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HomeMy WebLinkAboutD-3 Staff Report - Wildfire Mitigation Plan Comprehensive RevisionSCHEDULED ITEM D-3 TO: HONORABLE MAYOR AND MEMBERS OF THE CITY COUNCIL VIA: SERGIO GONZALEZ, CITY MANAGER FROM: TIKAN SINGH, GENERAL MANAGER - AZUSA LIGHT AND WATER DATE: JUNE 19, 2023 SUBJECT: ADOPTION OF THE CITY OF AZUSA REVISED WILDFIRE MITIGATION PLAN DATED JUNE 19, 2023 BACKGROUND: In late 2018, California Public Utilities Commission passed Senate Bill (“SB”) 901. It requires all electric utilities operating in California to adopt wildfire mitigation plans (“WMP”) to ensure that potential causes of wildfire ignition are fully mitigated within high-fire threat zones. In addition, Section 8387 of SB 901 also requires that the utilities update their WMP annually, and perform a comprehensive revision of the WMP every three years. It has been three years since the City Council adopted Azusa Light and Water’s first WMP. As required by SB 901, Azusa WMP is revised and evaluated by an independent evaluator. The proposed action would i) adopt a revised comprehensive wildfire mitigation plan and ii) receive and file an independent evaluation of the Azusa Wildfire Mitigation Plan that concluded that it is comprehensive and meets statutory requirements. RECOMMENDATIONS: Staff recommends the City Council take the following actions: 1) Adopt the revised City of Azusa Wildfire Mitigation Plan dated June 19, 2023; and 2)Receive and file the independent evaluation report prepared by Dudek, Inc. that concluded that the City of Azusa Wildfire Mitigation Plan is comprehensive and meets the statutory requirements of California Public Utilities Code Section 8387. ANALYSIS: SB 901 requires all electric utilities operating in California to adopt wildfire mitigation plans (“WMP”), update the WMP annually, and perform comprehensive revisions every three years. Since the adoption of its first WMP in 2020, Azusa has been submitting updated WMP annually to the Wildfire Safety Advisory Board (“WSAB”). The year 2023 marks the time for Azusa to perform the comprehensive revision of its WMP. As required, staff thoroughly reviewed and updated Azusa’s WMP to ensure it complies with all regulatory requirements of SB 901. Approved City Council June 19, 2023 Approve the City of Azusa Wildfire Mitigation Plan June 19, 2023 Page 2 ALW engaged Dudek, Inc., to review and evaluate the revised WMP. Dudek has reviewed and concluded that the revised WMP is comprehensive and meets the statutory requirements of California Public Utilities Code Section 8387. Dudek’s WMP independent evaluation report, dated May 31, 2023, is attached. FISCAL IMPACT: There is no fiscal impact associated with the adoption of the City of Azusa Wildfire Mitigation Plan. All recommended actions for implementation were included in the 2022-23 Electric Fund operations budget. Prepared by: Reviewed and Approved: Hien Vuong Tikan Singh Assistant General Manager General Manager - Light and Water Electric Operations Reviewed and Approved: Sergio Gonzalez City Manager Attachment: 1) City of Azusa Wildfire Mitigation Plan 2) Wildfire Mitigation Plan Independent Evaluation Report by Dudek CITY OF AZUSA WILDFIRE MITIGATION PLAN Updated June 19, 2023 Attachment 1 Table of Contents 1. STATUTORY COMPLIANCE .............................................................................................. 1 2. PURPOSE AND OBJECTIVES .............................................................................................. 6 3. ELECTRIC DISTRIBUTION FACILITIES IN FIRE THREAT AREAS..................................... 6 4. WILDFIRE RISKS ................................................................................................................ 6 5. WILDFIRE MITIGATION ACTIVITIES ................................................................................ 7 6. PUBLIC SAFETY POWER SHUTOFFS AND CUSTOMER NOTIFICATION .......................... 8 7. PLAN MONITORING AND AUDIT RESPONSIBILITIES .................................................... 10 8. PUBLIC COMMENT, APPROVAL AND INDEPENDENT EVALUATION ............................ 11 Exhibit A: City of Azusa Description Exhibit B: CPUC Fire Threat Zones in Azusa Exhibit C: Azusa Electric Distribution Facilities in Fire Threat Area Azusa Light & Water Wildfire Mitigation Plan 1 1. STATUTORY COMPLIANCE TABLE 1: Context Setting Information Utility Name CITY OF AZUSA Service Territory Size 9.3 square miles Owned Assets Distribution Number of Customers Served 16,500 customer accounts Population Within Service Territory 45,000 people Customer Class Makeup Number of Accounts Share of Total Load (MWh) 87.7% Residential; 1.7% Government; 0% Agricultural; 10.4% Small/Medium Business; 0.2% Commercial/Industrial 42.4% Residential; 4.1% Government; 0% Agricultural; 27.4% Small/Medium Business; 26.0% Commercial/Industrial Service Territory Location/Topography1 100% Urban Percent of Service Territory in CPUC High Fire Threat Districts (based on total area) Tier 2: 2.0% Tier 3: 0% Prevailing Wind Directions & Speeds by Season The average hourly wind speed in Azusa experiences mild seasonal variation over the course of the year. The windier part of the year lasts for 5.9 months, from November 9 to May 7, with average wind speeds of more than 6.6 miles per hour. The windiest day of the year is December 31, with an average hourly wind speed of 8.1 miles per hour. The calmer time of year lasts for 6.1 months, from May 7 to November 9. The calmest day of the year is September 8, with an average hourly wind speed of 5.2 miles per hour. 1 This data shall be based on the California Department of Forestry and Fire Protection, California Multi-Source Vegetation Layer Map, depicting WHR13 Types (Wildlife Habitat Relationship classes grouped into 13 major land cover types) available at: https://www.arcgis.com/home/item.html?id=b7ec5d68d8114b1fb2bfbf4665989eb3. Azusa Light & Water Wildfire Mitigation Plan 2 Miles of Owned Lines Underground and/or Overhead Overhead Dist.: 66 miles Overhead Trans.: 0 miles Underground Dist.: 59 miles Underground Trans.: 0 miles Percent of Owned Lines in CPUC High Fire Threat Districts Overhead Distribution Lines as % of Total Distribution System (Inside and Outside Service Territory) Tier 2: 0% Tier 3: 0% Customers have ever lost service due to an IOU PSPS event? ☐ Yes ☒ No Customers have ever been notified of a potential loss of service to due to a forecasted IOU PSPS event? ☐ Yes ☒ No Has developed protocols to pre-emptively shut off electricity in response to elevated wildfire risks? ☒ Yes ☐ No Has previously pre- emptively shut off electricity in response to elevated wildfire risk? ☐ Yes ☒ No If yes, then provide the following data for calendar year 2020: Number of shut-off events: 0 Customer Accounts that lost service for >10 minutes: 0 For prior response, average duration before service restored: 0 Azusa Light & Water Wildfire Mitigation Plan 3 Table 2: Cross References to Statutory Requirements Requirement Statutory Language Location in WMP Persons Responsible PUC § 8387(b)(2)(A): An accounting of the responsibilities of persons responsible for executing the plan. Section 7 Page 10 Objectives of the Plan PUC § 8387(b)(2)(B): The objectives of the wildfire mitigation plan. Section 2.B. Page 6 Preventive Strategies PUC § 8387(b)(2)(C): A