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Home My WebLink AboutStaff Report 2404-29052.City of Palo Alto Utilities Wildfire Mitigation Plan (WMP) Annual Update (ACTION 6:45 PM – 7:15 PM) Staff: Tomm Marshall Item No. 2. Page 1 of 3 Utilities Advisory Commission Staff Report From: Dean Batchelor, Director Utilities Lead Department: Utilities Meeting Date: June 3, 2024 Staff Report: 2404-2905 TITLE City of Palo Alto Utilities Wildfire Mitigation Plan (WMP) Annual Update. RECOMMENDATION Staff recommends the Utilities Advisory Commission accept and approve the updated 2024 Wildfire Mitigation Plan (WMP or Plan). EXECUTIVE SUMMARY The purpose of this report is to present to the UAC the updated annual Plan. Each year, electric utilities are required to update their Wildfire Mitigation Plans, present the Plan in a noticed public meeting, then submit the Plan annually by July 1 of to the California Wildfire Safety Advisory Board (WSAB).1 BACKGROUND California law requires all electric Utilities (Investor and Publicly-Owned Utilities) to annually update and submit a WMP to the WSAB, and to perform a comprehensive revision of the Plan at least once every three years.2 The Plan outlines specific ways in which the utility will prepare for and mitigate against possible wildfire ignition from electric equipment. The WMPs 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 map. For Palo Alto, this is the Foothills area. The City of Palo Alto Utilities Department (CPAU) submitted its initial Plan on January 21, 2020 (Staff Report ID 106703). As required by law, staff has updated the Plan in subsequent years 1 California Wildfire Safety Advisory Board https://energysafety.ca.gov/wp-content/uploads/2023/12//wsab-2024- wmp-pou-advisory-opinion.pdf 2 Public Utility Code 8387 https://leginfo.legislature.ca.gov/faces/codes_displaySection.xhtml?sectionNum=8387.&lawCode=PUC 3 Staff Report ID 10670 https://www.cityofpaloalto.org/files/assets/public/agendas-minutes-reports/reports/city- manager-reports-cmrs/year-archive/2020/id-10670-mini-packet-01212020.pdf?t=53268.17 Item No. 2. Page 2 of 3 2021 (Staff Report ID 121904), 2022 (Staff Report ID # 141755), and performed a ”comprehensive revision of the Plan” last year in 2023 (Staff Report ID #2301-0900).6 Palo Alto Utilities’ primary mitigation activity is undergrounding eleven miles of overhead 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 overhead poles; and installing pad-mounted equipment where possible. This project consists of multiple phases and is expected to be complete in 2025. We have completed the substructure portions for Phase 1, Phase 2, and currently wrapping up Phase 3. We will then be moving onto Phase 4, which is the last phase of the project. Please see Appendix A within the 2024 Plan for a listing of mitigation activities and status. FISCAL/RESOURCE IMPACT Neither the UAC presentation nor the Wildfire Mitigation Plan itself have any immediate resource impacts besides the staff time to monitor, review, and update 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. Additionally, all versions of the plan are posted on the Utilities Department website for public review. ENVIRONMENTAL REVIEW The UAC’s receipt of this WMP 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. To the extent proposed activities in the WMP require CEQA review, environmental review will be addressed when the City reviews the proposed project. ATTACHMENTS Attachment A: Updated 2024 Wildfire Mitigation Plan 4 Staff Report ID 12190 https://www.cityofpaloalto.org/files/assets/public/utilities/id-12190-item-2.pdf 5 Staff Report ID 14175 https://www.cityofpaloalto.org/files/assets/public/agendas-minutes-reports/agendas- minutes/utilities-advisory-commission/archived-agenda-and-minutes/agendas-and-minutes-2022/06-08-2022/06- 08-2022-id-14175-item-3-wildfire.pdf 6 Update” and “comprehensive revision” are undefined in the statute. Palo Alto staff and other POUs interpret “update” to mean bringing the original plan up to date with limited to no significant changes, and “comprehensive revision” to mean an in-depth review of each plan element, with significant changes made as needed to the original plan. Staff report ID 2301-0900 https://cityofpaloalto.primegov.com/meetings/ItemWithTemplateType?id=1404&meetingTemplateType=2 Item No. 2. Page 3 of 3 APPROVED By: Dean Batchelor, Director of Utilities Staff: Tomm Marshall, Assistant Director, Electric & Fiber Utilities WILDFIRE MITIGATION PLAN JUNE 2024 TABLE OF CONTENTS I. Utility overview and context……………………………………………………………………………………………….. 