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Resolution No. 2020-002RESOLUTION NO. 2020-02 A RESOLUTION OF THE CITY COUNCIL OF THE CITY OF VERNON ADOPTING THE VERNON PUBLIC UTILITIES 2020 WILDFIRE MITIGATION PLAN WHEREAS, the City of Vernon ("City") is a chartered municipal corporation of the State of California that owns and operates a system for the generation, purchase, transmission, distribution and sale of electric capacity and energy; and WHEREAS, the City is generally subject to the legislative and regulatory requirements applicable to local publicly owned electric utilities ("POUs"); and WHEREAS, Senate Bill 1028 (Statutes of 2016), adding California Public Utilities Code, Section 8387, requires each POU to 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; and WHEREAS, Senate Bill 901 (Statutes of 2018), amending California Public Utilities Code Section 8387, requires all POUs to prepare a wildfire mitigation plan before January 1, 2020, and annually thereafter; and WHEREAS, California Public Utilities Code Section 8387(b)(2) specifies the content that must be included in each POU's wildfire mitigation plan; and WHEREAS, California Public Utilities Code Section 8387(c) requires each POU to have a qualified independent evaluator review its wildfire mitigation plan to assess the comprehensiveness of its plan and to issue a report that is made available on the POU's website and presented at a public meeting; and WHEREAS, California Public Utilities Code Section 8387(b)(3) requires each POU to present its wildfire mitigation plan at an appropriately noticed public meeting and to verify that its plan complies with all applicable rules, regulations, and standards, as appropriate; and WHEREAS, Assembly Bill 111 (Statutes of 2019), adding California Public Utilities Code Section 326.1, established the California Wildfire Safety Advisory Board; and WHEREAS, Assembly Bill 1054 (Statutes of 2019), amending California Public Utilities Code Section 8387, requires each POU to submit its wildfire mitigation plan to the California Wildfire Safety Advisory Board by July 1 of each year, starting in the year 2020; and WHEREAS, pursuant to California Public Utilities Code Section 326.2, the California Wildfire Safety Advisory Board will review each POU's wildfire mitigation plan and will provide comments and advisory opinions on the content and sufficiency of each plan; and WHEREAS, City staff prepared a wildfire mitigation plan for calendar year 2020, addressing all statutory criteria; and WHEREAS, the City staff verified that the wildfire mitigation plan complies with all applicable rules, regulations, and standards; and WHEREAS, Dudek 6 Associates, Inc. is a qualified independent evaluator and, after reviewing the City's wildfire mitigation plan, has determined that the plan meets the requirements of California Public Utilities Code Section 8387; and WHEREAS, Dudek s Associates, Inc_ has prepared a report that is presented at a public meeting of City's governing board and is posted to the City's website; and - 2 - WHEREAS, by memorandum dated January 21, 2020, City staff has recommended the adoption of the 2020 Wildfire Mitigation Plan; and WHEREAS, the City Council of the City of Vernon desires to adopt the 2020 Wildfire Mitigation Plan, pursuant to California Public Utilities Code Section 8387. NOW, THEREFORE, BE IT RESOLVED BY THE CITY COUNCIL OF THE CITY OF VERNON AS FOLLOWS: SECTION 1: The City Council of the City of Vernon hereby finds and determines that the above recitals are true and correct. SECTION 2: The City Council of the City of Vernon finds that this action does not constitute a "project" pursuant to section 15378(b)(2) of the Guidelines to the California Environmental Quality Act ("CEQA"), because such action constitutes an administrative activity; and even if the adoption of the proposed item did constitute a project, it would be exempt in accordance with CEQA Guidelines section 15061(b)(3), the general rule that CEQA only applies to projects that may have an effect on the environment. SECTION 3: The City Council of the City of Vernon hereby adopts the 2020 Wildfire Mitigation Plan, a copy of which is attached hereto as Exhibit A and made a part hereof. SECTION 4: The City Council of the City of Vernon hereby authorizes the General Manager of Public Utilities, or his designee, to submit the 2020 Wildfire Mitigation Plan to the California Wildfire Safety Advisory Board before July 1, 2020. - 3 - SECTION 5: The City Clerk of the City of Vernon shall certify to the passage, approval and adoption of this resolution, and the City Clerk of the City of Vernon shall cause this resolution and the City Clerk's certification to be entered in the File of Resolutions of the Council of this City. APPROVED AND ADOPTED this 21°C day of January, 2020. AAAO- Name: Melissa' Yb"ra Title: i%Aoe ATTEST: m Vim' Lisa Pope, Cit Clerk APPROVED AS TO FORM: �pr 1 Br a B n, Senior Deputy City Attorney MI! STATE OF CALIFORNIA ) ) ss COUNTY OF LOS ANGELES ) I, Lisa M. Pope, City Clerk of the City of Vernon, do hereby certify that the foregoing Resolution, being Resolution No. 2020-02, was duly passed, approved and adopted by the City Council of the City of Vernon at a regular meeting of the City Council duly held on Tuesday, January 21, 2020, and thereafter was duly signed by the Mayor or Mayor Pro-Tem of the City of Vernon. Executed this Day of January, 2020, at Vernon, California. (SEAL) - 