description of the preventive strategies and programs to be adopted by the local publicly owned electric utility or electrical cooperative to minimize the risk of its electrical lines and equipment causing catastrophic wildfires, including consideration of dynamic climate change risks. Section 6 Page 9 Evaluation Metrics PUC § 8387(b)(2)(D): A description of the metrics the local publicly owned electric utility or electrical cooperative plans to use to evaluate the wildfire mitigation plan’s performance and the assumptions that underlie the use of those metrics. Section 8.B(2) Page 11 Impact of Metrics PUC § 8387(b)(2)(E): A discussion of how the application of previously identified metrics to previous wildfire mitigation plan performances has informed the wildfire mitigation plan. Section 8.B(2) Page 11 Deenergization Protocols PUC § 8387(b)(2)(F): Protocols for disabling reclosers and deenergizing portions of the electrical distribution system that consider the associated impacts on public safety, as well as protocols related to mitigating the public safety impacts of those protocols, including impacts on critical first responders and on health and communication infrastructure. Section 6.C. Page 9 Customer Notification Procedures PUC § 8387(b)(2)(G): Appropriate and feasible procedures for notifying a customer who may be impacted by the deenergizing of electrical lines. The procedures shall consider the need to notify, as a priority, critical first responders, health care facilities, and operators of telecommunications infrastructure. Section 6.C. Page 9 Vegetation Management PUC § 8387(b)(2)(H): Plans for vegetation management. Section 5.D. Page 8 Azusa Light & Water Wildfire Mitigation Plan 4 Inspections PUC § 8387(b)(2)(I): Plans for inspections of the local publicly owned electric utility’s or electrical cooperative’s electrical infrastructure. Section 5.B. Page 8 Prioritization of Wildfire Risks PUC § 8387(b)(2)(J): A list that identifies, describes, and prioritizes all wildfire risks, and drivers for those risks, throughout the local publicly owned electric utility’s or electrical cooperative’s service territory. The list shall include, but not be limited to, both of the following: (i) Risks and risk drivers associated with design, construction, operation, and maintenance of the local publicly owned electric utility’s or electrical cooperative’s equipment and facilities. (ii) Particular risks and risk drivers associated with topographic and climatological risk factors throughout the different parts of the local publicly owned electric utility’s or electrical cooperative’s service territory. Section 4 Page 7 CPUC Fire Threat Map Adjustments PUC § 8387(b)(2)(K): Identification of any geographic area in the local publicly owned electric utility’s or electrical cooperative’s service territory that is a higher wildfire threat than is identified in a commission fire threat map, and identification of where the commission should expand a high fire threat district based on new information or changes to the environment. Section 3 Page 7 Enterprise- wide Risks PUC § 8387(b)(2)(L): A methodology for identifying and presenting enterprise-wide safety risk and wildfire-related risk. Section 4 Page 7 Restoration of Service PUC § 8387(b)(2)(M): A statement of how the local publicly owned electric utility or electrical cooperative will restore service after a wildfire. Section 6.D. Page 9 Monitor and Audit PUC § 8387(b)(2)(N): A description of the processes and procedures the local publicly owned electric utility or electrical cooperative shall use to do all of the following (i) Monitor and audit the implementation of the wildfire mitigation plan. (ii) Identify any deficiencies in the wildfire mitigation plan or its implementation, and correct those deficiencies. (iii) Monitor and audit the effectiveness of electrical line and equipment inspections, including inspections performed by contractors, that are carried out under the plan, other applicable statutes, or commission rules. Section 7 Page 10 Azusa Light & Water Wildfire Mitigation Plan 5 Qualified Independent Evaluator PUC § 8387(c): The local publicly owned electric utility or electrical cooperative shall contract with a qualified independent evaluator with experience in assessing the safe operation of electrical infrastructure to review and assess the comprehensiveness of its wildfire mitigation plan. The independent evaluator shall issue a report that shall be made available on the Internet Web site of the local publicly owned electric utility or electrical cooperative, and shall present the report at a public meeting of the local publicly owned electric utility’s or electrical cooperative’s governing board. Section 8.C. Page 11 Azusa Light & Water Wildfire Mitigation Plan 6 2. PURPOSE AND OBJECTIVES A. Purpose The City of Azusa (“Azusa”) owns and operates an electric distribution utility in the City of Azusa and provides safe, reliable, sustainable, and affordable electricity to its residents and businesses through its Light and Water Department (as more fully described in Exhibit A). This Wildfire Mitigation Plan (“WMP”) documents that Azusa’s electric distribution facilities within the California Public Utilities Commission (“CPUC”) Tier 2 and Tier 3 Fire Threat Zones (“Fire Threat Area”), as shown in Exhibits B and C, are 100% underground facilities and do not pose a risk of wildfire ignition. Nevertheless, Azusa has routinely inspected and maintained its facilities following CPUC’s General Order (“GO”) 95, and 165 guidelines to further minimize potential risks of wildfire ignition. B. Objectives The objectives of this WMP are as follows: Identifying the ignition sources and wildfire risks related to Azusa’s equipment near the High Wildfire Threat District. Minimizing the sources of ignition near the Fire Threat Area. Improving the resiliency of the electric grid 3. ELECTRIC DISTRIBUTION FACILITIES IN FIRE THREAT AREAS Exhibit C shows only two (2) distribution feeder circuits in the Fire Threat Area, and both circuits are comprised of all-underground facilities. These two circuits are named the Owl and Sierra Madre 12.47 kV circuits. There are currently no plans for system expansion into the Fire Threat Area. Accordingly, no areas have been identified where the commission should expand a high fire-threat district based on new information or changes to the environment. 