1 A. Context table……………………………………………………………………………………………………………… 1 B. Statutory cross-reference table………………………………………………………………………………….. 1 C. Process for WMP adoption…………………………………………………………………………………………. 2 D. Plan location on the website………………………………………………………………………………………. 2 II. Plan purpose and objectives……………………………………………………………………………………………….. 2 A. Purpose……………………………………………………………………………………………………………………… 2 B. Scope…………………………………………………………………………………………………………………………… 2 C. Plan objectives…………………………………………………………………………………………………………… 3 III. Roles and responsibilities…………………………………………………………………………………………………….. 5 A. City of Palo Alto Utilities Department…………………………………………………………………………. 5 B. Coordination with other departments……………………………………………………………………….. 6 C. Deenergization-related communication……………………………………………………………………… 6 IV. Electric-line ignited wildﬁre risk drivers with prevention and mitigation eﬀorts………………… 7 A. Primary risk drivers and speciﬁc mitigation eﬀorts……………………………………………………. 7 B. Primary risk driver and speciﬁc mitigation eﬀorts: Vegetation type, density, and management practices……………………………………………………………………………………………… 7 C. Other electric equipment-speciﬁc mitigation strategies……………………………………………… 8 D. Enterprise-wide Safety Risks………………………………………………………………………………………. 9 E. Current and prior activities………………………………………………………………………………………… 10 V. Monitoring the plan…………………………………………………………………………………………………………...... 10 A. Measuring Plan and inspection performance……………………………………………………………… 10 B. Performance and outcome metrics……………………………………………………………………………. 11 C. Applying previous Plan metrics to this Plan………………………………………………………………… 11 Appendix A: Wildﬁre Mitigation Activities………………………………………………………………………………….. 13 1 I. UTILITY OVERVIEW AND CONTEXT A. Context table B. Statutory cross-reference table 1 CPUC ArcGIS map @ https://www.arcgis.com/home/webmap/viewer.html. 2 CAL Fire’s Santa Clara Unit 2023 Strategic Fire Plan @ https://cdnverify.osfm.ﬁre.ca.gov/media/aw4hpsgj/2023-santa-clara-unit-ﬁre-plan.pdf. 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 Tier 3 - 0% Tier 2 - 40% CAL FIRE FRAP Map Fire Threat Zones 40% High Approx. based on visual interpretation of CPUC ArcGIS map.1 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? Factors used to identify possible need for PSPS are based on weather forecast and field conditions. Refer to the PSPS Policy and Process. Prevailing wind directions & speeds by Please refer to Cal Fire’s Santa Clara Unit 2023 Strategic Fire Plan for information about wind regional wind conditions. 2 Code section Requirement Page 8387(b)(2)(A) Accounting of responsibilities 5 8387(b)(2)(B) Plan objectives 3 8387(b)(2)(C) Preventive strategies and programs to minimize risk 7 8387(b)(2)(D) Metrics used to evaluate Plan’s performance 11 8387(b)(2)(E) Current Plan informed by previous Plan’s metrics 11 8387(b)(2)(F) Protocols related to deenergizing and public safety impacts 8 8387(b)(2)(G) Customer notification around deenergizing 6 8387(b)(2)(H) Vegetation management 7 8387(b)(2)(I) Electrical infrastructure inspection plans 10 8387(b)(2)(J) A list of wildfire risks and drivers 7 8387(b)(2)(K) Area that is a particularly high wildfire threat 4 8387(b)(2)(L) Wildfire and safety risk methodology 7 8387(b)(2)(M) Restoring service after a wildfire 9 8387(b)(2)(N) Process to monitor Plan, identify any execution deficiencies, and audit inspection effectiveness 10 2 C. Process for WMP adoption Palo Alto is unique among POUs because it has a Utilities Advisory Commission (UAC), an advisory Commission to the City Council. This commission is comprised of Council-appointed residents who meet monthly to provide advice to City Council and staﬀ on utilities-related matters, including the City’s Wildﬁre Mitigation Plan (Plan). A Brown Act body, the UAC publishes agendas in advance of each public meeting and provides opportunities for public comment at each meeting. Each year, Palo Alto staﬀ presents the Plan at a UAC meeting where staﬀ accept any public comments and receive feedback from Commissioners.3 Minutes and videos of past meetings are available on the City’s website. D. Plan location on the website Palo Alto’s Plan is the ﬁrst substantive item found on the Utilities Department safety webpage. Navigating to this page from the Department’s main page takes only two clicks and is intuitive. Users click on “Utilities Services and Safety,” then “Wildﬁre Mitigation.” 