5 - Lisa Pope, 'Citj Clerk EXHIBIT A Wildfire mitIII igation Plan I f GPL�FOgA,, i 1A�'�r•- CITY OF VERNON PUBLIC UTILITIES 4305 S SANTA FE AVE. VERNON, CALIFORNIA 90058 �y r'- ti r E O ,may' cl Version: 1.3 Al. �'r r'lU �9 Effective Date: 11/21/2019 Itl Contents 1. Executive Summary ........................................................................................................1 2. Introduction.....................................................................................................................1 2.1. Policy Statement............................................................................................2 2.2. Organization of the Wildfire Mitigation Plan.................................................2 2.3. City of Vernon................................................................................................2 2.4. Vernon Public Utilities Profile........................................................................3 2.5. Generation and Distribution Facilities...........................................................3 2.6. Wildfire Risk Assessment...............................................................................3 3. Objectives .........................................................................................................................4 4. Roles and Responsibilities.............................................................................................4 4.1. Wildfire Prevention........................................................................................4 4.2. Wildfire Response and Recovery ...................................................................5 4.3. Standardized Emergency Management System............................................5 5. Wildfire Risks and Drivers..............................................................................................6 5.1. Design, Construction, Operation, and Maintenance.....................................6 5.2. Topographic and Climatological Risk Factors.................................................6 6. Enterprisewide Safety Risks..........................................................................................6 7. Wildfire Preventative Strategies..................................................................................7 8. Vegetation Management..............................................................................................7 9. Inspections.......................................................................................................................9 10. De-energization Protocols...........................................................................................10 10.1. Reclosing Policy.........................................................................................10 10.2. De-energization.........................................................................................10 11. Customer Notification Procedure..............................................................................10 12. Restoration of Service..................................................................................................11 13. Evaluation Metrics........................................................................................................11 13.1. Metrics and Assumptions for Measuring Plan Performance ....................11 +rr' Metric 1: Fire Ignitions.......................................................................................... 12 Metric 2: Wires Down.......................................................................................12 14. Impact of Metrics on Plan...........................................................................................12 15. Monitoring and Auditing the Plan..............................................................................13 15.1. Identifying and Correcting Deficiencies in the Plan..................................13 15.2. Monitoring the Effectiveness of Inspections............................................13 16. Independent Auditor....................................................................................................13 17. Acronym Glossary .........................................................................................................14 1. Executive Summary 1.1. The Vernon Public Utilities Wildfire Mitigation Plan meets applicable California Senate Bill 901, Assembly Bill 1054, and Assembly Bill 111 requirements. 1.2. The City of Vernon is an industrial city of S.2 square miles, adjacent to Downtown Los Angeles. Wildfire ignition risks are low due to the sparsity of vegetation and fuel sources in Vernon's industrial environment. 1.3. Vernon is located more than 10 miles from the nearest California Public Utilities Commission (CPUC) High Fire -Threat District Elevated risk area. 1.4. Vernon Public Utilities (VPU) does not own or operate transmission, distribution, or generation facilities in CPUC High Fire -Threat District. 1.5. VPU does not own or operate transmission, distribution, or generation facilities in California Department of Forestry and Fire Protection's (CAL FIRE) Fire and Resource Assessment Program (FRAP) Fire Threat Map's designated High or Extreme Wildfire Hazard areas. 1.6. VPU's Wildfire Mitigation Plan includes required program components such as performance metrics, continuous improvement, and responsible parties. 