4. WILDFIRE RISKS Azusa employed a methodology for identifying and presenting enterprise wide safety risk and wildfire-related risk in the development of this WMP, including consultation with local fire authorities and incorporation of industry best practices to identify the following wildfire risks and mitigation strategies. A. General Wildfire Risk: Fires caused by electrical facilities are generally caused by an electrical short circuit, which creates heat and ignites a source of fuel. Localized electrical fires transform into catastrophic wildfires when there is dry and abundant fuel available and wind conditions spread the fire quickly before it can be controlled. Wildfire Azusa Light & Water Wildfire Mitigation Plan 7 prevention programs mitigate ignition sources and fuel availability. B. Ignition Risk: Underground electrical facilities have inherently low ignition risk because the conductors are buried approximately 3-feet below ground, and the conductors are terminated in enclosed concrete vaults or metal cabinets. Any ignition from an electrical fault would extinguish quickly in the absence of fuel. Undergrounding of facilities is one of the most effective form of wildfire mitigation. Overhead electric facilities pose high ignition risk. Protective fuses when operate can expel burnt particles which could ignite nearby dry vegetations. Overhead power lines could also be the ignition cause. When power line is in contact with tree branches or the ground, short circuit creates arc that could ignite fire. ALW had replaced the pole mount fuses with S&C fault tamers on tap lines which serve the residential area on the outskirt of the fire threat zone. ALW also replaced two spans of bare copper wires with insulated tree wires in the back property line of a block of residential area near the edge of the fire threat zone. C. Fuel Risk: The customer service areas served by the underground electrical facilities in the Fire Threat Area are in fully developed residential neighborhoods with no brush or wooded areas that would serve as a fuel source that could grow into a catastrophic wildfire. Also, all premises served in the Fire Threat Area are subject to the Los Angeles County Fire Department Brush Clearance Program, which requires property owners to clear fuel within a 30-foot radius of the structure, which further mitigates wildfire risk. D. Topographic Risks: Azusa is a city in the San Gabriel Valley, at the foot of the San Gabriel Mountains. The mountains to the north of the City have been designated as CPUC Fire-Threat Tier 2 (Elevated) and CPUC Fire-Threat Tier 3 (Extreme). However, there are only two (2) distribution feeder circuits in the Fire threat Area, and both circuits are comprised of all-underground facilities in developed residential areas, and pose limited wildfire risk. E. Climatological Risks: Extended droughts or continued periods of below average rainfall can increase dry vegetative fuel loads lending to the increase in wildfire risk. Prolonged droughts can also weaken or kill trees. High winds can spread wildfires and blow organic and flammable materials into exposed energized equipment. However, since Azusa’s facilities are 100% underground in the Fire Threat Area there are no exposed energized conductors and low fuel subject to climatological conditions in the fully developed residential neighborhoods; therefore, climatological risks are low. The City’s annual vegetation management program, that exists outside of the Fire Threat Area for reliability purposes, clears all vegetation around high-voltage overhead power lines. 5. WILDFIRE MITIGATION ACTIVITIES The City of Azusa 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, including the following programs and activities: A. 100% Underground Facilities in Fire Threat Area: Azusa shall maintain 100% underground facilities in the Fire Threat Area, including any new system expansions Azusa Light & Water Wildfire Mitigation Plan 8 or line extensions. B. Facilities Inspection Program: Azusa will continue to perform annual inspections of all electrical facilities in the Fire Threat Area, in accordance with California Public Utilities Commission (“CPUC”) General Order (“GO”) 165 and promptly repair any issues found pursuant to such inspections. In the fully developed residential subdivision within the tier 2 CPUC fire threat zone, above-ground equipment such as pad mount transformers are routinely inspected and maintained to address the probable cause of fire ignition. In the year 2021, ALW had inspected all the pad mount transformers in the residential subdivision namely “Mountain Cove”, which is in the Tier 2 zones. Any known issues such as rusty transformers or oil- leaked transformers were immediately mitigated. ALW also practices conservative loading philosophy to avoid overloading transformers. C. No Automatic Re-energization into Fire Threat Area: The two feeder circuits serving customers in the Fire Threat Area shall not be automatically re-energized. Manual re- energization shall occur only after a visual inspection of facilities. D. Vegetation Management Program: Azusa has a long-established system-wide annual power line clearance tree trimming program, which clears all vegetation around high- voltage overhead power lines. Clearances are maintained in accordance with CPUC GO 95 using Appendix E as a guideline. This program was established and will continue for system reliability and is not part of this WMP because there are no overhead facilities in the Fire Threat Area requiring vegetation management. All pad mount transformers in the wildfire threat area are placed in front of the properties, where they are surrounded by hardscapes. In the event that a transformer does explode, the risk of spreading fire is extremely low. E. Deployment of Non-Explosion Fuses: ALW replaced traditional protective fuses at each overhead transformer in the residential area near the outskirt of the tier 2 wildfire threat area with non-explosion S&C Fault Tamer fuses. When fault tamers operate, they do not expel burnt elements that could ignite a fire. F. Replacement of Bare Overhead Conductor: ALW replaced two spans of overhead 12KV tap lines with insulated tree-wires in the residential area at the outskirt of the tier 2 fire threat zone. 6. PUBLIC SAFETY POWER SHUTOFFS AND CUSTOMER NOTIFICATION A. Azusa Initiated Public Safety Power Shutoffs (“PSPS”): Given that underground distribution facilities are not subject to increased risk during wind events and have a very low probability of ignition, Azusa does not plan on initiating PSPS for its feeder circuits pursuant to high wind conditions. B. Southern California Edison Initiated PSPS: Azusa imports 100% of its power supply from the California Independent System Operator (“CAISO”) electric grid. SCE is the Azusa Light & Water Wildfire Mitigation Plan 9 Transmission Operator that operates both of Azusa’s substations. SCE has advised Azusa that one of the SCE lines serving Azusa Substation runs partially through the Fire Threat Area and is subject to PSPS. The probability of SCE initiated PSPS for this line is very low because it runs through a commercial/industrial area, and it is not adjacent to an open space fuel source. Also, Azusa Substation is fed from a second sub-transmission line that is capable of carrying the entire station should a PSPS require the line through the Fire Threat Area to be de-energized. However, Azusa maintains good communication with SCE electric operations personnel and is prepared to shed load if required by a PSPS as described. In the event of a PSPS requiring Azusa to interrupt service to its customers, all power shall be promptly restored following the PSPS. ALW would follow the same protocol in restoring power after the normal outage to restore the power following the PSPS which entails: patrolling the circuit, identifying any electrical faults, and restoring power after all threats are removed. C. PSPS Notification of Customers: In the event that SCE were to interrupt one of the lines feeding Azusa Substation pursuant to a PSPS, and the remaining line was unable to reliably carry the entire station, then Azusa would shed load as required to stabilize the distribution system and employ the following customer communication