparsely
developed areas in the Santa Cruz Mountains to the west of I-280. Most of the wildland urban interface in the
CPAU’s territory lies within the section south and east of I-280 (Carlson, 2022). Development in this section is
sparse and while it accounts for a large portion of the city’s surface area it only contains a small percentage of the
CPAU’s customers. Approximately 40% of their service territory lies within a tier 2 fire threat district, none of the
CPAU service territory is classified as tier 3 (California Public Utilities Commission, 2018). The CPAU owns and
operates transmission and distribution assets with approximately 57% of their electrical lines located
underground. The CPAU does not generate its own electrical power and is reliant of power purchased on the
market and delivered over PG&E lines.
The CPAU’s service territory experiences a typical fire season that lasts from May to September with the area fire
danger moderated by morning fog and overcast skies throughout the summer months. The Bay area typically
experiences diurnal winds with onshore winds during the daytime that diminish after sunset. These on-shore
winds are typically cooler and moister than the on-shore air and helps to moderate the fire danger during the fire
season. As a result, large destructive wildfires are uncommon and there is one recorded instance of a large
wildfire occurring within 5 miles of CPAU’s service territory (CAL FIRE, 2022).
TO: JIM PACHIKARA
SUBJECT: CITY OF PALO ALTO UTILITIES WILDFIRE MITIGATION PLAN INDEPENDENT EVALUATOR’S REPORT
12108.09 3 MAY 2023
3 Statutory Requirements for Wildfire Mitigation Plans
A . Statutory Requirement Overview
PUC §8387(b)(2) lists the statutory requirements for WMPs. These are the specific elements that the
independent evaluator must review to make its determination for this report. The specific elements that must be
addressed in CPAU’s WMP are included in Table A (see Attachment A) and are summarized here for reference.
• Staff Responsibilities
• General Objectives
• Wildfire risk reduction program descriptions.
• The metrics used to evaluate the wildfire mitigation plan's performance.
• How the application of previously identified metrics has informed the wildfire mitigation plan.
• Protocols for reclosers, de-energization, and Public Safety Power Shut-off (PSPS)
• Procedures for community notification and outreach.
• Vegetation Management Plans
• Electrical Equipment and Infrastructure Inspection Plans.
• Description of wildfire risks, and drivers for those risks, throughout the service territory, including design,
construction, operation, and maintenance of equipment and facilities, and topographic and climatological
risk factors.
• Identification of any geographic area in the service territory that is a higher wildfire threat than is
identified in a commission fire threat map.
• Identification of enterprise-wide safety risk and wildfire-related risks.
• How the service will be restored after a wildfire.
• The processes and procedures used to monitor and audit the implementation of the wildfire mitigation
plan, identify any deficiencies, and the effectiveness of electrical line and equipment inspections.
3.1 Detailed Review of Statutory Requirements
A. Mi nimizing Wildfire Risks
PUC §8387(a) requires the following: “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.”
The CPAU’s WMP and the CPAU documents referenced in the WMP comprehensively describes the safety-related
measures that the CPAU follows to reduce its risk of causing wildfires. Dudek has determined that CPAU complies
with this requirement through the design of its system, its operational procedures, and the implementation of
wildfire risk reduction and wildfire response strategies specifically the utility’s commitment to undergrounding its
existing above ground circuits in the High Fire Threat District.
B. Evaluation of WMP Elements
Dudek found that CPAU’s WMP meets the statutory requirements of comprehensiveness per PUC §8387. The
review of the WMP’s elements is summarized relative to the application of the WMP. The table in Attachment A
TO: JIM PACHIKARA
SUBJECT: CITY OF PALO ALTO UTILITIES WILDFIRE MITIGATION PLAN INDEPENDENT EVALUATOR’S REPORT
12108.09 4 MAY 2023
lists each required element for CPAU’s WMP and provides Dudek’s initial assessment of the comprehensiveness
of that element within the WMP that was reported to the CPAU in our first review in February and our final
assessment.
Below is a summary of the WMP elements as required by PUC §8387, including restating sections of the WMP
where applicable.
8387(b)(2)(A): Responsibilities of Persons Responsible for Executing the Plan.
Chapter 3 A of the CPAU WMP comprehensively describes staff responsibilities and functions in the
implementation of their WMP including vegetation management, inspections, system maintenance, and
system design.
