City Council

LODI CITY COUNCIL "SHIRTSLEEVE" SESSION Date: October 15, 2019 Carnegie Forum 305 West Pine Street, Lodi Time: 7:00 a.m. TM *and via conference call: For information regarding this Agenda please contact: 1311 Midvale Road Jennifer M. Ferraiolo Lodi, CA 95240 & City Clerk 437 E. Elm Street Telephone: (209) 333-6702 Lodi, CA 95240 Informal Informational Meeting A. Roll Call by City Clerk B. Topic(s) B-1 Informational Overview of Senate Bill 901 and Lodi Electric Utility’s Draft Wildfire Mitigation Plan (EU) C. Comments by Public on Non-Agenda Items D. Adjournment Pursuant to Section 54954.2(a) of the Government Code of the State of California, this agenda was posted at least 72 hours in advance of the scheduled meeting at a public place freely accessible to the public 24 hours a day. ______________________________ Jennifer M. Ferraiolo City Clerk All staff reports or other written documentation relating to each item of business referred to on the agenda are on file in the Office of the City Clerk, located at 221 W. Pine Street, Lodi, and are available for public inspection. If requested, the agenda shall be made available in appropriate alternative formats to persons with a disability, as required by Section 202 of the Americans with Disabilities Act of 1990 (42 U.S.C. Sec. 12132), and the federal rules and regulations adopted in implementation thereof. To make a request for disability-related modification or accommodation contact the City Clerk’s Office as soon as possible and at least 72 hours prior to the meeting date. Language interpreter requests must be received at least 72 hours in advance of the meeting to help ensure availability. Contact Jennifer M. Ferraiolo at (209) 333-6702. Solicitudes de interpretación de idiomas deben ser recibidas por lo menos con 72 horas de anticipación a la reunión para ayudar a asegurar la disponibilidad. Llame a Jennifer M. Ferraiolo (209) 333-6702. J:\CITYCLRK\AGENDA\SHIRTSLV\SHRTSLV.DOC  AGENDA ITEM B-01 CITY OF LODI COUNCIL COMMUNICATION TM AGENDA TITLE: Informational Overview of Senate Bill 901 and Lodi Electric Utility’s Draft Wildfire Mitigation Plan MEETING DATE: October 15, 2019 PREPARED BY: Electric Utility Director RECOMMENDED ACTION: Informational overview of Senate Bill (SB) 901 and Lodi Electric Utility’s (LEU) Draft Wildfire Mitigation Plan. BACKGROUND INFORMATION: In September 2018, the State of California enacted SB 901, requiring California electric utilities to create a Wildfire Mitigation Plan and submit it to the state by January 1, 2020, and annually thereafter. Since the passage of SB 901, staff has worked diligently to understand and comply with the numerous requirements associated with this legislation. LEU has spent months drafting a plan, soliciting input from numerous stakeholders, and has recently provided the latest version for public comment. As required by the legislation, the draft is currently under review by a third party auditor, Navigant Consulting, Inc., as approved by City Council on September 18, 2019. The plan is substantially complete and on account of SB 901’s deadline and the requirements ahead, staff believes the timing is appropriate to provide an overview to Council. However, the draft may see changes from the independent audit process. Upon completion of review by the third party auditor, and any changes LEU makes, a finalized version will be brought to Council for approval by the end of this year. FISCAL IMPACT: Not applicable. FUNDING AVAILABLE: Not applicable. _______________________________ Jeff Berkheimer Electric Utility Director PREPARED BY: Tim Conn, Electrical Engineer APPROVED: __________________________________ Stephen Schwabauer, City Manager  LODI ELECTRIC UTILITY WILDFIRE MITIGATION PLAN VERSION 0.91 DRAFT August 28, 2019  TABLE OF CONTENTS I. Overview ............................................................................................................................................. 1 A. Policy Statement ............................................................................................................................... 1 B. Purpose of the Wildfire Mitigation Plan .......................................................................................... 1 C. Background........................................................................................................................................ 2 D. Organization of the Wildfire Mitigation Plan ................................................................................. 3 II. Objectives of the Wildfire Mitigation Plan ...................................................................................... 4 III. Roles and Responsibilities ................................................................................................................. 