protocols to notify customers of the extent and duration of the interruption: Post notices and updates on the Azusa website and social media. Email critical first responders such as Azusa Police Department, Los Angeles County Fire Department, and Verizon. There are no hospitals or other health care facilities currently operating in Azusa, but the email communication program would extend to any new health care facilities in the future. Call large key account customers, including the critical first responders to ensure clear communication. D. Emergency Management: One of the benefits of having a municipally owned electric and water utility is the close coordination with the first responders of other Departments of the City and the Los Angeles County Fire Department that provides fire and rescue services to the City. When the City Emergency Operations Center is invoked, under the incident command of the Azusa Police Department, Azusa electric utility first responders work collaboratively to manage emergencies affecting electric service, such as fires, PSPS events, earthquakes, floods, etc. The City Emergency Operation Center is organized and operated in accordance with the City’s Local Hazard Mitigation Plan, which available at the following web link: https://azusaca.gov/DocumentCenter/View/41099/D-1-Staff- Report---GPA-2019- 01--LHMP-Adoption?bidId=. Azusa Light & Water Wildfire Mitigation Plan 10 7. PLAN MONITORING AND AUDIT RESPONSIBILITIES A. Metrics: Azusa Light and Water uses three outcome driven metrics to evaluate the effectiveness of the WMP. These metrics are: 1. Number of wildfires ignited by Azusa equipment. Azusa Light and Water will track wildfire ignitions by Azusa’s electrical equipment within the city limits by cause and location. 2. Number of local fires ignited by Azusa equipment. Azusa Light and Water will track fire ignitions by Azusa’s electrical equipment within the city limits by cause and location. 3. Number of fuse or relay operations. Azusa Light and Water will track fire ignitions by Azusa’s electrical equipment within the city limits by cause and location (in or outside of the high fire threat district). B. Impacts of Metrics on the WMP: Azusa Light and Water has undergrounded its wires and equipment in and adjacent to the high fire threat district within city limits. Since the creation of the original WMP, ALW has recorded zero fires ignited because of our equipment. Ninety-six fuse or relay operations have been recorded, all occurring outside of the high fire threat district. These metrics including the zero events recorded for fire ignitions indicate that the ALW wildfire prevention programs, with their focus on undergrounding, continue to be an effective wildfire prevention strategy. Azusa Light and Water plans to continue tracking these metrics as a method of documenting overall WMP success at identifying and addressing wildfire risk. The following Azusa personnel are responsible for the implementation, monitoring, and auditing of the effectiveness of this WMP. C. General Manager: Accountable for the implementation of a WMP that is in compliance with statutory requirements, including the following: Verify that the wildfire mitigation plan complies with all applicable rules, regulations, and standards, as appropriate. Accept comments from the public, other local and state agencies, and interested parties regarding the WMP. Present the WMP and the associated independent evaluation report, as revised, to the Azusa Utility Board every three-year cycle at appropriately noticed public meetings. Submit the initial and subsequent revised versions of the WMP to the California Wildfire Safety Advisory Board on or before July 1 of each calendar year. D. Assistant General Manager - Electric Operations: Responsible for implementing, monitoring, auditing, and updating the WMP, including the following: Implementation: Manage the engineering, procurement, and administration required to fully implement the mitigation programs and activities of the WMP. Azusa Light & Water Wildfire Mitigation Plan 11 Monitor Effectiveness: WMP effectiveness is monitored by tracking the following metrics in the Fire Threat Area since the year 2019 • There is a “0” Number of wildfires ignited by Azusa equipment • There is a “0” Number of local fires ignited by Azusa equipment • There is a “0” Number of fuse or relay operations, including causes . Audit Compliance: Prepare an annual WMP compliance report, Azusa will audit the implementation of the WMP including completion reports for all prevention programs and activities required by the WMP. Azusa will also monitor and audit the effectiveness of inspections including those performed by contractors. • During the week of May 9th, 2022 CPUC Safety and Enforcement Division’s inspector audited ALW distribution system which includes the facilities in the fire threat area. Minor infractions were identified. ALW had mitigated immediately and submitted the report to that agency. • During the week of March 7, 2023. ALW’s contractor - Allied Reliability performed the Infrared Inspection of overhead facilities and pad mount transformers at large commercial sites, and pad mount equipment such as switches and transformers in the Mt. Cove (a subdivision) in the fire threat area Update Plan: Identify WMP deficiencies based on metrics, change in conditions, new prevention technology, and/or change in law, and update the WMP as applicable to correct such deficiencies. The WMP shall be updated comprehensively every three years. Independent Evaluation: Contract with a qualified independent evaluator with experience in assessing the safe operation of electrical infrastructure to review and assess the comprehensiveness of the WMP on an annual basis. Post on Internet: Post the latest version of the WMP and the independent evaluation report on Azusa’s website for public accessibility. 8. PUBLIC COMMENT, APPROVAL AND INDEPENDENT EVALUATION A. Public Comment On December 4, 2019, Azusa staff received comments on the WMP from the Forestry Division of the Los Angeles County Fire Department. All comments received were incorporated into the WMP. The draft WMP was posted on Azusa’s website on December 12, 2019, and the Azusa City Council accepted comments from the public and interested parties prior to approving the WMP. Azusa Light & Water Wildfire Mitigation Plan 12 B. Presentation and Approval On June 12, 2023 Azusa staff presented the WMP at a properly noticed public meeting of the City Council, which was also televised on a local channel, and the WMP was unanimously approved by the Azusa City Council after receiving the presentation and public comment. The WMP will be updated by staff and re-approved by City Council annually. C. Independent Evaluation This WMP has been reviewed by a qualified independent evaluator with experience in assessing the safe operation of electrical infrastructure to review and assess the comprehensiveness of its wildfire mitigation plan. A report from the independent evaluator was presented at a properly noticed City Council meeting on June 12, 2023 and is posted on Azusa’s website. Azusa Light & Water Wildfire Mitigation Plan 13 EXHIBIT A CITY OF AZUSA DESCRIPTION City of Azusa The City of Azusa (“Azusa”) was founded in 1887 and incorporated as a general law city on December 29, 1898. The City is located