8387(b)(2)(B): Objectives of the Wildfire Mitigation Plan
Chapter 2 B of the CPAU WMP comprehensively describes the CPAU’s two objectives.
8387(b)(2)(C): Prevention Strategies and Programs
Chapter 4 in the CPAU WMP describes the utility’s wildfire prevention strategies. The chapter is a
combination of risk-drivers and mitigation strategies. The WMP describes the risk driver and then the
strategy used to address the risk.
8387(b)(2)(D): Metrics and Assumptions for Measuring WMP Performance
Chapter 5 section B describes the metrics the CPAU uses to evaluate the effectiveness of their WMP. Five
metrics are described: three performance metrics and two outcome metrics.
8387(b)(2)(E): Impact of Previous Metrics on WMP
Chapter 5 section C of the CPAU WMP describes the metrics used on previous versions of the WMP
including the data collected by the utility since 2020.
8387(b)(2)(F): Reclosing Protocols
Chapter 4 section C in the CPAU’s WMP describes the utility’s reclosing protocols specifically that there is
only one recloser on lines within their High Fire Threat District and that these reclosers are disabled
specifically to reduce the risk of a wildfire ignition.
8387(b)(2)(G): De-energization Notification Procedures
De-energization is described in Chapter 4 section C and Chapter 3 section C. Chapter 4 describes the
conditions under which de-energization would be considered and who the CPAU would coordinate with to
make the decision to de-energization. Chapter 3 describes who at the CPAU is responsible for notifying
customers of a de-energization event and how the CPAU contacts customers who will be impacted and a
general message. Since the CPAU is dependent on PG&E for power, the CPAU is at risk of shut down
TO: JIM PACHIKARA
SUBJECT: CITY OF PALO ALTO UTILITIES WILDFIRE MITIGATION PLAN INDEPENDENT EVALUATOR’S REPORT
12108.09 5 MAY 2023
initiated by PG&E. CPAU uses the same procedures for notifications regardless of whether the de-
energization is initiated internally or externally.
8387(b)(2)(H): Vegetation Management
Chapter 4 section B of the CPAU WMP comprehensively describes in detail the utility’s vegetation
management program including their clearance standards for surface and aerial vegetation, and the
techniques the CPAU uses to perform vegetation management.
8387(b)(2)(I): Inspections
The WMP does not have a specific section that describes the inspection practices the utility uses. Instead,
the WMP contains several statements mainly in Chapter 4 that describe where and when the CPAU
performs vegetation and equipment inspections.
8387(b)(2)(J)(i): Risks and Risk Drivers Associated with Design and Construction Standards
Chapter 4 in the CPAU WMP describes risks and risk drivers present in the CPAU’s service territory. In the
introduction for the chapter the CPAU clearly states that they have determined vegetation to be primary
risk driver of wildfire in their service territory. Section C contains a brief description of risk drivers associated
with design and construction standards.
8387(b)(2)(J)(ii): Risks and Risk Drivers Associated with Topographic and Climatological Risk Factors
Chapter 4 in the CPAU WMP describes risks and risk drivers present in the CPAU’s service territory. In the
introduction for the chapter the CPAU clearly states that they have determined vegetation to be primary
risk driver of wildfire in their service territory. Section A & B in this chapter provide a more detailed
discussion of climatological and topographical risk drivers.
8387(b (2)) (K): Geographical Area of Higher Wildfire Threat
There is statement in Chapter 2 section B regarding the current extent of the High Fire Threat District in
the CPAU and the utility’s recommendation to maintain the current extent.
8387(b)(2)(L): Enterprise-wide Safety Risks
The WMP describes that the CPAU uses a risk assessment process that has been developed and is
implemented by the City’s Office of Emergency Services (OES). The OES, in collaboration with City
Departments has created several risk assessments and risk management plans that are relevant to the
electrical operations of the CPAU and address wildfire and safety related risks (Threat and Hazard
Identification and Risk Assessment Report, Local Hazard Mitigation Plan, etc.).
8387(b)(2)(M): Restoration of Service
Chapter 4 section C describes the CPAU’s power restoration process after a wildfire or de-energization
event. A full description of their restoration policy is in Appendix B of the WMP.