4 Because the City also has a Fire Department and an Oﬃce of Emergency Services that respond to ﬁres and other emergencies, this report brieﬂy notes how this wildﬁre Plan diﬀers from other City emergency response plans. II. PLAN PURPOSE AND OBJECTIVES A. Purpose 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 its electrical lines and equipment in a manner that minimizes the risk of wildﬁre posed by those lines and equipment. B. Scope The scope of this Plan is limited to providing information about mitigating the risk of wildﬁres from electric lines and equipment. It distinguishes between mitigating risks of possible electric line-ignited wildﬁres versus wildﬁres or wildﬁre suppression generally. The latter topics are in the scope and under the purview of trained ﬁre experts, such as the city’s Fire Department, and not within the expertise of utility engineers and technicians. The former is within the scope of CPAU responsibilities and is the subject of the state code section mandating this Plan; therefore, it is the sole focus of this Plan. 3 PUC 8783(b)(3) requires a POU to “present its wildﬁre mitigation plan in an appropriately noticed public meeting…[and] accept comments on its wildﬁre mitigation plan from the public….” While not the governing board of the utility, the UAC review satisﬁes the legal requirement of presenting the Plan at a noticed public meeting where comments from the public are accepted. 4 Utilities Department safety webpage @ https://www.cityofpaloalto.org/Departments/Utilities/Utilities- Services-Safety/Safety/Utilities-Wildﬁre-Safety. 8387(b)(3) Present Plan in an appropriately noticed public meeting 2 3 Additionally, this Plan applies to the only area in the City of Palo Alto identified as a high fire threat area in the California Public Utilities Commission (CPUC) State Fire Map. As of 2023, the high fire threat area in Palo Alto includes all areas with the City limits west of Highway 280, referred to as the Foothills Area. (See below, Figure 1). This area is about eight square miles, is sparsely populated, and consists primarily of open space. Lastly and per the Board’s request of all POUs, this updated Plan deliberately omits general information the Board already understands in favor of specific information about the City’s territory, infrastructure, and mitigation projects. For example, the Board already knows that CPAU, and other POUs, meet all applicable GO 95 standards so it is not reiterated here. To avoid redundancy, the Plan omits appendices submitted in prior years, although there may be references to information from prior Plans. This is intended to acknowledge that both CPAU and the Board have limited resources to write and review Plans, the Board has already reviewed the appendices and offered guidance, and recycling past information is not as helpful as providing new information. C. Plan objectives The Plan’s primary objective is to guide CPAU staff in minimizing the probability that the City’s distribution system may be an original or contributing source for wildfire ignition. The City strives to ensure that its infrastructure is safe and resilient by taking proactive actions to maintain its equipment, refine the existing Public Safety Power Shutoff (PSPS) protocols as needed, and underground the electric lines in the only high fire threat area. A secondary objective is to improve the resiliency of the City’s distribution system and to measure the efficacy of the mitigation strategies. 4 Fig. 1: CPAU electric service area, showing high ﬁre threat “Foothills Area”. 5 III. ROLES AND RESPONSIBILITIES A. City of Palo Alto Utilities Department In Palo Alto, the City Council is the governing body of all City functions including the City’s utilities. As noted above, the UAC is a 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. CPAU 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. CPAU’s electric and fiber staff noted above all play a role in mitigating wildfire risk from electric lines and equipment. Specifically, CPAU engineers produce safe and resilient designs, and oversee wildfire mitigation projects such as undergrounding electric lines. 6 Electric Operations staff inspect, repair, and maintain equipment while flagging any potential causes for concern. The CPAU Communications team produces safety communication material to the community, and the Compliance Manager ensures CPAU meets or exceeds laws and regulations.5 B. Coordination with other departments As one division of the City’s utilities department, CPAU’s Electric Utility staff works closely with other utilities divisions and other City departments. These include the Public Works Department and its Urban Forestry and Environmental Services Divisions, the Fire Department, the Office of Emergency Services, and the water utility Engineering and Operations team. 