in the County of Los Angeles, situated 27 miles northeast of the City of Los Angeles, and nestled against the San Gabriel Mountain foothills. The City of Azusa encompasses 9.13 square miles and has a population of approximately 45,000. Educational facilities include 9 public elementary / middle schools, 2 public high schools, 1 private school, and 1 private university. Light & Water Department The Light & Water Department operates and maintains the electric and water utilities for the City and serves approximately 16,500 electric and 23,000 water customers. The Azusa electric utility was the successor to Azusa Electric Light & Power Company purchased in 1904 for $2,300 and formally established its municipal electric utility. Electricity was purchased wholesale from the Sierra Electric Company and then distributed retail to our citizens and businesses. After Southern California Edison acquired Sierra Electric Company in 1917, Azusa began to buy electricity wholesale from SCE. In the early 1980s, Azusa joined several other California municipal utilities allowing the Department to purchase energy in the open market. Azusa is a Distribution Provider, Load Serving Entity, and Scheduling Coordinator operating within the California Independent System Operator (CAISO) Balancing Authority. Azusa has no wholesale generation facilities, and all power is imported through two 69 kV substations interconnected with Southern California Edison Company, the adjacent Transmission Operator. Azusa’s electric distribution feeders operate at 12 kV, and they are both overhead and underground. All newly constructed distribution facilities are required to be underground, and 100% of the existing facilities located in Fire Threat Area are underground facilities, which fully mitigates Azusa’s wildfire ignition risk. EXHIBIT B CPUC FIRE THREAT ZONES IN AZUSA (SEE MAP ON NEXT PAGE) Ci t r u s A v e . Sierra Madre Ave. 1 inch = 1,600 feet Foothill Blvd. ´ CPUC Fire-Threat Tier 2 (Elevated) CPUC Fire-Threat Tier 3 (Extreme) J.Prado California Public Utilities Commission To d d Av e . Ve r n o n Av e . Sa n Ga b r i e l Av e . Az u s a Av e . EXHIBIT C AZUSA ELECTRIC DISTRIBUTION FACILITIES IN FIRE THREAT AREA (SEE MAP ON NEXT PAGE) 12255.05 Mr. Hien Vuong Assistant General Manager-Electrical Operations Azusa Light and Water City of Azusa 729 N. Azusa Avenue Azusa, California 91702 Subject: Independent Evaluator’s Report of the Azusa Light and Water’s 2023 Wildfire Mitigation Plan Dear Hien Vuong: Thank you for the opportunity to review the Azusa Light and Water 2023 Wildfire Mitigation Plan. Dudek is aware that publicly owned utilities like yours strive to operate in a safe and efficient manner, and we are pleased to be able to support Azusa in this effort. Below is our independent evaluation of your Wildfire Mitigation Plan. 1 Introduction Azusa Light and Water (ALW) contracted with Dudek to engage in an independent evaluation of its 2023 Wildfire Mitigation Plan (WMP). This independent evaluation report describes the technical review and evaluation of the WMP prepared by ALW. The WMP requirements are codified in California Public Utilities Code (PUC) Section 8387(b)(2) for local, publicly owned electric utilities (POUs). PUC Section 8387(c) requires that an independent evaluator review and assess the comprehensiveness of a POU’s WMP and issue a summary report. The year 2023 is important for POUs because they are required by PUC Section 8387(b)(1) to comprehensively revise their WMPs “at least once every three years.”. The ALW’s last Independent Evaluator’s report was prepared for the review of their 2020 WMP. Dudek conducted a review of ALW’s 2023 WMP from February 27 to May 5, 2023. The focus of the evaluation was to determine the comprehensiveness of the WMP and ensure it included all elements required under PUC Section 8387(b)(2) (listed in Attachment A). In addition to evaluating the elements required by the PUC, Dudek reviewed the Wildfire Safety Advisory Board’s (WSAB’s) specific guidance for the ALW published in their Guidance Advisory Opinion for the 2023 Wildfire Mitigation Plans of Electric Publicly Owned Utilities and Rural Electrical Cooperatives (WSAB 2022). This Independent Evaluator’s Report contains the following elements: (1) an overview of the ALW, (2) a review of the statutory requirements in PUC Section 8387(b)(2) for local POUs, (3) a review of the specific recommendations published by WSAB for ALW’s 2022 WMP, (4) ALW’s 2022 wildfire mitigation and prevention accomplishments, (5) an overview of the metrics used in the ALW WMP, and (6) a comparison of wildfire risk reduction strategies used by ALW to those used by similar utilities and municipal utility industry standards. May 31, 2023 Attachment 3 TO: HIEN VUONG SUBJECT: INDEPENDENT EVALUATOR’S REPORT OF AZUSA LIGHT AND WATER 2023 WILDFIRE MITIGATION PLAN 2 An Overview of Azusa Light and Water ALW is a municipal utility provider that provides electric service to customers within the city limits of Azusa (City), California. ALW’s service territory covers 9.3 square miles of the San Gabriel Valley. The northernmost portions of the City (north of the Metro train line) extend into the foothills of the San Gabriel Mountains. The west side of the City is defined by San Gabriel Canyon, the large drainage that contains the San Gabriel River and extends northeast into the core of the San Gabriel Mountains. Generally, ALW’s service territory has a south-facing aspect with gentle slopes that becoming increasingly steep moving from south to north. The northern most portions of ALW’s service territory extends into the mountains and ridgelines that define the southernmost peaks of the San Gabriel Mountains, but these mountainous areas are undeveloped, and ALW has no infrastructure outside of a single development in San Gabriel Canyon. ALW’s asset portfolio consists entirely of distribution lines and distribution equipment. ALW’s lines and equipment in the northern third of its service territory (north of Sierra Madre Boulevard) are entirely underground. The remainder of the service territory is a combination of aboveground and belowground wires and equipment. The High Fire Threat District begins north of Sierra Madre Boulevard throughout most of ALW’s service territory so that the transition to underground wires and equipment occurs outside of the High Fire Threat District and in developed, urban areas. Southern California Edison has a transmission line that runs along the west side of the service territory. Including all facilities, equipment, and service lines, 2% of ALW’s service territory lies within a CPUC High Fire Threat Tier 2 area and 0% lies within a CPUC High Fire Threat Tier 3 area. As stated above, ALW’s service territory is contained within Azusa city limits. South of Sierra Madre Boulevard the City is fully urbanized, and there is insufficient vegetation to sustain the growth of a wildfire. North of Sierra Madre Boulevard, development, mainly residential neighborhoods, is interspersed with open space or undeveloped hillsides until the northern most portions of the City where development ends. Approximately 50% of ALW’s service territory is classified as Wildland Urban Interface (WUI) (Radeloff, V.C. 2020), beginning approximately at Foothill Boulevard and extending north to the city limits. ALW ’s service