5 A. Utility Governance Structure ........................................................................................................... 5 B. Wildfire Prevention ............................................................................................................................ 6 C. Wildfire Response and Recovery .................................................................................................... 6 D. Coordination with Water Utility and Public Safety ....................................................................... 8 E. Coordination with Communication Infrastructure Providers ...................................................... 9 F. Standardized Emergency Management System ......................................................................... 9 IV. Wildfire Risks and Drivers Associated with Design, Construction, Operation, and Maintenance ............................................................................................................................................... 10 A. Particular Risks and Risk Drivers Associated with Topographic and Climatological Risk Factors ....................................................................................................................................................... 11 B. Enterprisewide Safety Risks ............................................................................................................. 11 C. Changes to CPUC Fire Threat Map .............................................................................................. 13 V. Wildfire Preventative Strategies ..................................................................................................... 14 A. High Fire Threat District .................................................................................................................... 14 B. Weather Monitoring ........................................................................................................................ 14 C. Design and Construction Standards ............................................................................................ 14 D. Vegetation Management ............................................................................................................. 14 E. Inspections........................................................................................................................................ 16  F. Reclosing Policy ............................................................................................................................... 18 G. De-energization ............................................................................................................................... 18 VI. Community Outreach and Public Awareness ............................................................................ 20 VII. Restoration of Service ..................................................................................................................... 20 VIII. Evaluating of the Plan ..................................................................................................................... 21 A. Metrics and Assumptions for Measuring Plan Performance ..................................................... 21 Metric 1: Fire Ignitions .......................................................................................................................... 21 Metric 2: Wires Down ........................................................................................................................... 21 B. Impact of Metrics on Plan .............................................................................................................. 21 C. Monitoring and Auditing the Plan ................................................................................................ 21 D. Identifying and Correcting Deficiencies in the Plan .................................................................. 22 E. Monitoring the Effectiveness of Inspections ................................................................................ 22 IX. Independent Auditor ...................................................................................................................... 23 X. Cross References to SB-901 Requirements ................................................................................... 