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. 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.”6 This procedure includes proactively sending a specific recorded message to customers living in the Foothills area, and a more general but still targeted message to all electric 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. 5 To keep the public informed of CPAU’s capital improvement projects (CIPs), CPAU places CIP-related information @ https://www.cityofpaloalto.org/Departments/Utilities/Utilities-Services-Safety/Utilities- Projects/Foothill-Fire-Mitigation-Project. This information includes primary staﬀ contact information for the projects. 6 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 that submittal. 7 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 because Palo Alto is in the process of undergrounding the lines in its single high fire threat area, this Plan notes only the risk associated with electric equipment in the Foothills area. The more general risks Palo Alto regularly mitigates, but does not specifically address in this Plan, include: • Electric system operating, management, and construction practices outside the Foothills area • Weather including high winds outside the Foothills area • 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 first-responder departments on any actions needed due to weather conditions. B. Primary risk drivers and specific mitigation efforts: Vegetation type, density, and management practices. Wildfire risks from electric lines and equipment 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 the City’s Line Clearing Program and Tree Technical Manual for proper care of trees. Palo Alto is fortunate to have a dedicated Urban Forestry Division within the Public Works Department, staffed by trained and experienced urban foresters. Twice a year, these individuals evaluate every line- adjacent tree in the high fire threat area with a potential for contact with CPAU electric lines. 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. The Urban Forestry Department is planning a program to help remove potential fall- ins from trees outside of Palo Alto’s maintenance envelope of line-adjacent trees. 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. 8 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 clearance standards for the line 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 maintains a minimum of 10 feet and a target of 12 feet radial clearance for all circuits in the Foothills area. C. Other electric equipment-specific mitigation strategies • Disabling certain reclosures. In the Foothills area, CPAU has 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 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. CPAU utilizes non-expulsion fuses in the 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. CPAU considers deenergizing electric lines as a last resort, realizing that while the lack of power could be an 9 inconvenience for some customers, it could cause significant health and safety concerns for others. However, CPAU will utilize this option when necessary to minimize the risk of an electric-line ignited wildfire in the high fire threat area. Factors CPAU considers when determining whether to deenergize include: o The possible safety impacts to City customers o Any fire activity in the vicinity o Any evacuation orders and other information from emergency personnel o Information from local fire agencies, vegetation staff, and CPAU electric operators o Local and regional weather conditions including wind, humidity, precipitation and any red flag warnings o The state of vegetation in the area (i.e. 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 procedure when determining whether to deenergize lines because of a wildfire risk. The written protocol also includes customer notification procedures and reenergization information.7 In addition to customer notification from the Utilities Department, PSPS communication is also coordinated with 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 the City 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 the City’s 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, CPAU changed the fuse type and size, as noted above, on Foothills area distribution lines and changed relay settings for reclosers and a station circuit breaker. 