territory experiences a fire season that lasts from April to November during a typical year. Early fall, from September to October, is considered the most critical period due to the combination of Santa Ana winds and low fuel moistures. ALW’s service territory has experienced repeated wildfires since the California Department of Forestry and Fire Protection (CAL FIRE) began recording data on fire perimeters, with more than 20 wildfires occurring within the city limits since 1918 (CAL FIRE 2022). The northern portion of ALW’s service territory, north of Sierra Madre Boulevard, has experienced larger and more frequent fires then the remainder of the City. TO: HIEN VUONG SUBJECT: INDEPENDENT EVALUATOR’S REPORT OF AZUSA LIGHT AND WATER 2023 WILDFIRE MITIGATION PLAN 3 Statutory Requirements for Wildfire Mitigation Plans PUC Section 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 a report. The specific elements that must be addressed in the ALW WMP are included in Attachment A and are summarized here for reference. ▪ Staff responsibilities ▪ General objectives ▪ Wildfire risk reduction program descriptions ▪ The metrics used to evaluate WMP performance. ▪ How the application of previously identified metrics has informed the WMP ▪ Protocols for reclosers, de-energization, and public safety power shut-off ▪ 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 WMP and identify any deficiencies, and the effectiveness of electrical line and equipment inspections 4 Public Utility Code Requirements Dudek found that the ALW WMP meets the statutory requirements of comprehensiveness per PUC Section 8387. The review of the WMP’s elements is summarized relative to the application of the WMP. Dudek’s assessment is in bold text beneath the description of the requirement. The table in Attachment A lists each PUC-required element for the ALW WMP and provides Dudek’s initial and final assessments of the comprehensiveness of that element. Minimizing Wildfire Risks PUC Section 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 ALW WMP comprehensively describes the safety-related measures that the ALW follows to reduce its risk of causing wildfires. Dudek has determined that ALW complies with this requirement through the design of its system, its operations, and the implementation of wildfire risk reduction and wildfire response strategies. The WMP has an TO: HIEN VUONG SUBJECT: INDEPENDENT EVALUATOR’S REPORT OF AZUSA LIGHT AND WATER 2023 WILDFIRE MITIGATION PLAN emphasis on ALW’s commitment to undergrounding its assets in the High Fire Threat District and that program’s effectiveness at reducing wildfire ignition risks. Evaluation of WMP Elements Below is a summary of the WMP elements as required by PUC Section 8387, including restating sections of the WMP where applicable. 8387(b)(2)(A): Responsibilities of Persons Responsible for Executing the Plan. Chapter 7 of the ALW WMP comprehensively describes staff responsibilities and functions in the implementation of the WMP. 8387(b)(2)(B): Objectives of the Wildfire Mitigation Plan Chapter 2, Section B, of the ALW WMP describes the WMP’s three objectives. The objectives are brief but aptly describe the objectives of the ALW WMP. 8387(b)(2)(C): Prevention Strategies and Programs Chapter 5 in the ALW WMP describes ALW’s wildfire prevention strategies. It is comprehensive and emphasizes that undergrounding all equipment in the High Fire Threat District is ALW’s primary strategy. 8387(b)(2)(D): Metrics and Assumptions for Measuring WMP Performance Chapter 7, Section A, of the ALW WMP contains a description of the metrics used by the WMP. 8387(b)(2)(E): Impact of Previous Metrics on WMP Chapter 7, Section B, of the ALW WMP contains a a description of the impacts that the metrics used in the previous of the WMP have had on the current WMP. 8387(b)(2)(F): Reclosing Protocols Chapter 5, Section C of the ALW WMP states that there are no automatic recloser schemes on the two circuits in the High Fire Threat District. 8387(b)(2)(G): De-energization Notification Procedures Chapter 6 in the ALW WMP comprehensively describes ALW’s notification process and the means by which ALW must notify customers (e.g., email to first responders, ALW website). 8387(b)(2)(H): Vegetation Management Chapter 6, Section 6.4 of the ALW WMP contains a comprehensive description of the ALW vegetation management program. Since the utility has undergrounded their equipment in the High Fire Threat District, the ALW’s vegetation management program is limited to urban areas of the City where there are aboveground wires. TO: HIEN VUONG SUBJECT: INDEPENDENT EVALUATOR’S REPORT OF AZUSA LIGHT AND WATER 2023 WILDFIRE MITIGATION PLAN 8387(b)(2)(I): Inspections Chapter 6, Section 6.5 of the ALW WMP comprehensively describes ALW’s inspection program, including the type and frequency of inspections. 8387(b)(2)(J)(i): Risks and Risk Drivers Associated with Design and Construction Standards Chapter 4, Sections A and B of the ALW WMP describe some risk drivers related to design, construction, operation, and maintenance. 8387(b)(2)(J)(ii): Risks and Risk Drivers Associated with Topographic and Climatological Risk Factors Chapter 4, Sections C through E in the ALW WMP provide a comprehensive description of the geographic and climatological factors present across the ALW service territory. 8387(b (2)) (K): Geographical Area of Higher Wildfire Threat Chapter 3 in the ALW WMP states that ALW has examined the High Fire Threat District maps for the ALW and sees no areas where it needs to be expanded. 8387(b)(2)(L): Enterprise-wide Safety Risks The beginning of Chapter 4 of the ALW WMP includes the statement, “Azusa employed a methodology for identifying and presenting enterprise-wide safety risk and wildfire-related risk in the development of this WMP, including consultation with local fire authorities and incorporation of industry best practices to identify the following wildfire risks and mitigation strategies.” The ALW does not have an independent enterprise risk identification and presentation protocol; instead, ALW uses the risk assessment process described in the City’s Local Hazard Mitigation Plan. 8387(b)(2)(M): Restoration of Service Chapter 6, Section B of the ALW WMP includes the statement, “In the event of a PSPS [Public Safety Power Shutoff] requiring Azusa to interrupt service to its customers, all power shall be promptly restored following the PSPS.” 8387(b)(2)(N)(i): Monitoring and Auditing WMP Implementation, 8387(b)(2)(N)(ii): Identifying and Correcting WMP Deficiencies, and 8387(b)(2)(N)(iii): Monitoring and Auditing the Effectiveness of Inspections Chapter 7, Sections C and D of the ALW WMP provide a description of the ALW’s program for monitoring and auditing the WMP, and for identifying deficiencies in the WMP. The WMP organizes the ALW’s actions for reviewing their WMP, identifying deficiencies, and applying corrective actions based on the personnel responsible for the different elements of the WMP. TO: HIEN VUONG SUBJECT: INDEPENDENT EVALUATOR’S REPORT OF AZUSA LIGHT AND WATER 2023 WILDFIRE MITIGATION PLAN 5 Wildfire Safety Advisory Board Guidance Advisory Opinions In November 2022, WSAB published a report with a description of general recommendations for improving the WMPs for POUs and rural electrical cooperatives. At the end of the report, WSAB