TO: JIM PACHIKARA
SUBJECT: CITY OF PALO ALTO UTILITIES WILDFIRE MITIGATION PLAN INDEPENDENT EVALUATOR’S REPORT
12108.09 6 MAY 2023
8387(b)(2)(N)(i): Monitoring and Auditing WMP Implementation, 8387(b)(2)(N)(ii): Identifying and
correcting WMP deficiencies, 8387(b)(2)(N)(iii): Monitoring and Auditing the effectiveness of inspections.
Chapter 5 section of the CPAU WMP provides a brief description of how the utility monitors and audits the
implementation of the strategies described in Chapter 4. Chapter 4 also contains statements on how the
CPAU uses inspection results to identify issues and improve their electrical system.
4 Wildfire Safety Advisory Board Guidance Advisory
Opinions
In November 2022 the WSAB published a report (California Wildfire Safety Advisory Board Guidance Advisory
Opinion for the 2023 Wildfire Mitigation Plans of Electric Publicly Owned Utilities and Rural Electrical Cooperatives)
with a description of general recommendations for improving the Wildfire Mitigation Plans for publicly owned utilities
and rural electrical cooperatives (POUs). In addition, the report provided specific recommendations for each utility
that submitted a WMP for review by the board. Dudek reviewed the WSAB’s report, and the section below contains
a summary of each recommendation the WSAB had for the CPAU’s 2022 WMP and whether the 2023 WMP has
addressed the WSAB’s recommendation. It should be noted that the materials published by the WSAB and the
recommendations within are for ‘guidance’ and not statutory requirements.
1. The WSAB likes the added detail about WMP adoption, with plans being presented to the Advisory
Committee. For the 2023 comprehensive revision WMP, these practices should remain, per the proposed
new WSAB WMP template.
The CPAU WMP includes the WMP adoption policy in Chapter 1 section C of the plan.
2. The WSAB greatly appreciates Palo Alto’s additional descriptions of city climate change actions, and
encourages continued attention to this crucial issue, including revisited consideration of drone technology
or explaining in more detail why it is inappropriate in this case.
The 2023 CPAU WMP does not include any statements about the implementation of a UAV or drone aerial
inspection program. The CPAU does not have long stretches of poles where drone technology would be
effective. CPAU will continue to perform visual inspections of the 11 miles of aboveground wires. This
number will decrease as progress is made underground wires in the High Fire Threat District.
3. The WSAB appreciates and commends Palo Alto’s detailed PSPS policies, including the new PSPS customer
communication policy (found in Appendices F and G). In addition, the WSAB welcomes the consideration of
backup generation to potentially limit the customer impact of PSPS and other outages in the area.
The CPAU WMP does not include any discussion of backup generators. Based on the information in the
plan and discussions with CPAU staff, it is the opinion of the Independent Evaluator that this is because
the CPAU has correctly identified the wildfire risk and risk drivers in their service territory and have
determined that the wildfire mitigation efforts are best directed at reducing wildfire risk in the high fire
threat district.
TO: JIM PACHIKARA
SUBJECT: CITY OF PALO ALTO UTILITIES WILDFIRE MITIGATION PLAN INDEPENDENT EVALUATOR’S REPORT
12108.09 7 MAY 2023
4. The WSAB looks forward, as promised in the 2022 Palo Alto WMP, to the consideration of new metrics
(including performance metrics) in the 2023 comprehensive revision WMP, and thanks Palo Alto for
including information in the current WMP about metric tracking results (0 fire ignitions)
The 2023 CPAU WMP contains 5 metrics. These metrics better describe the risk drivers present in the CPAU
service territory and the effectiveness of the WMP wildfire prevention strategies.
5 CPAU 2022 Progress in implementing WMP Wildfire
Prevention Strategies
The CPAU’s 2022 accomplishments for the wildfire prevention strategies described in their WMP were provided by
CPAU staff. The CPAU accomplished the following:
Vegetation Management
For the entire Service Territory:
• 4,689 trees trimmed away from primary and secondary lines.
• 99 electrical services cleared.
• 31 poles cleared of both brush and encroaching trees.
• 11 whole tree removals for Right Tree, Right Place program
• 50 trees trimmed away from streetlights/traffic signals.
In the High Fire Threat District
• 124 Trees trimmed away from primary and secondary lines.
• 15 poles cleared of both brush and encroaching trees.
• 7,000 square feet of access trail cleared of brush.
Inspections
• Completed Inspections in High Fire Threat District in September 2022.