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 a broad range of potential hazards and threats. The City’s Office of Emergency Services (OES) leads that coordination with the goal of developing, maintaining, and sustaining a citywide, comprehensive, all hazard, risk-based emergency management program that engages the whole 7 The PSPS Policy and Process was included as Appendix F in the City’s 2022 update and has not been updated since then. Information on PSPS events can also be found on the website @ https://www.cityofpaloalto.org/Departments/Utilities/Utilities-Services-Safety/Outages/Public-Safety- Power-Shutoffs. 10 community. The City maintains and updates the following reports and plans that provide information regarding the risks in Palo Alto and the necessary actions to take. - Threat and Hazard Identification and Risk Assessment Report8 - 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 Plan9 - 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 Plan10 - 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 CPAU’s earlier Plans note mitigation tasks the 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 the electric system, and electric infrastructure designs that consider fire safety. Attachment A shows the status of CPAU’s mitigation-related activities. V. MONITORING THE PLAN A. Measuring Plan and inspection performance In preparing annual Plans, CPAU takes the opportunity to evaluate the current Plan for any deficiencies, or if any best practices have changed. In doing so, CPAU considers what, if anything, related to wildfires occurred in the high fire threat area. Any events related to wildfires or City electric infrastructure in the Foothills area could inform future Plans and help understand the effectiveness of the current Plan. Since CPAU began submitting these annual reports, there have been no wildfires in the high fire threat area. With regard to inspections, CPAU examines its electric equipment in the high fire threat area more frequently than in other areas of the service territory. Staff 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, 8 The Threat and Hazard Identiﬁcation and Risk Assessment Report can be found @ https://www.cityofpaloalto.org/files/assets/public/oes/plans/unrestricted_palo_alto_thira_report_final_a pril-2017.pdf. 9 The Local Hazard Mitigation Plan can be found @ https://www.cityofpaloalto.org/files/assets/public/oes/lhmap/paloalto_separateannex_march2017.pdf. 10 The Foothills Fire Management Plan can be found @ https://www.cityofpaloalto.org/ﬁles/assets/public/oes/plans/foothills-ﬁre-management-plan-update- 2016-ﬁnal.pdf . 11 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 the 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 fire threat area. b. Infrastructure maintenance in high fire threat area. This metric includes the amount of equipment and number of 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 mitigating wildfires from electric equipment or lines in the high fire threat area and ensuring that projects progress on the proper timeline. ii. Outcome metrics a. Electric-line ignited wildﬁre. This metric includes any ﬁre started by CPAU’s electric equipment in the 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 the 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 the service territory falls to the ground or onto a foreign object. CPAU will not normalize this metric by excluding unusual events, such as severe storms. Instead, staﬀ will supplement this metric with a qualitative description of any such unusual events. C. Applying previous Plan metrics to this Plan CPAU’s initial Plan speciﬁed two metrics for evaluating performance, each discussed below, and noting how they have informed this revised Plan: i. Outages to the overhead lines in the high ﬁre threat area 12 In the 2020 Plan, staﬀ described how CPAU would evaluate any outages in the high ﬁre threat area. (Page 21). It also noted a related project in Appendix F, rebuilding the overhead lines, the status of which is presented below in Appendix A. CPAU’s evaluation of any outages in the high ﬁre threat area described in 2020 remains: Determine if CPAU’s 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. Both the evaluation and metric remain for this Plan because they properly inform CPAU eﬀorts in preventing outages. Since January 1, 2020, CPAU has 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. ii. Fire ignitions An important metric, CPAU stated in the 2020 Plan that staﬀ would provide the number of ﬁres occurring in the