23  I. OVERVIEW A. POLICY STATEMENT Lodi Electric Utility’s (LEU’s) overarching goal is to provide safe, reliable, and economic electric service to its local community. In order to meet this goal, LEU strives to construct, maintain, and operate its electrical lines and equipment in a manner that minimizes the risk of catastrophic wildfire posed by its electrical lines and equipment. LEU is a department within the City of Lodi. As a public entity whose service territory is contained entirely within the City limits, LEU’s interests are entirely aligned with the City’s and the population we serve; we have no fiduciary obligation to any shareholders taking precedence over our customer-residents, nor any other priorities greater than Lodi’s. LEU is singularly focused on serving Lodi, to the greatest extent possible. Lodi’s wildfire prevention and mitigation efforts are thus benefited by Lodi’s organizational structure and focus. B. PURPOSE OF THE WILDFIRE MITIGATION PLAN This Wildfire Mitigation Plan describes the range of activities that LEU is taking to mitigate the threat of power-line ignited wildfires, including its various programs, policies, and procedures. This plan is subject to direct supervision by Lodi’s City Council and is implemented by the Electric Utility Director. This plan complies with the requirements of Public Utilities Code section 8387 for publicly owned electric utilities to prepare a wildfire mitigation plan by January 1, 2020, and annually thereafter. LEU is located in a region of the state with a very low wildfire risk. No part of LEU’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. Lodi Electric’s service territory is predominantly categorized as either “non-fuel” or “moderate” in the California Department of Forestry and Fire Protection’s (CALFIRE) Fire and Resource Assessment Program (FRAP) Fire Threat Map1. Cal Fire also provides the following statement with regard to the Local Responsibility Area for the County of San Joaquin, which LEU’s Service Territory is entirely within, “Update, 6/2008: CAL FIRE has determined that this county has no Very High Fire Hazard Severity Zones in LRA. Therefore [San Joaquin] county will not have a map of recommended VHFHSZ in LRA”2. Based on a review of local conditions and historical fires, Lodi Electric has determined that its electrical lines and equipment do not pose a significant risk of catastrophic wildfire. Despite this low risk, LEU takes appropriate actions to help its region prevent and respond to the increasing risk of wildfires. In its role as a public agency, LEU closely coordinates with other local 1 Cal Fire Map ID: FTHREAT_MAP, Oct. 20, 2005 2 Cal Fire Map ID: FHSZL06_1_MAP, Oct. 02, 2007, http://www.fire.ca.gov/fire_prevention/fhsz_maps_sanjoaquin (05/22/2019) Lodi Electric Utility Wildfire Mitigation Plan Version 1.0 XXXXXX, XX, 2019 1 safety and emergency officials to help protect against fires and respond to emergencies. LEU follows 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 LEU follows to reduce its risk of causing wildfires. C. BACKGROUND LEU has no known history of causing any widespread fire, nor suffering a widespread and prolonged outage due to any fire. While no utility is fully immune to fire, LEU’s history of outages and fire is consistent with operating a utility in an urban area. Per the City of Lodi’s General Plan, “The Planning Area is not characterized by substantial areas of wildlands. The topography of the area is relatively homogenous and steep slopes that could contribute to wildland fires are not common. Data provided by the California Department of Conservation Fire and Resource Assessment Program in 2007 indicate that no portions of the [City’s] Planning Area are classified as having a “High” or “Very High” risk.”3 LEU’s Service Territory is limited to a dense urban footprint (approximately 13.7 square miles of land). With an estimated service-territory population of more than 68,000, there are approximately on-average 5,000 persons per square mile of LEU service-territory, offering tremendous visibility on LEU’s infrastructure. Problems within LEU’s territory are therefore generally discovered very quickly. LEU’s compact territory also allows LEU to reach nearly every utility asset within a 10-minute drive from its headquarters. The high visibility and close proximity generally result in quick discovery and addressing of problems. This is in contrast with utilities having thousands of miles of line in the middle of dry forests, far from urban areas, lacking any real visibility, and with potentially great travel distances required when responding to a problem. Wildfire risk is greatly reduced by LEU’s topography and setting. LEU is relatively flat, lacking mountains, valleys, and other hard to access locations. LEU is bordered on the northern edge by the Mokelumne River. LEU is further benefited by advantageous land use in the surrounding area. In contrast with utilities traversing through large wilderness areas with decades of dry fuel accumulation, LEU is surrounded by miles of actively managed grape vineyards. Grape vineyards, with their open-space, moisture content, and active management, are frequently considered a very good firebreak, "The fire just came up to the edge of the vineyard and stopped."4 Further, much of LEU’s underground circuitry exists on the perimeter of LEU’s service territory, and functions as a buffer between LEU’s overhead infrastructure and the unimproved land abutting LEU’s service territory. 