• 11 miles of aboveground wires in the High Fire Threat District
• 202 Poles in High Fire Threat district
• 167 Underground locations (transformers, vaults, load cabinets.)
TO: JIM PACHIKARA
SUBJECT: CITY OF PALO ALTO UTILITIES WILDFIRE MITIGATION PLAN INDEPENDENT EVALUATOR’S REPORT
12108.09 8 MAY 2023
Operational Practices
• An inspection audit was completed by Operations Department, Compliance Team in Fall 2022.
System Hardening
• 84 poles and 340 crossarms have been replaced since July 1st, 2022 (the majority of these are NOT in the
foothills area; we are not able to easily separate this data but will start working on that for next year).
• A total of ~12000ft of substructure install and underground wire pull in the Foothills will be completed by
July 1st, 2023. ~50 poles will be de-energized, and pole removal process will begin next.
6 WMP Metric Overview
Metrics help POUs determine if their wildfire prevention strategies are effective for reducing the risk of a wildfire
ignited by their electrical equipment. In 2020 the California Municipal Utilities Association published a Wildfire
Mitigation Plan template for POUs to use in the preparation of their WMPs. This template included two metrics:
number of fire ignition events and wires down events. These two metrics are general in nature and do not provide
the POU a lot of information about the effectiveness of their wildfire prevention strategies. As POUs have gained
more experience with their WMPs they have either adopted new metrics or added supplemental data such as
location, cause, and whether the event occurred in a HFTD that increases the usefulness of these two metrics.
The CPAU used the two initial metrics plus one additional metric, outages on overhead lines in the High Fire Threat
District in the previous versions of their WMP. The 2023 WMP incorporates three new metrics. The WMP’s five
metrics are organized into two categories: performance metrics and outcome metrics. Performance metrics
includes vegetation management accomplishments, infrastructure maintenance, and system hardening project
status. The outcomes metrics include outages on overhead lines in high fire threat district, new wildfire ignitions
and wires down. The CPAU supplements the data collected for these metrics by including whether metric happened
in or outside of the High Fire Threat District. The CPAU has not begun collecting data for the new metrics yet. A
summary data for the previous metrics is included in the WMP and detailed data shown on Table 1, 2, and 3 below
is based on conversations with CPAU staff.
Table 1: Metric 1-Outages to the overhead lines in the high fire threat area
Date Fire Threat Zone Line Voltage Cause
3/11/2022 Tier 2 12,470V Car hit pole
3/9/2023 Tier 2 12,470V Branch on line
Table 2: Metric 2-Fire Ignitions
Date Fire Threat Zone Line Voltage Cause
n/a Tier 2 - - No fires Reported
TO: JIM PACHIKARA
SUBJECT: CITY OF PALO ALTO UTILITIES WILDFIRE MITIGATION PLAN INDEPENDENT EVALUATOR’S REPORT
12108.09 9 MAY 2023
Table 3: Metric 3-Wires Down
Date Fire Threat Zone Line Voltage Cause
n/a Tier 2 - No wires down Reported
These three metrics with the supplemental data are useful for informing the CPAU about the effectiveness of their
wildfire prevention strategies and if the utility is making progress reducing the risk of a wildfire being started by
their electrical equipment. As the CPAU collects data of its new metrics there is the potential that this new data will
provide CPAU staff with a more accurate assessment of the effectiveness of their WMP and provide some direction
where they can place their wildfire prevention efforts.
7 Comparison of Industry Standards and Similar Utility
Wildfire Prevention Strategies
As part of our review of the CPAU’s 2023 wildfire mitigation plan, Dudek compared the wildfire prevention strategies
described in the plan to the strategies being implemented by POU’s that are like the CPAU in terms of service
territory size, customer class, owned assets, and wildfire risk. The City of Palo Alto is only the city of its immediate
neighbors that has its own public electrical utility. There is only one other POU in the bay area, Silicon Valley Power
(SVP), but is significantly different from CPAU (larger customer base, remote assets, no WUI in the city limits, etc.).
For this independent evaluator’s report Azusa Light and Water (ALW) and the Banning Electric Utility (BEU) were
selected to compare the CPAU’s wildfire prevention strategies to. Th e CPAU, the ALW and BEU have similar assets
including customers and customer population, and all three have a service territory that consists of two sharply
distinct areas; a densely urban area and sparsely developed wildland urban interface. Additionally, all three utilities
are using undergrounding as their principal means to reduce wildfire risk in their high fire threat district. The BEU
and ALW differ from the CPAU in that both of their service territories have experienced several large wildfires where
the CPAU has not.
