Resolution No. 2021-012RESOLUTION NO. 2021-12
A RESOLUTION OF THE CITY COUNCIL OF THE CITY OF VERNON
APPROVING THE VERNON PUBLIC UTILITIES 2021 WILDFIRE
MITIGATION PLAN AND REPEALING RESOLUTION NO. 2020-02
SECTION 1. Recitals.
A. Pursuant to Public Utilities Code Section 8387 (Senate Bill 901), on January 21,
2020, the City Council adopted Resolution No. 2020 -02 adopting the Vernon Public
Utilities 2020 Wildfire Mitigation Plan.
B. The plan must be updated annually, with a comprehens ive update conducted
every three years.
C. As part of the 2021 annual review, Vernon Public Utilities (VPU) reviewed the 2020
plan for changes to the generation and distribution facilities, key wildfire risks, and risk
drivers.
D. Section 8.1 was amended to increase the number of trees in the City from 1 ,100
to 1,200 and other minor formatting and non-substantive revisions were made.
NOW, THEREFORE, BE IT RESOLVED BY THE CITY COUNCIL OF THE CITY
OF VERNON AS FOLLOWS:
SECTION 2. The City Council of the City of Vernon hereby finds and determines
that the above recitals are true and correct.
SECTION 3. The City Council of the City of Vernon hereby approves the Vernon
Public Utilities 2021 Wildfire Mitigation Plan, Attachment 1 to May 18, 2021, City Council
Agenda Report entitled 2021 Wildfire Mitigation Plan.
SECTION 4. Subsequent annual updates and triennial comprehensive revisions
shall be approved by minute order of the City Council.
SECTION 5. All resolutions or parts of resolutions, specifically Resolution No.
2020-02, not consistent with or in conflict with this resolution are hereby repealed.
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Resolution No. 2021-12
Page 2 of 2
SECTION 6. The City Clerk shall certify the passage and adoption of this
resolution and enter it into the book of original resolutions.
APPROVED AND ADOPTED this 18th day of May, 2021.
MELISSA YBARRA, Mayor
ATTEST:
LISA POPE, City Clerk
seal)
APPROVED AS TO FORM:
ARNOLD M. ALVAREZ-GLASMAN,
Interim City Attorney
I CERTIFY THAT THE FOREGOING RESOLUTION NO. 2021-12 was passed and
adopted by the City Council of the City of Vernon at the regular meeting on May 18, 2021
by the following vote:
AYES: 5 Council Members: Gonzales, Lopez, Menke, Davis, Ybarra
NOES: 0
ABSENT: 0
ABSTAIN: 0
LISA POPE, City Clerk
seal)
DocuSign Envelope ID: CBAA038F-BBE4-494F-8A8C-426D697B5B29
City Council Agenda Item Report
Agenda Item No. COV-606-2021
Submitted by: Adriana Ramos
Submitting Department: Public Utilities
Meeting Date: May 18, 2021
SUBJECT
Vernon Public Utilities 2021 Wildfire Mitigation Plan
Recommendation:
A. Find that the proposed action is exempt from the California Environmental Quality Act (“CEQA”), in
accordance with CEQA Guidelines § 15061(b)(3), the general rule that CEQA only applies to projects
that may have a significant effect on the environment. This action receives and files an update to the
City’s plan for the implementation of preventative strategies and mitigation measures to minimize the risk
of wildfires caused by electrical lines and equipment; this action does not authorize any construction
activity or any disturbance of an environmental resource, and has no potential for causing a significant
effect on the environment; and
B. Adopt Resolution No. 2021-12 approving Vernon Public Utilities 2021 Wildfire Mitigation Plan and
repealing Resolution No. 2020-02.
Background:
In 2018, the California legislature adopted Senate Bill 901 (SB 901). Under SB 901, California has taken
a comprehensive approach to mitigating wildfires and creating greater resilience against catastrophic
wildfires. SB 901 amended Public Utilities Code (PUC) Section 8387 to require every publicly owned
electric utility to prepare and present a Wildfire Mitigation Plan (WMP) to its governing body by January
1, 2020, and update it annually thereafter. 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 relating 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 California Wildfire Safety Advisory Board by July 1 of each year, starting in 2020. The
Board will then review the POU plans and provide comments and advisory opinions on the content and
sufficiency of the plans. At least once every three years, the submission shall be a comprehensive
revision of the plan.