1.7. VPU will make annual Wildfire Mitigation Plan progress updates to the Vernon City Council and the California Wildfire Safety Advisory Board. 2. Introduction Over the last few years, California has seen some of its most devastating and destructive wildfires. Climate Change is recognized as a contributing factor (long hot spells, low moisture, etc.). In response, Senate Bill (5B) 901 authored by Senator Dodd, was enacted in 2018. SS 901 requires every electric utility to prepare a wildfire mitigation plan (WMP) and annually present the plan to its governing body. SB 901 amended Public Utilities Code (PUC) section 8387. Section 8387 generally requires every publicly owned utility to construct, maintain, and operate its electrical facilities to minimize the risk of wildfire posed by those facilities. As further required by Assembly Bill (AB) 1054 enacted in 2019, the WMP shall be submitted to the California Wildfire Safety Advisory Board for review and advisory opinion by July 1, 2020. At least once every three years, the submittal must be a comprehensive revision of the WMP. This document outlines Vernon Public Utilities' activities in accordance with these requirements. VERNON WILDFIRE MITIGATION PLAN 2020 Page 1 2.1. Policy Statement Vernon Public Utilities' overarching goal is to provide safe, reliable, and economic electric service to its local community. In order to meet this goal, Vernon Public Utilities (VPU) constructs, maintains, and operates its electrical lines and equipment in a manner that minimizes the risk of catastrophic wildfire posed by its electrical lines and equipment. 2.2. Organization of the Wildfire Mitigation Plan This Wildfire Mitigation Plan includes the following elements: • Objectives of the plan; • Roles and responsibilities for carrying out the plan; • Identification of key wildfire risks and risk drivers; • Description of wildfire prevention, mitigation, and response strategies and programs; • Metrics for evaluating the performance of the plan and identifying areas for improvement; and • Review and validation of the plan. 2.3. City of Vernon ,a can The City of Vernon is an industrial city ,... ">E of 5.2 square miles located several Burbank � t_, miles to the southeast of Downtown Glendale Pasadena Los Angeles in Southern California. The City's business -friendly environment, © low-cost utilities, and proximity to west Covina ports, trucking and rail transport make Los Angeles Vernon an ideal location for industrial m East Los ® Pcyof Angeles ® industry ® uses. `- Vernon.F The City of Vernon is located in a Inglewood region of Los Angeles County with low Downey wildfire risk. No part of VPU's servicean ntlo ® ® Brea territory is located in or near the High Compton ® Fullerton Fire -Threat District, designed in the Lakewood California Public Utilities Commission's Torrance ®1 Anaheim (CPUC) Fire Threat Map. Further, all of O o C VPU's service territory is excluded from a i Long Beach Gartfao gle the High, Very High, and Extreme — _-- Threat areas of the California Department of Forestry and Fire Protection's (CAL FIRE) Fire and Resource Assessment Program (FRAP) Fire Threat Map. Based on a review of local VERNON WILDFIRE MITIGATION PLAN 2020 Page 2 conditions and historical fires, the Vernon Fire Department has determined that VPU's electrical lines and equipment do not pose a significant risk of wildfire. Despite this low risk, VPU takes appropriate actions to help its region prevent and respond to the increasing risk of wildfires. In its role as a public agency, VPU closely coordinates with other local safety and emergency officials to help protect against fires and respond to emergencies. In its role as a utility, VPU follows all applicable design, construction, operation, and maintenance requirements that reduce safety risks associated with its system. This Wildfire Mitigation Plan describes the safety -related measures that Vernon Public Utilities follows to reduce its risk of causing wildfires. 2.4. Vernon Public Utilities Profile Formerly known as Vernon Light and Power and Vernon Gas & Electric, the City of Vernon has consolidated all utility services within the Vernon Public Utilities department (VPU). VPU provides electric, water, natural gas, and fiber optic services. VPU serves about 2,000 mainly commercial and industrial electric customers with electric sales of approximately 1,128 GWh annually, and peak loads of approximately 184 MW in the summer and 174 MW in the winter. 2.5. Generation and Distribution Facilities VPU's electric system includes generation and distribution facilities that are completely located within VPU's electric service territory in the LA Basin. VPU does not own or operate any transmission facilities. VPU has two generation facilities that are located within VPU service territory. MGS, a 134 MW combined -cycle natural gas -fired plant and two H. Gonzales units, a combined 10 MW natural gas plant. VPU has 56 miles of distribution lines, and 9 miles of 66 kV subtransmission lines. No overhead distribution lines span over naturally vegetated open space areas. Therefore, there is no potential for electrical equipment igniting a wildfire. The generation and distribution facilities are located entirely within the CAISO balancing area and are connected to the CAISO through the Southern California Edison (SCE) 220-66 kV Laguna Bell Substation. The Vernon load is supplied and supported by five 66 kV source lines that exit the SCE Laguna Bell 220/66 kV Substation. Under a double contingency (N-2) situation, where two 66 kV transmission lines are out of service, the VPU electric system reliability will most likely not be compromised with the support of Vernon's local generation. 