provided specific recommendations for each utility that submitted a WMP for review. Dudek reviewed WSAB’s report, and the section below contains a summary of each recommendation WSAB had for the ALW’s 2022 WMP and whether the 2023 WMP has addressed the WSAB’s recommendations (WSAB 2022). The materials published by the WSAB and the recommendations within are for guidance only and are not statutory requirements. WSAB did not have any recommendations, revisions, or corrections for the ALW’WMP in the most recent guidance document. TO: HIEN VUONG SUBJECT: INDEPENDENT EVALUATOR’S REPORT OF AZUSA LIGHT AND WATER 2023 WILDFIRE MITIGATION PLAN 6 Azusa Light and Water 2022 Progress in Implementing Wildfire Mitigation Plan Wildfire Prevention Strategies This section describes the ALW’s accomplishments in 2022 for the wildfire prevention program and strategies described in the WMP. Vegetation Management 1 ▪ Vegetation Management Completed (in circuit miles): 108 ▪ Vegetation/Line Clearance Completed (in circuit miles): 108 Inspections • Equipment inspections performed (in circuit miles) including underground equipment inspections: 148 System Hardening • Pole replacement program accomplishments: All poles inspected in 2021; 48 were red tagged in the 2021, and ALW replaced 18 of the red tagged poles in 2022 • Fuse replacement program accomplishments: 26 fuses were replaced with non -expulsive type holders in the High Fire Threat District. • Covered conductors installed: Two spans of wire were replaced next to the Tier 2 High Fire Threat District. • Animal deterrents installed: Covered conductors were installed for lead wire to equipment , and insulators covers were installed. 7 Wildfire Mitigation Plan 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. ALW has adopted three metrics and used them since the creation of the first WMP in 2020. These metrics are number of wildfires ignited by Azusa equipment, number of local fires ignited by Azusa equipment, and number of fuse or relay operations. ALW records fire ignition metric data on an event basis. ALW records fuse or relay 1 ALW performs minimal vegetation management work in the High Fire Threat Districts since their equipment and wires are underground in these areas. TO: HIEN VUONG SUBJECT: INDEPENDENT EVALUATOR’S REPORT OF AZUSA LIGHT AND WATER 2023 WILDFIRE MITIGATION PLAN operations metric data on monthly outage reports. For each event, ALW records the date and time of the event and a description of the cause of the event (if known). Table 1 provides the data recorded from 2020 to 2022 using the three metrics. Table 1. Metric Event Records in 2020–2022 Metric Outside of the HFTD Within the HFTD Fire Ignitions 0 0 Wildfire Ignitions 0 0 Fuse or Relay Operations 96 0 Note: HFTD = High Fire Threat District. These three metrics with the supplemental data regarding date, time, and location of the event for fire ignitions, plus cause of the event for fuse or relay operation, are useful for informing the ALW about the effectiveness of their wildfire prevention strategies. Undergrounding their equipment and locating the aboveground portions of this system in developed areas has reduced the risk of ALW’s electrical equipment igniting a wildfire by removing the common elements of electrical equipment ignited fires, namely overhead wires, vegetation adjacent to the wires, and a receptive fuel bed on the surface. Since performance metrics, such as vegetation management or tree trimming, or outcome metrics that are a precursor to a wildfire ignition, such as wire down events, don’t apply to the ALW, outcome metrics such as new fire ignitions and fuse or relay operations are effective metrics for measuring WMP performance. This independent evaluator’s report finds these three metrics to be acceptable; it would be useful to collect new fire ignition data from other electrical utilities for a comparison in future versions of the WMP. 8 Comparison of Industry Standards and Similar Utility Wildfire Prevention Strategies As part of this review of the ALW 2023 WMP, Dudek compared the wildfire prevention strategies described in the WMP to the strategies being implemented by POUs and accepted electrical industry practices for reducing wildfire risk. ALW’s service territory has the most in common with the adjacent cities of Glendora and Irwindale; however, its immediate neighbors are served by Southern California Edison. For this Independent Evaluator’s Report, Palo Alto Utility (CPAU) and the Moreno Valley Utility (MVU) were selected for comparison to ALW’s wildfire prevention strategies. ALW, CPAU, and MVU are similar in terms of owned assets and the layout of their service territories with an urban core and a sparsely developed foothill or mountainous areas at the edge of their service territories. Additionally, all three utilities use undergrounding as their principal means to reduce wildfire risk in their High Fire Threat Districts. However, CPAU differs from ALW and MVU in that CPAU is in the process of undergrounding the portions of its system in the High Fire Threat District whereas ALW and MVU have already completed this effort. 8.1 Vegetation Management ALW, CPAU, and MVU implement vegetation management programs that meet General Order 95 requirements, including tree trimming and surface vegetation management. Because they have no overhead lines or equipment TO: HIEN VUONG SUBJECT: INDEPENDENT EVALUATOR’S REPORT OF AZUSA LIGHT AND WATER 2023 WILDFIRE MITIGATION PLAN in their High Fire Threat Districts, ALW and MVU perform very little surface vegetation management work, and most of their line clearance tree trimming work is performed in the developed urban areas and away from portions of their territories with sufficient vegetation to sustain a wildfire. 8.2 System Hardening Undergrounding ALW, CPAU, and MVU use undergrounding as their primary strategy for reducing the risk of wildfire being ignited by their equipment and their systems being damaged by a wildfire. ALW and MVU have 100% undergrounded their distribution system in their High Fire Threat Districts. CPAU is in the process of transitioning to underground circuits in their High Fire Threat District. Equipment Maintenance and Upgrades ALW and CPAU have ongoing equipment 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 • Installing covered conductors • Replacing expulsive fuses with non-expulsive fuses CPAU performs these upgrades on the portions of their system not identified for undergrounding, and ALW performs these upgrades on equipment outside the High Fire Threat District. The MVU does not have an equipment upgrade program focused on wildfire risk reduction because their entire distribution system in underground. System Design ALW has construction standards designed to reduce the risk of fire ignited by the failure of their electrical equipment, which include the requirement of undergrounding of all new electrical equipment in the High Fire Threat District. In addition, ALW requires that the aboveground portions (e.g., transformers) of an underground electrical circuit be installed in developed areas along roads so in the event of an equipment failure that leads to a fire, there will be no flammable vegetation around the equipment box. Recloser Policy ALW, CPAU, and MVU do not utilize automatic reclosing schemes on circuits in their High Fire Threat Districts. ALW and CPAU are set to manual re-energization, and in the event of an outage, both utilities do not re-energize until they have inspected their equipment. TO: HIEN VUONG SUBJECT: INDEPENDENT EVALUATOR’S REPORT OF AZUSA LIGHT AND WATER 2023 WILDFIRE MITIGATION PLAN 8.3 Situational Awareness Patrols and Visual Inspec tions All three utilities have electrical equipment and facilities that meet California Public Utilities Commission requirements including the annual visual inspection of their overhead circuits and the routine inspection of underground circuits. 