On January 21, 2020, the City Council adopted the Vernon Public Utilities 2020 Wildfire Mitigation Plan
via Resolution No. 2020-02. In 2018, the Vernon Public Utilities (VPU) Department requested the
Vernon Fire Department perform an assessment of the electric service territories risk of wildfire caused
by electric operations and equipment. Vernon Fire Department's 2018 assessment reviewed Vernon's
historical fire data, geographical location, and local conditions. The assessment also included
information from the U.S. Forest Service's Fire Modeling Institute and from the Office of the State Fire
Marshal of CAL FIRE. 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 or
catastrophic wildfire condition. This assessment of low-risk was confirmed by an independent evaluator
in January 2020, and is incorporated in the WMP in Appendix A.
Notwithstanding Vernon's low wildfire-risk, VPU is required to develop a WMP in accordance to Public
Utilities Code Section 8387, which 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 extremely limited tree canopy,
then certain elements can be eliminated or minimized with an explanation. VPU's WMP meets all the
required criteria pursuant to Section 8387, including identification of elements that do not apply to Vernon
due to the sparsity of wildfire fuel sources and distance from High Fire -Threat District Elevated risk
areas, and an independent evaluators determination that VPU's WMP addressed all required elements.
As part of the update, VPU reviewed the 2020 plan for changes to the Generation and Distribution
facilities, Wildfire Risks and Drivers. There were no reportable incidences for the 2020 calendar year, as
specified in the WMP. Minor updates to the 2020 plan include increasing the approximate number of
trees in Section 8.1. from 1100 trees to 1200 trees in the City. Additionally, there were minor formatting
and non-substantive revisions. VPU’s WMP will be due for a comprehensive revision in July 2023.
Fiscal Impact:
At this time, due to Vernon's low wildfire threat profile, the additional costs of meeting the state
requirements are limited to the staff time required to prepare and annually review the Wildfire Mitigation
Plan.
Attachments:
1. 2021 Wildfire Mitigation Plan
2. Resolution No. 2021-12
CITY OF VERNON PUBLIC UTILITIES
4305 S SANTA FE AVE.
VERNON, CALIFORNIA 90058
Effective Date: 5/18/2021
Wildfire
Mitigation Plan
2021
Contents
1.Executive Summary ........................................................................................................... 1
2.Introduction ....................................................................................................................... 1
2.1. Policy Statement ......................................................................................................... 2
2.2. Organization of the Wildfire Mitigation Plan ............................................................. 2
........................................................................................................................................... 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
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 Evaluator ................................................................................................... 13
17. Acronym Glossary ........................................................................................................... 14
APPENDIX
A. Independent Evaluation of Vernon Plan......................................................... 15
VERNON WILDFIRE MITIGATION PLAN 2021 Page 1
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 5.2 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 (SB) 901 authored by Senator Dodd, was enacted
in 2018. SB 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 f or 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 2021 Page 2
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 i n 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
The City of Vernon is an industrial city
of 5.2 square miles located several
miles to the southeast of Downtown
Los Angeles in Southern California. The
City’s business-friendly environment,
low-cost utilities, and proximity to
ports, trucking and rail transport make
Vernon an ideal location for industrial
uses.
The City of Vernon is located in a
region of Los Angeles County with low
wildfire risk. No part of VPU’s service
territory is located in or near the High
Fire-Threat District, designed in the
California Public Utilities Commission’s
(CPUC) Fire Threat Map. Further, all of
VPU’s service territory is excluded from
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 2021 Page 3
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 119 miles of
distribution lines, and 27 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 A ngeles
basin. Specifically, VPU's service area is not within or near any wildland-urban interface
VERNON WILDFIRE MITIGATION PLAN 2021 Page 4
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 2021 Page 5
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,1 VPU has planning, communication, and coordination
obligations pursuant to the California Office of Emergency Services’ Standardized
Emergency Management System (SEMS) Regulations,2 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.3 Pursuant to this structure, VPU annually
coordinates and communicates with the relevant safety agencies as well as other relevant
1 As defined in Cal. Gov. Code § 8680.2.
2 19 CCR § 2407.
3 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.
(3) “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
coordination and communication link with the federal disaster response system.