2.6. Wildfire Risk Assessment In 2018, Vernon Fire Department conducted a risk assessment of wildfires caused by VPU's overhead electrical lines and equipment, in compliance with Senate Bill 1028 (Hill, 2016). VPU provides electric service to the City of Vernon within the greater Los Angeles basin. Specifically, VPU's service area is not within or near any wildland-urban interface VERNON WILDFIRE MITIGATION PLAN 2020 Page 3 zones and more than ten miles from the nearest wildland-urban interface area. The assessment includes information from the US Forest Service's Fire Modeling Institute, and the CAL FIRE Office of the State Fire Marshal. Also considered were Vernon's historical fire data, geographical location, and local conditions. Based on this information, the determination was made that VPU's electric equipment and operations do not pose a risk of igniting a fire that could cause any significant wildfire condition. 3. Objectives The primary objectives of this Wildfire Mitigation Plan are to: 1. Describe VPU's existing programs, practices, and measures that effectively reduce the probability that VPU's electric supply system could be the origin or contributing source for the ignition of a wildfire. To support this goal, VPU regularly evaluates the prudent and cost-effective improvements to its physical assets, operations, and training that can help reduce the risk of equipment -related fires. 2. The secondary objective of this Wildfire Mitigation Plan is to improve the resiliency of the electric grid. As part of the development of this plan, VPU assesses new industry practices and technologies that will reduce the likelihood of an interruption (frequency) in service and improve the restoration (duration) of service. 3. Create a WMP that is consistent with state law and objectives. 4. Roles and Responsibilities 4.1. Wildfire Prevention VPU staff that have responsibility for wildfire prevention are General Manager: Assumes overall responsibility for VPU's planning and mitigation activities, including maintaining compliance with state and federal safety and operating requirements. Assistant General Manager: Responsible for emergency preparedness, emergency response, and coordinating recovery after a fire. Utilities Operations Manager: Responsible for the reliable operation of VPU's electric distribution system and safety protocols, including the evaluation and installation of new protective equipment to reduce fire risk. Maintain compliance with federal, state and VERNON WILDFIRE MITIGATION PLAN 2020 Page 4 local fire management personnel to ensure that appropriate preventive measures are in place. Electric Operations Supervisor: Is primarily responsible for ensuring inspections of electric lines, poles, and equipment, in addition to the performance of operations and maintenance (O&M). While other individuals, such as linemen, have the responsibility to inspect and report any faulty operations of equipment, the primary responsibility for preventing electrical - ignited fires and coordinating recovery is the Utilities Operations Manager and Assistant General Manager. 4.2. Wildfire Response and Recovery VPU is a member of the California Utility Emergency Association, which plays a key role in ensuring communications between utilities and with California Office of Emergency Services (CAL-OES) during emergencies. VPU also participates in the American Public Power Association (APPA) Mutual Assistance Agreement, which is a mutual assistance agreement covering municipal utilities across the United States. 4.3. Standardized Emergency Management System As a local governmental agency,' VPU has planning, communication, and coordination obligations pursuant to the California Office of Emergency Services' Standardized Emergency Management System (SEMS) Regulations,' adopted in accordance with Government Code section 8607. The SEMS Regulations specify roles, responsibilities, and structures of communications at five different levels: field response, local government, operational area, regional, and state.' Pursuant to this structure, VPU annually coordinates and communicates with the relevant safety agencies as well as other relevant ' A defined in Cal. Gov. Code § 86802- 19 CCR § 2407, a Cal. Gov. Code § 2403(b): (1) "Field response level" commands emergency response personnel and resources to carry out tactical decisions and activities in direct response to an incident or threat. (2)'Local government level" manages and coordinates the overall emergency response and recovery activities within their jurisdiction. (a) "Operational area level" manages and/or coordinates information, resources, and priorities among local governments within the operational area and serves as the coordination and communication link between the local government level and the regional level. (4)'Regional level" manages and coordinates information and resources among operational areas within the mutual aid region designated pursuant to Government Code §8600 and between the operational areas and the state level. This level along with the state level coordinates overall state agency support for emergency response activities. (5)'State level" manages state resources in response to the emergency needs of the other levels, manages and coordinates mutual aid among the mutual aid regions and between the regional level and state level, and serves as the mod-abo,a-dm,n „^ ,it lo.