3 City of Lodi, General Plan, 4/2010 § 8.4 4 Mohan, Geoffrey. “Vineyards may have kept the wine country fire from getting worse.” Los Angeles Times, web. https://www.latimes.com/business/la-fi-vineyards-firebreak-20171012-story.html Lodi Electric Utility Wildfire Mitigation Plan Version 1.0 XXXXXX, XX, 2019 2  D. 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; • Community outreach and education; • Metrics for evaluating the performance of the plan and identifying areas for improvement; and • Review and validation of the plan. Lodi Electric Utility Wildfire Mitigation Plan Version 1.0 XXXXXX, XX, 2019 3  II. OBJECTIVES OF THE WILDFIRE MITIGATION PLAN The primary goal of this Wildfire Mitigation Plan is to describe LEU’s programs, practices, and measures in-place, which effectively reduce the probability that LEU’s electric supply system could be the origin or contributing source for the ignition of a wildfire. To support this goal, LEU 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. The secondary goal of this Wildfire Mitigation Plan is to improve the resiliency of the electric grid. As part of the development of this plan, LEU will continue to assess new industry practices and technologies that will reduce the likelihood of an interruption (frequency) in service and improve the restoration (duration) of service. Lodi Electric Utility Wildfire Mitigation Plan Version 1.0 XXXXXX, XX, 2019 4  III. ROLES AND RESPONSIBILITIES A. UTILITY GOVERNANCE STRUCTURE Citizens of Lodi Lodi City Council City Manager Electric Utility Public Works Parks & Rec Police Chief Fire Chief Director Director Director Engineering & Electric Operations Water Utility Mgr. Superintendent Operations Substation Division Division Engineering Construction / Division Maint. Division Vegetation Management Excerpted City of Lodi Organization Chart, As Relevant to Wildfire Mitigation LEU’s governance begins with the citizens of Lodi electing a City Council. The City Council appoints a city manager who in turn hires directors and chiefs to run the various departments and utilities within the City’s auspices. A key difference between LEU and Investor Owned Utilities (IOUs) is that LEU is publicly owned and overseen by the very community it serves; LEU has no shareholders and is not-for-profit. Lodi Electric Utility Wildfire Mitigation Plan Version 1.0 XXXXXX, XX, 2019 5  B. WILDFIRE PREVENTION Under the City’s organizational arrangement, LEU’s Director has overall responsibility for the implementation and execution of this plan; LEU’s Engineering and Operations Manager oversees responsibility for electric facility design; and LEU’s Electric Superintendent oversees responsibility for construction, maintenance, inspections, and vegetation management. Other City departments contribute greatly to wildfire prevention efforts. Lodi’s Fire Department conducts various forms of community outreach and has historically worked with Lodi’s Parks & Recreation Department to conduct annual inspections of trees and vegetation in certain within certain properties controlled by the City, with the goal of identifying and removing fire-fuels such as dead trees or underbrush which may have accumulated. C. WILDFIRE RESPONSE AND RECOVERY LEU is available to its customers 24 hours per day, seven days per week, 365 days per year. During a wildfire or other public safety event, LEU’s operations center has the ability to dispatch personnel to aide as needed around the clock. In the event that an incident requires more personnel than LEU has on hand, LEU has mutual-aid agreements in place and available to provide nearly unlimited line-worker resources. LEU staff has the following obligations regarding fire prevention, response, and investigation: • Operate the electrical system in a manner that will minimize potential wildfire risks. • Take all reasonable and practicable actions to minimize the risk of a catastrophic wildfire caused by LEU’s electric facilities. • Coordinate with federal, state, and local fire management personnel as necessary or appropriate to implement LEU’s Wildfire Mitigation Plan. • Immediately report fires, pursuant to existing POU practices and the requirements of this Wildfire Mitigation Plan. • Take corrective action when the staff witnesses or is notified that fire protection measures have