VERNON WILDFIRE MITIGATION PLAN 2021 Page 6
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 2021 Page 7
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,4 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 elevated fire-threat areas and thus,
there is no risk of igniting wildfires.
4 Adopted by CPUC Decision 17-12-024.
VERNON WILDFIRE MITIGATION PLAN 2021 Page 8
8.1. City of Vernon Urban Forest is comprised of approximately 1200 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, Rule 35, Table 1
Case Type of Clearance Trolley
Contact,
Feeder and
Span Wires,
0-5kv
Supply
Conductors
and Supply
Cables, 750 -
22,500 Volts
Supply
Conductors
and Supply
Cables, 22.5
- 300 kV
Supply
Conductors
and Supply
Cables, 300 -
550 kV (mm)
13 Radial clearance of
bare line
conductors from
tree branches or
foliage
18 inches 18 inches ¼ Pin
Spacing
½ Pin
Spacing
14 Radial clearance of
bare line
conductors from
vegetation in the
Fire-Threat District
18 inches 48 inches 48 inches 120 inches
VERNON WILDFIRE MITIGATION PLAN 2021 Page 9
Appendix E
Guidelines to Rule 35
The radial clearances shown below are recommended minimum clearances that 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
operating at 2,400 or more volts, but less than
72,000 volts
4 feet
12 feet
Radial clearances for any conductor of a line
operating at 72,000 or more volts, but less than
110,000 volts
6 feet
20 feet
Radial clearances for any conductor of a line
operating at 110,000 or more volts, but less
than 300,000 volts
10 feet
30 feet
Radial clearances for any conductor of a line
operating at 300,000 or more volts
15 feet
30 feet
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 2021 Page 10
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 line(s) 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 2021 Page 11
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 2021 Page 12
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 2021 Page 13
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.
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 Evaluator
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 Dudek & Associates, a qualified independent evaluator with
experience in assessing the safe operation of electrical infrastructure. Dudek’s
Independent Evaluation is attached in Appendix A of this Plan.
The independent evaluator’s report is posted to the City of Vernon’s website and has
been presented to Vernon’s City Council at a noticed public meeting.
VERNON WILDFIRE MITIGATION PLAN 2021 Page 14
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)
O&M (Operations & Maintenance)
EOC (Emergency Operations Centers)
OES (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)
12255.02
1 January 2020
January 9, 2020 12255.02
Angela Kimmey, MPA
Compliance Administrator & Government Affairs
Vernon Public Utilities
4305 S. Santa Fe Ave.
Vernon, CA 90058
Subject: Vernon Public Utilities Wildfire Mitigation Plan – Comprehensive and Appropriate for Low Wildfire Risk
Service Area
Dear Ms. Kimmey:
Dudek conducted an evaluation of the Vernon Public Utilities (VPU) Wildfire Mitigation Plan (WMP), as required
under California Public Utilities Code (CPUC) Section 8387(b). CPUC Section 8387(b), as modified by Senate Bill (SB)
901, and the Administrative Law Judge’s Ruling issued on January 17, 2019 in CPUC Docket No. R.18-10-007 (ALJ
Ruling), applies to publicly-owned electric utilities and requires preparation of a WMP, which shall be submitted to the
California Wildfire Safety Advisory Board by July 1, 2020 (Assembly Bill 1054, July 2019). CPUC Section 8387(c) requires
that an independent evaluator review and assess the comprehensiveness of a publicly-owned utility’s WMP and issue a
summary report.
Dudek, as the WMP independent evaluator, conducted an initial review of VPU’s Draft WMP on December 19, 2019
and provided a summary letter for suggested Draft WMP modifications. The focus of the evaluation was to
determine whether the Draft WMP addressed all required elements under CPUC Section 8387(b) (2) (included in
Attachment A) that were applicable to VPU.
Subsequently, VPU elected to modify its Draft WMP and incorporated Dudek’s recommended modifications to the
Plan. The revised WMP was provided to Dudek on December 30, 2019. Dudek reviewed the revised WMP and
determined that VPU’s WMP is deemed comprehensive and appropriate for the very low risk fire environment within
their service territory. Additionally, VPU’s WMP approach appropriately addresses all applicable elements required
under CPUC Section 8387(b) (2).
Should you have any questions or require additional information, please do not hesitate to contact me at (619)
992-9161.