9 Conclusion ALW has prepared a comprehensive WMP for 2023. The WMP meets all statutory requirements described in PUC Section 8387(b)(2) for a POU. In their most recent guidance document, WSAB had no recommended revisions or additions for the ALW WMP. The ALW WMP describes a wildfire mitigation program that accurately assesses the risks and risk drivers present in their service territory and is successful at demonstrating that the ALW’s primary wildfire prevention program of undergrounding wires is an effective strategy for reducing the risk of a wildfire ignition from its electrical equipment. Based on the information available in the WMP and information collected in the preparation of this report, ALW is aware of the wildfire risk present in its service territory and the surrounding foothills of the San Gabriel Mountains. ALW has been proactive in reducing the risk that its equipment and facilities will start a wildfire by requiring the undergrounding of its electrical equipment. Sincerely, ________________________________ Jeremy Cawn Fire Protection Planner TO: HIEN VUONG SUBJECT: INDEPENDENT EVALUATOR’S REPORT OF AZUSA LIGHT AND WATER 2023 WILDFIRE MITIGATION PLAN 10 References Carlson, A.R., Helmers, D.P., Hawbaker, T.J., Mockrin, M.H., and Radeloff, V.C., 2020, Wildland-urban interface maps for the conterminous U.S. based on 125 million building locations: U.S. Geological Survey data release, https://doi.org/10.5066/P94BT6Q7. CAL FIRE (California Department of Forestry and Fire Protection). 2022. Fire Perimeters through 2021. Fire and Resource Assessment Program. October 1, 2022. https://frap.fire.ca.gov/mapping/gis-data/. WSAB (California Wildfire Safety Advisory Board). 2022. Guidance Advisory Opinion for the 2023 Wildfire Mitigation Plans of Electric Publicly Owned Utilities and Rural Electric Cooperative. Office of Energy Infrastructure Safety. Adopted November 16, 2022. Accessed May 31, 2023. https://energysafety.ca.gov/wp-content/uploads/wsab-wmp-pou-guidance-advisory-opinion-adopted.pdf. Attachment A Azusa Light and Water 2023 WMP Review Summary Tables Table 1. PUC 8387 Requirements Public Utility Code 8387(b)(2) Section Description of Required Element Initial Review Comment Final Review Comment A Staff Responsibilities Good. Good. B General Objectives The text in PUC 8387 and the WSAB's guidance documents don't provide specific direction for what a POU's objectives should be. The objectives can be revised to show to how the WMP reduces the POU's risk of wildfire caused by its electrical equipment. I recommend updating/revising the WMP objectives: objective (1) identify Azusa’s electric distribution facilities located within the High Fire Threat District and immediately adjacent to the High Fire Threat District, (2) minimizing the source of ignitions from ALW electrical equipment, (3) resiliency of the electrical grid. Updated. Objectives section revised to described three objectives. Updated objectives are more relevant to wildfire mitigation plan. C Program Descriptions Good. Undergrounding is the ALWs primary wildfire prevention strategy. Good. D Evaluation Metrics Good. Move into its own section with PUC 8387 (b)(2)(E). I recommend explaining how the local fires ignited by Azusa equipment differs from the wildfires ignited by Azusa equipment metric. Updated. Moved into its own section TO: HIEN VUONG SUBJECT: INDEPENDENT EVALUATOR’S REPORT OF AZUSA LIGHT AND WATER 2023 WILDFIRE MITIGATION PLAN E Lessons learned, metrics application Needs more information. Include metric data collected since 2019 and describe why this indicates these metrics are useful for informing on the effectiveness of the plan. Updated. Added a short description of the impacts that the metrics have on the WMP and ALW’s wildfire prevention programs. F Protocols for reclosers, de- energization, and PSPS mitigation Good. ALW does not set circuits for automatic reclosing schemes in the High Fire Threat District. Good. ALW does not set circuits for automatic reclosing schemes in the High Fire Threat District. G Community Notification Good. Good. H Vegetation Management Good. Good. I Infrastructure Inspections Good. Include description of infrared inspections of equipment, aboveground transformers in High Fire Threat Fire District. Good. J(i) Grid Design, construction, and operation risks Good. Describe if there is any aboveground electrical equipment or overhead wires next to the High Fire Threat District that is in location where there is sufficient vegetation to sustain a fire. Good. TO: HIEN VUONG SUBJECT: INDEPENDENT EVALUATOR’S REPORT OF AZUSA LIGHT AND WATER 2023 WILDFIRE MITIGATION PLAN J(ii) Vegetation, topographic, and climate risks Good. Describe weather-related risk-drivers for the Azusa area, i.e., Santa Ana winds, Red Flag Conditions for long periods of high temps/low humidities. Good. K Identification and expansion of higher wildfire threat areas Good. Good. L Identify enterprise-wide risk Needs more information. Describe ALW's process for identifying enterprise-wide risk. Updated. ALW does not use its own risk assessment system. It uses the risk assessment process described in the City’s Local Hazard Mitigation Plan. M Restoration of Service Needs more information. Describe ALW’s process for restoring power after PSPS or after an outage if the procedure is the same. Updated. Describes the ALW's process for restoration of service. N(i) Monitoring and auditing of WMPs Good. Include the annual WMP audit report (CPUC system-wide audit), describe the nature of the audit and the results. Good. Audit results included. Based on conversations with ALW staff, ALW addressed all of the items identified in the CPUC audit. TO: HIEN VUONG SUBJECT: INDEPENDENT EVALUATOR’S REPORT OF AZUSA LIGHT AND WATER 2023 WILDFIRE MITIGATION PLAN N(ii) Identifying and correcting deficiencies Good. Good. N(iii) Monitoring asset inspections Needs more information. Add a description of how the ALW monitors and audits inspections, e.g., ride-a- longs, quality control inspections/re-inspections, etc. Needs more information. Add a description of how ALW monitors and audits inspections, e.g., ride- a-longs, quality control inspections/re-inspections, etc. Table 2. ALW-Specific WSAB Recommendations WSAB 2023 POU WMP Guidance Advisory Opinion Description of the WSAB Recommendation Initial Review Comment Final Review Comment None None The WSAB had no recommendations, revisions, or corrections for the ALW WMP in their most recent guidance document. The WSAB had no recommendations, revisions, or corrections for the ALW WMP in their most recent guidance document. Table 3. ALW WMP Comments Location Page Initial Review Comment Final Review Comment Exhibit C 19 No Comments Text on the map legend was translated to gibberish.