-.-.ew.. t"e'e"e ra'C sa ster ,n,,seryrtem VERNON WILDFIRE MITIGATION PLAN 2020 Page 5 local and state agencies. Pursuant to the SEMS structure, VPU participates in annual training exercises with the Vernon Disaster Council. The Council meets quarterly to discuss emergency management protocols, FEMA and SEMS procedures, and lessons learned from disasters around the world. On an annual basis, the City's Emergency Operating Center is exercised by the Disaster Council as part of an Emergency Drill. 5. Wildfire Risks and Drivers Pursuant to Public Utilities Code section 8387(b)(2), VPU has determined that it is not necessary to describe Wildfire Risks and Drivers in this Wildfire Mitigation Plan because of the unique characteristics of the service territory and operations of VPU, including lack of wildfire fuel sources, and distance from any designated elevated fire -threat areas. 5.1. Design, Construction, Operation, and Maintenance Due to the minimal risk of VPU's electrical supply facilities igniting a wildfire, VPU is not adopting wildfire specific protocols for Wildfire Risks and Drivers Associated with Design, Construction, Operation, and Maintenance. 5.2. Topographic and Climatological Risk Factors Due to the minimal risk of VPU's electrical supply facilities igniting a wildfire, VPU is not adopting wildfire specific protocols for Wildfire Risks and Drivers Associated with Topographic and Climatological Risk Factors. 6. Enterprisewide Safety Risks Pursuant to Public Utilities Code section 8387(b)(2), VPU has determined that it is not necessary to describe Enterprisewide Safety Risks in this Wildfire Mitigation Plan because of the unique characteristics of the service territory and operations of VPU, including lack of wildfire fuel sources, and distance from any designated elevated fire -threat areas. VERNON WILDFIRE MITIGATION PLAN 2020 Page 6 7. Wildfire Preventative Strategies Pursuant to Public Utilities Code section 8387(b)(2), VPU has determined that it is not necessary to describe Wildfire Preventative Strategies in this Wildfire Mitigation Plan because of the unique characteristics of the service territory and operations of VPU, including lack of wildfire fuel sources, and distance from any designated elevated fire - threat areas. High Fire -Threat District In coordination with the California Municipal Utilities Association, VPU participated in the development of the CPUC's Fire -Threat Map,° which defines a statewide High Fire -Threat District (HFTD). In the map development process, VPU reviewed the proposed boundaries of the High Fire -Threat District and confirmed that, based on local conditions and historical fire data, all of VPU's service territory was properly excluded. Design and Construction Standards VPU's electric facilities are designed and constructed to meet or exceed the relevant federal, state, or industry standard. VPU treats CPUC General Orders (GO) 95 and 128 as a key industry standard for design and construction standards for overhead and underground electrical facilities. VPU meets or exceeds all standards in GO 95 and GO 128. Additionally, VPU monitors and follows, as appropriate, the National Electric Safety Code. 8. Vegetation Management Due to the industrial nature of the City of Vernon, there is very little risk of vegetation igniting a wildfire, or impeding Vernon Public Utilities' services. VPU's service territory neither contains nor is adjacent to any wildlands or elevate fire -threat areas and thus, there is no risk of igniting wildfires. Adapted by CPUC Dec is v 17-1-2-924. VERNON WILDFIRE MITIGATION PLAN 2020 Page 7 8.1. City of Vernon Urban Forest is comprised of approximately 1100 trees, which are maintained and are pruned annually by a contracted Urban Forest Management Service company. 8.2. Substations require bare ground for the safe operation of high voltage equipment. Electric Operators monitor substations, switchyards, and other electric facilities on a daily basis and remove invasive weeds and other vegetation as necessary. This may be accomplished by pulling the vegetation, pruning, or spraying with an herbicide such as glyphosate. 8.3. VPU meets or exceeds the minimum industry standard vegetation management practices. For distribution level facilities, VPU meets: (1) Public Resources Code section 4292; (2) Public Resources Code section 4293; (3) GO 95 Rule 35; and (4) the GO 95 Appendix E Guidelines to Rule 35. These standards require significantly increased clearances in the High Fire -Threat District. The recommended time -of - trim guidelines do not establish a mandatory standard, but instead, provide useful guidance to utilities. GO 95, .