Sincerely,
____________________________________
Michael Huff
Principal/Senior Fire Protection Planner
Att.: A. Required WMP Elements under PUC Section 8387(b)
Attachment A
Required WMP Elements under PUC Section 8387(b)
12255.02
A-1 January 2020
Required WMP Elements under PUC Section 8387(b)
PUC
8387(b)(2)
Section
Description
A An accounting of the responsibilities of the persons responsible for executing the plan.
B The objectives of the wildfire mitigation plan.
C Description of the preventative strategies and programs to be adopted by the 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.
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 made that
underlie the use of those metrics.
E A discussion of how the application of previously identified metrics to previous wildfire mitigation
plan performances has informed the wildfire mitigation plan.
F Protocols for disabling reclosers and de-energizing 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
G Appropriate and feasible procedures for notifying a customer who may be impacted by the de-
energizing of electric lines. The procedures shall consider the need to notify, as a priority, critical
first responders, health care facilities, and operators of telecommunications infrastructure.
H Plans for vegetation management.
I Plans for inspections of the local publicly owned electric utility’s or electrical cooperative’s
electrical infrastructure.
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:
J(i) Risks and risk drivers associated with design, construction, operations, and maintenance of the
local publicly owned electric utility or electrical cooperative’s equipment and facilities.
J(ii) Particular risks and risk drivers associated with topographic and climatological risk factors
throughout the different parts of the local publicly owned utility’s or electrical cooperative’s service
territory.
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 currently identified in a
commission fire threat map, and identification of where the commission should expand the high
fire threat district based on new information or changes to the environment.
L A methodology for identifying and presenting enterprise-wide safety risk and wildfire-related risk.
M A statement of how the local publicly owned electric utility will restore service after a wildfire.
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:
N(i) Monitor and audit the wildfire mitigation plan.
N(ii) Identify any deficiencies in the wildfire mitigation plan or its implementation, and correct those
deficiencies.
N(iii) Monitor and audit the effectiveness of electrical line and equipment inspections, including
inspections performed by contractors that are carried out under the plan, and other applicable
statutes, or commission rules.
RESOLUTION NO. 2021-12
A RESOLUTION OF THE CITY COUNCIL OF THE CITY OF VERNON
APPROVING THE VERNON PUBLIC UTILITIES 2021 WILDFIRE
MITIGATION PLAN AND REPEALING RESOLUTION NO. 2020-02
SECTION 1. Recitals.
A.Pursuant to Public Utilities Code Section 8387 (Senate Bill 901), on January 21,
2020, the City Council adopted Resolution No. 2020-02 adopting the Vernon Public
Utilities 2020 Wildfire Mitigation Plan.
B.The plan must be updated annually, with a comprehensive update conducted
every three years.
C.As part of the 2021 annual review, Vernon Public Utilities (VPU) reviewed the 2020
plan for changes to the generation and distribution facilities, key wildfire risks, and risk
drivers.
D.Section 8.1 was amended to increase the number of trees in the City from 1,100
to 1,200 and other minor formatting and non-substantive revisions were made.
NOW, THEREFORE, BE IT RESOLVED BY THE CITY COUNCIL OF THE CITY
OF VERNON AS FOLLOWS:
SECTION 2. The City Council of the City of Vernon hereby finds and determines
that the above recitals are true and correct.
SECTION 3. The City Council of the City of Vernon hereby approves the Vernon
Public Utilities 2021 Wildfire Mitigation Plan, Attachment 1 to May 18, 2021, City Council
Agenda Report entitled 2021 Wildfire Mitigation Plan.
SECTION 4. Subsequent annual updates and triennial comprehensive revisions
shall be approved by minute order of the City Council.
SECTION 5. All resolutions or parts of resolutions, specifically Resolution No.
2020-02, not consistent with or in conflict with this resolution are hereby repealed.
/ / /
/ / /
/ / /
Resolution No. 2021-12
Page 2 of 2
_______________________
SECTION 6.The City Clerk shall certify the passage and adoption of this
resolution and enter it into the book of original resolutions.
APPROVED AND ADOPTED this 18th day of May, 2021.
_____________________________
MELISSA YBARRA, Mayor
ATTEST:
LISA POPE, City Clerk
(seal)
APPROVED AS TO FORM:
_________________________________
ARNOLD M. ALVAREZ-GLASMAN,
Interim City Attorney