not been properly installed or maintained. • Comply with relevant federal, state, and industry standard requirements, including the industry standards established by the California Public Utilities Commission. • Collect and maintain wildfire data necessary for the implementation of this Wildfire Mitigation Plan. • Provide suitable training programs for all employees having obligations for implementation of this Wildfire Mitigation Plan. The City has established and positioned numerous public safety and water-utility resources, available to assist in combating wildfires and assisting with other public safety events and emergencies. In 2019/2020 the City’s Fire Department will be staffed with 57 personnel, including 55 firefighters, company officers, or chief officers. Lodi Electric Utility Wildfire Mitigation Plan Version 1.0 XXXXXX, XX, 2019 6 The Insurance Services Office (ISO) measures the effectiveness of fire-mitigation services in fire protection areas throughout the country5. The ISO assigns each area a Public Protection Classification (PPC) rating between one and ten (where one is the best, and ten is the worst). As of May 2019, Lodi has the nearly highest ISO PPC rating of two. The Lodi Fire Department’s high ranking places Lodi, in the top 95 percent of the ISO’s fire-mitigation effectiveness rankings, nationwide. A Class 2 ISO rating “indicates that the Fire Department is strategically placed throughout the City, and has adequate personnel, equipment, and expertise to serve the current population.”6 Source: https://www.isomitigation.com/p pc/program-works/facts-and- figures-about-ppc-codes- around-the-country/ 5/9/2019 Unlike many volunteer fire departments, Lodi’s Fire Department is staffed with professional firefighters 24/7/365 and maintains a constant high-level of readiness.” As of 8/7/2019, the department met the self-imposed National Fire Protection Association’s response time criteria of 6 minutes for 90% of all calls.7 As of 2018, the City operated 28 groundwater wells providing a total pumping capacity of 37,910 gallons per minute8,9 in addition to a Surface Water Treatment Plant, which currently has a capacity of 10-million gallons per day10,11. The 28 wells are computer controlled and “operate automatically on pressure demand, so that when water use increases, more wells are started”12. “Seven wells are fitted with emergency diesel powered generators. (….will help maintain water 5 http://www.iso.com/isoPassportHelp/reading_loc_ppc_reports.htm 6 City of Lodi, General Plan, 4/2010 § 3.3 7 Lodi Ca. Incident Compliance Percentage Report, June July 2019 8 City of Lodi, Public Works, Annual Water Quality Report For 2018 9 City of Lodi, Public Works, Water Master Plan, 2012, § 2.1 10 City of Lodi, Urban Water Management Plan, Pg. 40 11 City of Lodi, Public Works, Annual Water Quality Report For 2018 12 City of Lodi, Public Works, Annual Water Quality Report For 2018 Lodi Electric Utility Wildfire Mitigation Plan Version 1.0 XXXXXX, XX, 2019 7 pressure during power outages….)”13 The City has 4.1 million gallons of water storage, spread across three different tanks14, and is scheduled to receive an additional million-gallon storage tank in October of 2019, increasing storage capacity to 5.1 million gallons15. During peak-season (roughly coinciding with high-heat and fire-season), the City’s Water Utility’s operating practice is to maintain its massive storage reserves at a nearly-full capacity. “The City of Lodi owns and operates 28 emergency standby generator sets that range in size between six kilowatt (kW) to 2,000kW. The generators are located at critical facilities where operation during an extended power outage is necessary to maintain public health and/or safety. Examples of these facilities include fire stations, water wells, the Surface Water Treatment Plant, sanitary lift stations, White Slough Water Pollution Control Facility (WSWPCF), the police station, and Lodi Public Library.”16 The City has also undertaken replacement projects to upsize two and three inch water mains, to larger sizes, capable of providing more flows during fires.17 Additionally, Lodi’s Fire Department has the ability to pump water from the Mokelumne River -- a nearly unlimited fire-water resource on the northern edge of town. Lodi’s Fire Department also has access to wide-area mutual-aid resources, able to provide yet more water tenders and substantial additional fire-fighting resources. The General Plan reports the following policing resources, “For 2019, the Police Department has budgeted 111 full-time employees, with 77 sworn officers, and 72 volunteers.”18 “The City has adopted the San Joaquin County Hazard Mitigation Plan. This plan identifies measures to reduce the impacts of natural