Vegetation Management
All three utilities implement vegetation management programs that meet GO 95 requirements. The CPAU and BEU
vegetation management programs include the management of surface vegetation around and beneath electrical
equipment with the specific goal of preventing the rapid spread of a new wildfire ignition. Azusa Light and Water
does not have a surface vegetation management program for its assets in the high fire threat district. All three
utilities rely on manual treatment techniques (e.g., crews with hand tools or powered equipment) to complete the
vegetation treatment work. For all three utilities vegetation contact with wires is identified as a significant wildfire
risk driver in the aboveground portions of the system and their vegetation management programs direct most of
their efforts towards tree trimming and the removal of dead trees that could strike their wires.
The CPAU is unique in that their lines run through large open space areas and their vegetation mana gement
program incorporates treatment of the surface vegetation (mowing, dead brush removal, etc.) along roadways in
the the power line right-of-way.
TO: JIM PACHIKARA
SUBJECT: CITY OF PALO ALTO UTILITIES WILDFIRE MITIGATION PLAN INDEPENDENT EVALUATOR’S REPORT
12108.09 10 MAY 2023
System Hardening
Undergrounding
All three utilities utilize undergrounding as one of their primary system upgrade strategies to reduce wildfire risk in
their high fire threat districts. The CPAU completed approximately 7500 ft and the BEU completed approximately
2800 ft of undergrounding. Azusa Light and Water has %100 undergrounding in their high fire thre at district.
Undergrounding is considered an industry standard for reducing the risk of wildfire from electrical equipment and
many POUs have some policy towards its use. The CPAU has a wildfire prevention strategy that incorporates
undergrounding and is making progress in utilizing this strategy.
Equipment Upgrades
The CPAU and BEU ongoing upgrade programs that are designed to reduce the risk of outage, equipment failure,
and new wildfire ignitions. These include:
• Installing animal deterrents such as raptor framing and squirrel guards.
• Replacing wooden pole crossarms with non-combustible fiberglass cross arms
Azusa Light and Power has no above ground wires in the high fire threat district and does not utilize any of these
strategies.
Pole inspection and hardening
The CPAU and BEU both have a pole inspection programs that involve visual inspection and periodic intrusive testing
of wooden utility poles. Both utilities have pole reinforcement programs that include hardening the pole against
wildfire using protective wraps or applications of fire-retardant material.
Recloser Policy
All three utilities have recloser policies for circuits in their High Fire Threat Districts where the recloser is set to
manual reclosing operations.
TO: JIM PACHIKARA
SUBJECT: CITY OF PALO ALTO UTILITIES WILDFIRE MITIGATION PLAN INDEPENDENT EVALUATOR’S REPORT
12108.09 11 MAY 2023
8 Conclusion
The City of Palo Alto Public Utilities Department has prepared a comprehensive Wildfire Mitigation Plan for 2023.
The plan does meet the statutory requirements described in PUC 8387 (b)(2) for a publicly owned utility. The CPAU
has also considered the recommendations of the Wildfire Safety Advisory Board and revised their WMP
appropriately. The CPAU’s WMP with the provided appendices describes a wildfire mitigation program that
accurately assesses the risks and risk drivers present in their service territory and implements preventative
strategies with a focus on undergrounding lines in the HFTD that are effective at reducing the wildfire risk of these
risks and risk drivers.
Based on the wildfire prevention programs described in the WMP and the progress the CPAU has made in its wildfire
prevention programs, the CPAU takes the risk of wildfire in its service territory seriously and is actively working to
the reduce the risk that its equipment starts or aids in the spread of a wildfire.
Sincerely,
________________________________
Jeremy Cawn
Fire Protection Planner
TO: JIM PACHIKARA
SUBJECT: CITY OF PALO ALTO UTILITIES WILDFIRE MITIGATION PLAN INDEPENDENT EVALUATOR’S REPORT
12108.09 12 MAY 2023
References
California Public Utilities Commission. (2018, January 18). CPUC High Fire Threat District (HFTD). Retrieved from
Fire-Threat Maps and Fire-Safety Rulemaking:
https://capuc.maps.arcgis.com/apps/webappviewer/index.html?id=5bdb921d747a46929d9f00dbdb6d
0fa2
Carlson, A. H. (2022, March 31). Wildland-urban interface maps for the conterminous U.S. based on 125 million
building locations. Retrieved from U.S. Geological Survey data release:
https://doi.org/10.5066/P94BT6Q7
Wildfire Safety Advisory Board. (2022). Guidance Advisory Opinion of the 2023 Wildfire Mitigation PLans of
Electric Publicly Owned Utilities and Rural Electrical Cooperatives. Sacramento: Office of Energy
Infrastructure Safety.