high ﬁre threat area that were less than 10 acres in size, speciﬁcally describing any ﬁres larger than 10 acres. Since January 1, 2020, CPAU has had zero wildﬁres in the high ﬁre threat area over 10 acres with no calls to 911 to report of a ﬁre of any size. If CPAU experiences any wildﬁres in this area, whether ignited by electric infrastructure or not, CPAU will work with the Fire Department, Oﬃce of Emergency Services, and any related local government agency to review the cause, how or if CPAU equipment related to the cause or was impacted and collaborate on any after-action activities. iii. Wires down This metric includes instances of any electric lines or conductors that fall to the ground or come into contact with a foreign object in the high ﬁre threat area. For each wires-down event, CPAU will utilize an evaluation system similar to CPAU’s outage evaluation: reviewing the cause, what actions may have prevented the event, and if there are areas for improvement. 13 APPENDIX A: WILDFIRE MITIGATION ACTIVITIES The City’s key mitigation activity is undergrounding eleven miles of overhead 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 overhead poles; and installing pad- mount equipment where possible. This iterative project consists of multiple phases (Phases 1-4) and is expected to be complete in 2025. CPAU already installed three of four required substructures. This image is a high-level visual representation of the project area, timeline, and how many feet below the surface equipment will be placed. 14 WILDFIRE MITIGATION ACTIVITIES Activity Description Status Projected completion date Undergrounding Phase 1 and Phase 2 Substructure work, installing boxes and padmount equipment, pulling cable, energizing electric lines, and removing electric facilities off of overhead poles. Substructure work for Phases 1 and 2 in Foothills Park is done. Electric lines are now underground, and facilities are energized. Completed 2024 Utilizing Fiberglass Some poles will remain in the high fire threat area once lines are underground. CPAU will use new fiberglass crossarms when replacement is needed to enhance resiliency. Staff completed the fiberglass crossarms design, ordered materials, but faced shipping delays. Materials arrived in Spring 2023. Completed 2023 Outage Management System (OMS) Updating the Outage Management System to provide enhanced customer communication during outages and improve customer service. Implementation upgrades now oﬀer enhanced functionalities, enabling customer notiﬁcations and resource mobilization for outages and emergencies, with updates via email, text, and social media. Completed 2023 Overhead Pole Removal and Fiber Transfer Full removal of aerial facilities in Phases 1 and 2 by the end of the Summer. Fiber cable is still aerial due to long lead times for material, however that material has been received and staﬀ anticipate the full removal of aerial facilities in Phases 1 and 2 by then end of the Summer 2024. Fall 2024 15 Activity Description Status Projected completion date Undergrounding Phase 3 Substructure work, installing boxes and padmount equipment, pulling cable, energizing electric lines, and removing electric facilities oﬀ of overhead poles. Substructure for Phase 3 has been completed on Pony Tracks Fire Road and Page Mill Road. Fall 2024 SCADA switch to facilitate deenergization To facilitate the ability to quickly shut oﬀ power on the line serving the high ﬁre threat area, CPAU staﬀ will install a remotely operable switch, providing Electric Dispatch Operators at the Utility Control Center the capability to deenergize the line immediately. CPAU selected the location of the remote switch and will install it while completing the above- mentioned undergrounding project Spring 2025 Fiber Optic Extension CPAU will design and install new ﬁber optic cable to enhance the communications capability in the high ﬁre threat area. Segments of underground communication conduit are being installed along with the electric substructure work, phase by phase. Summer 2025 Undergrounding Phase 4 Substructure work, installing boxes and padmount equipment, pulling cable, energizing electric lines, and removing electric facilities oﬀ of overhead poles. Phase 4 substructure is under construction along Page Mill Road and Montebello Road. It is expected to reach Montebello Reservoir by year-end. Staﬀ is discussing relocating the Public Utility easement with Mid-Peninsula Open Space to extend installation along Montebello Road beyond Montebello Reservoir. Spring 2025