and manmade hazards and to facilitate the recovery and repair of structures if damage should occur from hazardous events.”19 “The City provides street standards for all street types, thus ensuring appropriate standards for emergency access and evacuation.”20 D. COORDINATION WITH WATER UTILITY AND PUBLIC SAFETY Lodi’s Fire Department, Lodi’s Public Works (including the Water Utility), and Lodi’s Electric Utility, are all departments within the same organization. This unified structure results in frequent contact and communication between the departments on many fronts and topics, and a beneficial familiarity in working together. Lodi’s Fire Department, (generally by way of its 24-hour 13 City of Lodi, Public Works, Annual Water Quality Report For 2018 14 City of Lodi, General Plan, 4/2010 § 3.3 15 City of Lodi, Urban Water Management Plan, Fig. 6-1 16 City of Lodi, City Council meeting, June-19 2019, Agenda Item C-11 17 City of Lodi, General Plan, 4/2010 § 3.3 18 City of Lodi, General Plan, 4/2010 § 8.5 19 City of Lodi, General Plan, 4/2010 § 8.5 20 City of Lodi, General Plan, 4/2010 § 8.5 Lodi Electric Utility Wildfire Mitigation Plan Version 1.0 XXXXXX, XX, 2019 8 Fire Dispatch), is well-versed in requesting assistance from LEU during emergencies. Fire Dispatch requests LEU’s assistance for every structure fire; for all other fires (e.g. vehicle fires) LEU assistance is always available, with utilization determined on a case-by-case basis by the event’s Incident Commander. Examples of LEU assistance include, to de-energize lines for fire and rescue operations, and to assess the hazards when overhead lines are on the ground (such as due to car accidents). While Lodi’s Police Department requests assistance from LEU less often, the same available communication channels and ready access exist. The Water Utility’s infrastructure is designed to automatically increase pressure and water-supply to the areas of the system where it’s needed, 24 hours per day, without any human involvement required. In the rare event that an unusually large or prolonged event requires more water than is normally possible, Lodi’s Water Utility staff are available 24 hours per day; Lodi’s Fire Department is able to notify the Water Utility of any unusual need. Upon such notification, the Water Utility has some additional ability to manually increase supply and pressure, and allocate more water to certain parts of town. E. COORDINATION WITH COMMUNICATION INFRASTRUCTURE PROVIDERS In the event of a disaster, Lodi has various different communication channels available for notifying and messaging the public. • Lodi has access to the County of San Joaquin’s emergency alert system – able to interrupt radio and television programming to provide an emergency message. • The County of San Joaquin also has a cell-phone triangulation system, able to message cell phones within a user-definable region. This system is available to Lodi for emergency use. • Lodi has the ability to broadcast a message onto the AM spectrum. • Lodi Unified School District has public-messaging capabilities available to the City. • Lodi is currently developing a reverse-911 system, whereby emergency personnel can send an emergency notification message to area cell-phones, land-lines, and VOIP phones. This system is estimated to be available to Lodi by 2021. • LEU also provides notifications on our website www.lodielectric.com and is presently developing an Outage Management System (OMS) and an Interactive Voice Response (IVR) system, to be used for notification purposes once completed. F. STANDARDIZED EMERGENCY MANAGEMENT SYSTEM As a local governmental agency,21 the City of Lodi has planning, communication, and coordination obligations pursuant to the California Office of Emergency Services’ Standardized Emergency Management System (“SEMS”) Regulations,22 adopted in accordance with Government Code section 8607. The SEMS Regulations specify roles, responsibilities, and 21 As defined in Cal. Gov. Code § 8680.2. 22 19 CCR § 2407. Lodi Electric Utility Wildfire Mitigation Plan Version 1.0 XXXXXX, XX, 2019 9 structures of communications at five different levels: field response, local government, operational area, regional, and state.23 Pursuant to this structure, the City of Lodi annually coordinates and communicates with the relevant safety agencies as well as other relevant local and state agencies. Under the SEMS structure, a significant amount of preparation is done through advanced planning at the county level, including the coordination of effort of public, private, and nonprofit organizations. San Joaquin County serves as the Operational Area; Lodi’s representation includes the City of Lodi’s Fire Chief. The Operational Area includes local and