- Case Type of Clearance Trolley Supply Supply Supply Contact, Conductors Conductors Conductors Feeder and and Supply and Supply and Supply Span Wires, Cables, 750 - Cables, 22.5 Cables, 300 - 0-5kv 22,500 Volts - 300 kV 550 kV (mm) 13 Radial clearance of 18 inches 18 inches X Pin % Pin bare line Spacing Spacing conductors from tree branches or foliage 14 Radial clearance of 18inches 48inches 48inches 120inches bare line conductors from vegetation in the Fire -Threat District VERNON WILDFIRE MITIGATION PLAN 2020 Page 8 Appendix Guidelines to Rule 35 The radial clearances shown below are recommended minimum clearancesthat should be established, at time of trimming, between the vegetation and the energized conductors and associated live parts where practicable. Reasonable vegetation management practices may make it advantageous for the purposes of public safety or service reliability to obtain greater clearances than those listed below to ensure compliance until the next scheduled maintenance. Each utility may determine and apply additional appropriate clearances beyond clearances listed below, which take into consideration various factors, including: line operating voltage, length of span, line sag, planned maintenance cycles, location of vegetation within the span, species type, experience with particular species, vegetation growth rate and characteristics, vegetation management standards and best practices, local climate, elevation, fire risk, and vegetation trimming requirements that are applicable to State Responsibility Area lands pursuant to Public Resource Code Sections 4102 and 4293. Voltage of Lines Case 13 Case 14 Radial clearances for any conductor of a line 4 feet 12 feet operating at 2,400 or more volts, but less than 72,000 volts Radial clearances for any conductor of a line 6 feet 20 feet operating at 72,000 or more volts, but less than 110,000 volts Radial clearances for any conductor of a line 10 feet 30 feet operating at 110,000 or more volts, but less than 300,000 volts Radial clearances for any conductor of a line 15 feet 30 feet operating at 300,000 or more volts 9. Inspections VPU meets or exceeds the minimum inspection requirements provided in CPUC GO 165 and CPUC GO 95, Rule 18. Pursuant to these rules, utilities inspect electric facilities in the High Fire -Threat District more frequently than the other areas of its service territory. As described above, VPU currently does not have any overhead powerlines located within, or near the High Fire Threat District within the CPUC's Fire -Threat Map but still maintains compliance with the inspection requirements as a best business practice. VPU performs intrusive pole inspections and has a pole replacement priority and schedule program to remove potential pole failure hazards, even though there is no significant native vegetation below VPU's overhead distribution lines. VPU staff uses their knowledge of the specific environmental and geographical conditions of VPU's service territory to determine if any particular areas require more frequent inspections. VERNON WILDFIRE MITIGATION PLAN 2020 Page 9 If VPU staff discovers a facility in need of repair that is owned by an entity other than VPU, VPU will issue a notice of repair to the facility owner and work to ensure that necessary repairs are completed promptly. 10. De-energization Protocols 10.1. Reclosing Policy Due to the low wildfire threat in VPU's service territory, VPU does not disable re -closers due to anticipated wildfires. VPU does not have a formal procedure identified for disabling re -closers. VPU will continue to assess the wildfire threat, and will develop a procedure as needed. 10.2. De-energization Electrical outages can adversely affect electrical system equipment, customer production and equipment, devices vital to public health and safety such as lighting, traffic signals, wells and chlorinators and can cause disruption to critical communication networks. Due to Vernon's low wildfire risk profile, VPU is not adopting wildfire specific protocols for de -energizing any portions of its electric distribution system. VPU will re-evaluate the need to pre-emptively shut off power due to fire -threat conditions in future updates to this Wildfire Mitigation Plan. 11. Customer Notification Procedure While VPU has a low risk of igniting a wildfire, VPU and its customers may be subject to a, wildfire threat to a major shared transmission lines) that impacts the statewide grid or parts of it- creating a resource shortage for the utilities that rely on the resources the line(s) provides. VPU proactively communicates to customers and key stakeholders through multiple channels about preparing for potential curtailments, and the power restoration process. VPU recognizes that many entities and individuals are particularly vulnerable during extended power outages and makes every effort to provide up-to-date information to these populations prior to, during, and after an event. VERNON WILDFIRE MITIGATION PLAN 2020 Page 10 VPU's Customer Service Center, Key Accounts staff, social media and CityofVernon.org will provide ongoing and available resources for communication and education for the overall customer base. Key stakeholders, federal, state, and local elected officials, City and County executive staff and first responders are also contacted via a variety of channels and personnel. VPU has specific personnel assigned to elected officials and agencies, and to critical customers including water and telecommunications utilities, potentially affected by an outage to a major shared transmission line. 12. Restoration of Service Due to Vernon's low wildfire risk profile, VPU is not adopting wildfire specific protocols for restoration of service after de -energizing its electric distribution system. General Steps to Restoration of Service are: Patrol. VPU crews patrol the line to look for vegetation in lines and any obvious damage that may prevent safe energization. Repair. During patrol, crews look for potential damage to the lines and poles. Where equipment damage is found, additional crews are dispatched with new materials to repair or replace damaged equipment. Test. Once the lines and poles are safe to operate, crews test the infrastructure by closing the fuse or breaker to re -energize the line segment. Restore. Power is restored, and the outage communication system provides notification of power restoration to customers. 