Attachment A: CPAU WMP Independent Evaluator’s Report Summary Tables
2023 Palo Alto Utilities WMP IE Report
Summary Tables
CPUC Requirement
Public Utility Code 8387(b)(2) Description of Required Element Initial Review Comment Final Review Comment
A Staff Responsibilities
Needs more information. Describe which staff member
position oversees inspections, vegetation mgmt., training,
community outreach, etc.
Updated. Good.
B General Objectives Good. Three objectives listed. Maybe expand the
description of improving resilience. Good.
C Program Descriptions Good. Appendix A contains a comprehensive description of
mitigation actions being done by CPAU Good.
D Evaluation Metrics
Good. The 2023 WMP introduces five metrics in two
categories: performance and outcome metrics. Three of the
new metrics are the metrics from the 2022 WMP.
Good.
E Lessons learned, metrics
application
Good. Describes how the metric is relevant to the 2023 plan
and provides data since the WMP was created. Good.
F
Protocols for reclosers, de-
energization, and PSPS
mitigation
Good. Good.
G Community Notification
Good. Describe how PAU sends these messages". This
procedure includes proactively distributing a specific
recorded message to customers living in the Foothills area,
and a more general but still targeted message to all
customers. These messages are sent prior to deenergizing
lines, to allow residents time to act, if necessary."
Updated. Good.
TO: JIM PACHIKARA
SUBJECT: CITY OF PALO ALTO UTILITIES WILDFIRE MITIGATION PLAN INDEPENDENT EVALUATOR’S REPORT
12108.09 2 MAY 2023
H Vegetation Management
Needs more information. Describe where brush cutting and
mowing are used and how much clearance around assets is
being created. "Palo Alto utilizes a variety of vegetation
treatment methods to reduce the risk of wildfire, including
tree or branch removal, trimming, mowing, brush cutting,
discing, and herbicide use."
Updated. Good.
I Infrastructure Inspections Good. Minimal.
Good. I recommend
combining all of the
inspection related
statements in the WMP
into one section titled
"Inspections"
J(i) Grid Design, construction, and
operation risks
Needs more information. Describe the risk drivers, for
example "CPAU has lines that run through open space areas
with dense vegetation." This may be a 'common' issue
amongst POUs but it's CPAU specific too. It's also called out
in the city's risk assessment report.
Updated. Good.
J(ii) Vegetation, topographic, and
climate risks
Good. Identifies tree/vegetation contacts as the primary risk
driver in CPAU. Good.
K Identification and expansion of
higher wildfire threat areas Not included
Updated. Good. In the
middle of a paragraph in
Chapter 2 Section B.
L Identify enterprise-wide risk Not included
Updated. CPAU uses a City
of Palo Alto developed risk
assessment process
developed by the City OES.
M Restoration of Service Good. Good.
N(i) Monitoring and auditing of
WMPs Good. Good.
N(ii) Identifying and correcting
deficiencies
Needs more information. Describe how CPAU reviews and
updates your WMP. For example, the updated metrics. Updated. Good.
N(iii) Monitoring asset inspections Good. Good.
TO: JIM PACHIKARA
SUBJECT: CITY OF PALO ALTO UTILITIES WILDFIRE MITIGATION PLAN INDEPENDENT EVALUATOR’S REPORT
12108.09 3 MAY 2023
PAU Specific WSAB
Recommendations
WSAB 2023 POU WMP
Guidance Advisory Opinion
Description of the WSAB
Recommendation Initial Review Comment Final Review Comment
A3-42
The WSAB looks forward, as
promised in the 2022 Palo Alto
WMP, to the consideration of
new metrics (including
performance metrics)
in the 2023 comprehensive
revision WMP,
Good. CPAU re-worked their WMP metrics into two
categories with a total of 5 metrics. Good.