regional organizations that bring relevant expertise to the wildfire prevention and recovery planning process. Pursuant to the SEMS structure, City of Lodi representatives participate in regular meetings (typically monthly) and various simulation exercises (typically yearly), wherein various disasters (e.g. flood, earthquake, fire, etc.) are simulated. LEU is a member of the California Utility Emergency Association, which plays a key role in ensuring communications between utilities during emergencies. LEU also participate in the Western Energy Institute’s Western Region Mutual Assistance Agreement, which is a mutual assistance agreement covering utilities across a number of western states. IV. WILDFIRE RISKS AND DRIVERS ASSOCIATED WITH DESIGN, CONSTRUCTION, OPERATION, AND MAINTENANCE 23 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. Lodi Electric Utility Wildfire Mitigation Plan Version 1.0 XXXXXX, XX, 2019 10  A. PARTICULAR RISKS AND RISK DRIVERS ASSOCIATED WITH TOPOGRAPHIC AND CLIMATOLOGICAL RISK FACTORS Within LEU’s service territory and the surrounding areas, the primary risk drivers for wildfire are the following: • Extended drought • High winds • Vegetation density B. ENTERPRISEWIDE SAFETY RISKS Fire risks due to drought and windy conditions are low within LEU’s service territory. Lodi is a well- developed area with over 50 percent underground high voltage circuitry. A statewide fire threat map was adopted by CPUC to delineate the boundaries to identify, evaluate and potentially adopt stricter fire-safety regulations that apply to overhead power lines, electric equipment, and communications lines located within those boundaries. An overlay (of LEU’s service territory and overhead transmission lines coming into the City of Lodi) on the fire threat map was created to identify wildfire safety risks. LEU’s service territory and transmission lines fall under the category of Tier 1 (i.e. low risk). The description of tiered fire threat zones are shown in Table 1 and the overlay of LEU’s service territory over the CPUC fire threat map is shown as Exhibit 1 below. Table – 1 Description of tiered fire threat zones Zone Category Description Wildland areas where exposure to overhead power lines, the availability Tier 3 Extreme of water resources, and emergency responder circulation routes affect response times to combat wildland fires. Elevated risk due to vegetation, high voltage regional transmission lines Tier 2 Elevated crossing the area, and adjacency to Tier 3 fire threat zones. Tier 1 Low Well developed areas, typically with underground high voltage circuitry. Lodi Electric Utility Wildfire Mitigation Plan Version 1.0 XXXXXX, XX, 2019 11  Exhibit – 1 Overlay of LEU’s service territory over the CPUC fire threat map Note: Three 60kV transmission lines originating from PG&E’s Lockeford substation enter LEU’s service territory at the Industrial substation. Lodi Electric Utility Wildfire Mitigation Plan Version 1.0 XXXXXX, XX, 2019 12  C. CHANGES TO CPUC FIRE THREAT MAP Currently LEU does not propose any changes to the borders of the High Fire Threat District boundaries as indicated in CPUC’s fire threat map (adopted by the CPUC January 19, 2018). Lodi Electric Utility Wildfire Mitigation Plan Version 1.0 XXXXXX, XX, 2019 13  V. WILDFIRE PREVENTATIVE STRATEGIES A. HIGH FIRE THREAT DISTRICT LEU, as a member of CMUA, participated in the development of the CPUC’s fire-threat map which designates a high-fire threat district. In the map development process, LEU served as a territory lead, and worked with utility staff and local fire and government officials to identify the areas of LEU’s service territory that are at an elevated or extreme risk of power line ignited wildfire. It was determined that LEU’s service territory and 60 kV transmission lines leading into the service territory are located outside of the high fire threat district as designated by the CPUC Fire-Threat Map. B. WEATHER MONITORING LEU monitors current and forecasted weather data from a variety of sources including: • LEU’s in-house weather station • United States National Weather Service • “PG&E Weather Awareness” website24 (an aggregation of regional PSPS, wind, temperature, Red-Flag and other information) • “PG&E PSPS Maps” website25 C. DESIGN AND CONSTRUCTION STANDARDS LEU’s electric facilities are designed and constructed per the City of Lodi’s Electric Overhead Construction Standards to meet or exceed the relevant federal, state, or industry standards. LEU treats CPUC General Order (GO) 95 as a key industry standard for design and construction of overhead electrical facilities. LEU meets or exceeds all standards in GO 95. Additionally, LEU monitors and follows as appropriate the National Electric Safety