13. Evaluation Metrics This section provides the metrics used to measure the performance of the Plan and outlined programs. 13.1. Metrics and Assumptions for Measuring Plan Performance VPU will track two metrics to measure the performance of this Wildfire Mitigation Plan: (1) number of fire ignitions; and (2) wires down within the service territory. VERNON WILDFIRE MITIGATION PLAN 2020 Page 11 Metric 1: Fire Ignitions For purposes of this metric, a Fire Ignition is defined as follows: VPU facility was associated with the fire; • The fire was self -propagating and of a material other than electrical and/or communication facilities; The resulting fire traveled greater than one linear meter from the ignition point; and • VPU has knowledge that the fire occurred. In future Wildfire Mitigation Plans, VPU will provide the number of Fire Ignitions that occurred that were less than 5 acres in size. Any fires greater than 5 acres will be individually described. Metric 2: Wires Down The second metric is the number of distribution wires downed within VPU's service territory. (VPU does not own or operate any transmission lines.) For purposes of this metric, a Wires Down event includes any instance where an electric primary distribution conductor falls to the ground, or on to a foreign object. As VPU does not own or operate any transmission lines, or own/operate distribution lines in the High Fire -Threat District, reporting of Wires Down is limited to local distribution outside of the High Fire -Threat District. VPU will not normalize this metric by excluding unusual events, such as severe storms. Instead, VPU will supplement this metric with a qualitative description of any such unusual events. 14. Impact of Metrics on Plan Due to VPU's extremely -low risk wildfire circumstances, VPU anticipates that there will be relatively limited data gathered through these metrics. However, as the data collection history increases, VPU will be able to identify if any areas of its operations and service territory are disproportionately impacted. VPU will then evaluate potential improvements in future updates to this Plan. VERNON WILDFIRE MITIGATION PLAN 2020 Page 12 15. Monitoring and Auditing the Plan This Wildfire Mitigation Plan will be reviewed annually, and will include an assessment of the Plan programs and performance. The Plan, and any updates, will be presented to the Vernon City Council on an annual basis. Additionally, a qualified independent evaluator will present a report on this plan to the Vernon City Council. 15.1. Identifying and Correcting Deficiencies in the Plan At any point in time, when deficiencies are identified, the Utilities Operations Manager or his/her delegates are responsible for correcting the deficiencies. 15.2. Monitoring the Effectiveness of Inspections VPU's Utilities Operations Manager will be responsible for monitoring and auditing the targets specified in the Plan to confirm that the objectives of the Plan are met. 16. Independent Auditor Public Utilities Code section 8387(c) requires VPU to contract with a qualified independent evaluator with experience in assessing the safe operation of electrical infrastructure to review and assess the comprehensiveness of this Wildfire Mitigation Plan. The independent evaluator must issue a report that is posted to the City of Vernon's website. This report must also be presented to the Vernon City Council at a public meeting. VPU participated in a public request for proposals, to identify the best qualified independent evaluator to assess the comprehensiveness of VPU's Wildfire Mitigation Plan. VPU contracted with a qualified independent evaluator with experience in assessing the safe operation of electrical infrastructure. The independent evaluator's report will be posted to the City of Vernon's website and presented to Vernon's City Council at a noticed public meeting. VERNON WILOnRE MITIGATION PLAN 2020 Page 13 17. Acronym Glossary AB (Assembly Bill) CAISO (California Independent System Operation) CAL FIRE (California Department of Forestry and Fire Protection) CPUC (California Public Utilities Commission) CUEA (California Utilities Emergency Association) ERM (Enterprise Risk Management) FRAP (Fire Resource and Assessment Program) GHG (Greenhouse gas) GIS (Geographic Information System) GO (General Order) HFTD (High Fire Threat Districts) KV (Kilovolt) KWH (Kilowatt Hours) MW (Mega Watts) 0&M (Operations & Maintenance) EOC (Emergency Operations Centers) DES (Office of Emergency Services) PUC (Public Utilities Code) SB (Senate Bill) SEMS (Standardized Emergency Management System) SME (Subject Matter Expert) T&D (Transmission and Distribution) WMP (Wildfire Mitigation Plan) VERNON WILDFIRE MITIGATION PLAN 2020 Page 14 STAFF REPORT City Council Agenda Rem Report Agenda Rem No. COV-16-2020 Submitted by. Angela Kimmey Submitting Department: Public Utilities Meeting Date: January21, 2020 SUBJECT Vernon Public Utilities Wildfire Mitigation Plan Recommendation: A. Find that approval of this action does not constitute a "project" pursuant to section 15378(bx2) of the Guidelines to the Califon -ha Environmental Quality