Independent Evaluator's
general WMP Comments
Location Page Initial Review Comment Final Review Comment
1. Utility Overview and
Context
1 Context Table-Prevailing Wind Direction and Speed. The link
does not work. Please provide the text describing prevailing
winds or fix the link.
Corrected.
2. Plan Purpose and Objective 4 Based on past WSAB guidance documents, WSAB wants
quick access to WMP information including attachments, I
recommend including the relevant appendices. To avoid
redundancy, we also do not include appendixes submitted
in prior years, although we may refer to them. This is not to
short shrift our efforts, but rather to acknowledge that both
CPAU and the Board have limited resources to write and
review Plans, the Board has already reviewed the
appendixes and offered guidance, and recycling past
information is not as helpful as providing new information.
CPAU added relevant City
documentation as
appendices to the end of
the document.
Utilities Wildfire Mitigation Plan Update
June 7, 2023
2
Background information
•California legislation (Senate Bill 901) requires electric utilities to prepare a
Wildfire Mitigation Plan and update it annually.
•The Utilities’ Wildfire Mitigation Plan will be updated annually, presented
in a publicly noticed meeting, and submitted to the California Wildfire
Advisory Board by July 1st of each year.
•Every 3 years publicly owned utilities will complete a comprehensive
revision of the plan. 2023 is Utilities’ first revision.
3
Utilities Wildfire Mitigation Plan
Update
▪Objective
Complete a comprehensive revision of
the Wildfire Mitigation Plan.
▪Collaboration
Prepared with assistance and input from
Fire, Urban Forestry, Open Space, Office
of Emergency Services.
▪Evaluation
Staff contracted with an outside
consultant to perform a independent
and comprehensive evaluation of the
plan.
4
Utilities Wildfire Mitigation Plan Updates
1.Rebuild of overhead lines in the Foothills
•Staff installed 2.38 miles of substructure (conduit and boxes) of the 11 miles of
overhead lines.
•The removal of approximately 70 poles will now be scheduled and the
installation of substructure for Phases 3 and 4 will begin summer 2023.
•The anticipated target completion for the project is summer 2025.
2.Independent Evaluation
•CPAU contracted with Dudek to perform a comprehensive evolution of this Plan.
The final evaluation report is included here as Attachment B.
•In summary, the Utilities Wildfire Plan fulfills the requirements of a plan and
meets the statutory requirements described in PUC 8387 (b)(2) for a publicly
owned utility.
5
Discussion
End of Presentation
Questions?
6
Extra Slides
Supporting Information
7
Activities
Activity Description Status Projected
completion date
Utilizing fiberglass Some poles will remain in our high fire threat area
once lines are all underground. We will use new
fiberglass crossarms when replacement is needed to
enhance resiliency.
CPAU engineering staff finalized the
design and specifications for fiberglass
crossarms and ordered the necessary
materials. Shipping constraints delayed
shipment; materials were received in the
Spring of 2023.
2024
Fiber optic extension Concurrently with the above project, we will design
and install new fiber optic cable to enhance the
communications capability in our high fire threat area.
Segments of underground
communication conduit are being
installed along with the electric
substructure work, phase by phase. Two
phases are complete with two more in
development.
Summer 2025
Emergency generators Installing emergency backup generators at the water
pumping stations and wastewater lift station in our
high fire threat area.
Staff is working on the requirements for
each site. Staffing shortages have
delayed this project.
2024/2025
Activity Description Status Projected
completion date
Wood pole inspection To ensure proper infrastructure maintenance, this
project involves inspecting, testing, treating, and
reinforcing 700 wood utility poles through our territory.
This is a regular, reoccurring project. June 2023
SCADA switch to facilitate
deenergization
To facilitate the ability to quickly shut off power on the
line serving our high fire threat area, CPAU staff will
install a remotely operable switch, providing Electric
Dispatch Operators at our Utility Control Center the
capability to deenergize the line immediately.
We have selected the location of the
remote switch and will install it while
completing the above-mentioned
undergrounding project
Early 2025
Outage Management
System
To provide enhanced customer communication during
outages, CPAU is updating our Outage Management
System. The upgrades will provide additional
functionalities, including the ability to notify customers
and mobilize resources in response to outages and
emergencies, send updates by email, text, and social
media outlets, and improve customer service.
Implementation of the new System is
underway.
August 2023
8
Activities -continued