Act ("CEQA'), because such action constitutes an administrative activity, and even if the adoption of the proposed item did constitute a project, it would be exempt in accordance with CEQA Guidelines section 15061(b)(3), the general rule that CEQA only applies to projects that may have an effect on the environment and B. Adopt a resolution adopting the Vernon Public Utilities 2020 Wildfire Mitigation Plan. Background: On September 24, 2016, Senate Bill 1028: Wildfire Mitigation Plans ("WMP") (Hill, Chapter 598, Statutes of 2016) was signed into law. As it relates to Vernon Public Utilities ("VPU"), SB 1028 required the governing board of a local publicly owned electric utilityto determine whether any portion of the geographical area where the utilitys overhead electrical lines and equipment are located has a significant risk of catastrophic wildfire resulting from those electrical lines and equipment and, if so, would require the local publicly owned electric utility, at an interval determined by the board, to present to the board for its approval those wildfire mitigation measures the utility intends to undertake to minimize the risk of its overhead electrical lines and equipment causing a catastrophic wildfire. In compliance with SB 1028, the Public Utilities Department requested the Vernon Fire Department to perform an assessment of the electric service teritorys risk of wildfire caused by electric operations and equipment. Vernon Fire Department's 2018 assessment considered Vernon's historical fire data, geographical location, and local conditions. The assessment also includes information from the US Forest Service's Fire Modeling Institute, and the CAL FIRE Office of the State Fire Marshal. Based on this information, the determination was made that VPU's electric equipment and operations do rat pose a risk of igniting a fire that could cause any significant or catastrophic wildfire condition. VPU's 2020 Wildfire Mitigation Plan reflects the 2018 Vernon Wildfire Risk Assessment findings: • Wildfire ignition risks are low due to the sparsity of vegetation and fuel sources in Vemori s industrial environment. • Vernon is located more than 10 miles from the nearest Califomia Public Utilities Commission ("CPUC") High Fire -Threat District Elevated risk area. • VPU does rat own or operate transmission, distribution, or generation facilities in CPUC High Fire -Threat District. " VPU does rot own or operate transmission, distribution, or generation facilities in California Departrnent of Forestry and Fire Protection's ("CAL FIRE') Fire and Resource Assessment Program ("FRAP") Fire Threat Map's designated High or Extreme Wildfire Hazard areas. Vernon's low wildfire -risk, notwithstanding, VPU is required to develop a Wildfire Mitigation Plan to comply with Senate Bill 901 (Dodd, Chapter 626, Statutes of 2018), amending California Public Utilities Code Section 8387, which requires all publicly owned utilities ("POU") to prepare a wildfire mitigation plan before January 1, 2020, and annually thereafter. SB 901 requires WMPs to consider as necessary, certain specified elements. The "consider as necessary' clause indicates that if certain elements do not apply to a community, such as communities with significant underground facilities or a)&emely limited tree canopy, than certain elements can be eliminated or minimized, with an explanation. POUs must also have their plan reviewed by a qualified independent evaluator to assess the comprehensiveness of the plan. The independent evaluator must then issue a report that the POU must make available on the POU's website, and the POU must present the report at a public meeting of the POU's governing board. In 2019, Assembly Bill 1054 (Holden, Chapter 79, Statutes of 2019) and Assembly Bill 111 (Committee on Budget, Chapter 81, Statutes of 2019) made additional major reforms retabrhg to wildfires. As part of these reforms, AB 111 created a new state agency called the California Wildfire Safety Advisory Board ("Board'). AB 1054 requires that all POUs must submit their WMPs to the Board by July 1 of each year, staring in 2020. The Board will then review the POU plans and will provide comments and advisory opinions on the content and sufficiency of the plans. Pursuant to Public Utilities Code, Section 8387, VPU has prepared the required Wildfire Mitigation Plan ("WMP"). VPU's WMP meets all the required criteria in Section 8387, including identification of elements that do rat apply to Vernon due to the sparsity of wildfire fuel sources and distance from High Fire -Treat District Elevated risk areas, and an independent evaluators determination that VPU's WMP addressed all required elements. - Staff recommends the adoption of the proposed resolution that will approve and adopt the Vernon Public Utilities Wildfire Mitigation Plan. VPU will submit its adopted WMP to the California Wildfire Safety Advisory Board prior to Juty 1, 2020. Fiscal Impact: At this time, due to Vernon's low wildfire -threat profile, the additional costs of meeting the state requirements are limited to staff time to prepare and annually review the Wildfire Mitigation Plan, and the e)perhse of the independent evaluator. There is no fiscal impact associated with the adoption of the attached resolution. Attachments: 1. Resolution Adopting VPU Wildfire Mitigation Plan 2020 2. Vernon Fire Department 2018 Wildfire Risk Assessment 3. Independent Evaluation of VPU Wildfire Mitigation Plan