Code. D. VEGETATION MANAGEMENT LEU meets or exceeds the minimum industry standard vegetation management practices. The recommended time-of-trim guidelines do not establish a mandatory standard, but instead provide useful guidance to utilities. LEU will use specific knowledge of growing conditions and tree species to determine the appropriate time-of-trim-clearance in various circumstances. GO 95, Rule 35, Table 1 Case Type of Clearance Trolley Supply Supply Supply Contact, Conductors Conductors Conductors 24 https://www.pge.com/en_US/safety/emergency-preparedness/natural-disaster/wildfires/psps-weather- map.page?WT.mc_id=Vanity_weather 25 https://www.pge.com/en_US/safety/emergency-preparedness/natural-disaster/wildfires/psps-event-maps.page Lodi Electric Utility Wildfire Mitigation Plan Version 1.0 XXXXXX, XX, 2019 14  Feeder and and Supply and Supply and Supply Span Wires, 0- Cables, 750 - Cables, 22.5 - Cables, 300 - 5kv 22,500 Volts 300 kV 550 kV (mm) 13 Radial clearance of 18 inches 18 inches ¼ Pin ½ Pin bare line conductors Spacing Spacing from tree branches or foliage 14 Radial clearance of 18 inches 48 inches 48 inches 120 inches bare line conductors from vegetation in the Fire-Threat District 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 Radial clearances for any conductor of a line operating at 2,400 or 4 feet more volts, but less than 72,000 volts Radial clearances for any conductor of a line operating at 72,000 or 6 feet more volts, but less than 110,000 volts Radial clearances for any conductor of a line operating at 110,000 or 10 feet more volts, but less than 300,000 volts Radial clearances for any conductor of a line operating at 300,000 or 15 feet more volts LEU’s typical practice for trimming exceeds GO-95 Table-1, as well as the recommendations in GO-95 Appendix-E Case-13. LEU’s standard practice in trimming is to provide a minimum five- foot clear zone area around all secondary-voltage overhead infrastructure, a minimum ten-foot clear zone around all primary-voltage overhead infrastructure, and a minimum 15-foot clear Lodi Electric Utility Wildfire Mitigation Plan Version 1.0 XXXXXX, XX, 2019 15 zone around all sub-transmission and transmission overhead infrastructure. In instances including when our arborists believe that this high degree of trimming may kill a tree, they will occasionally reduce these large clearances, never going below GO-95’s proscribed values. LEU, Typical Trimming Clearances: Secondary Primary Sub-Transmission / Voltage Voltage Transmission Voltage ≤ 600V 12 kV LL 60 kV LL 5’ 10’ 15’ While LEU’s typical-practices already greatly exceed the state’s GO-95 requirements, LEU will at times trim vegetation even further for various reasons including arboricultural best practices, matching prior trimming cuts, aesthetics, or customer request. Additional features of LEU’s tree trimming program: • Prioritization given to dense-vegetation areas. • Consideration for vegetation-species, when determining prioritization. • When LEU encounters fast-growing or invasive species beneath overhead power lines, subject to permission from tree’s owner, LEU will undertake complete removal in lieu of trimming. • If LEU can anticipate an imminent seasonal growth spurt, LEU will generally trim deciduous trees beyond LEU’s typical amounts. • LEU has at its disposal two dedicated tree crews; LEU’s tree contractor has over 900 employees26, and offers the ability to greatly scale-up on a job-by-job basis should a particular job need additional crews and resources. • LEU’s contractor can provide cranes, as needed. • Every tree in proximity of electric infrastructure will be visited every 18-24-months, some even more frequently. • While customer initiation is not required, customers with concerns can submit a request to have their vegetation situation reviewed. Customer-initiated requests are visited for assessment purposes within 48-hours, and frequently as fast as same-day. LEU receives an estimated 10-20 of these requests per week. E. INSPECTIONS 26 https://westcoastarborists.com/ Lodi Electric Utility Wildfire Mitigation Plan Version 1.0 XXXXXX, XX, 2019 16 LEU meets or exceeds the minimum inspection requirements provided in CPUC GO 165 and CPUC GO 95, Rule 18. Additionally, LEU staff uses their knowledge of the specific environmental and geographical conditions to determine when certain areas require more frequent inspections. General Order 165 Table 1 -- Distribution Inspection Cycles (Maximum Intervals in Years) Patrol Detailed Intrusive Urban Rural Urban Rural Urban Rural Transformers Overhead 1 21 5 5 --- --- Underground 1 2 3 3 --- --- Padmounted 1 2 5 5 --- --- Switching/Protective Devices Overhead 1 21 5 5 --- --- Underground 1 2 3 3 --- --- Padmounted 1 2 5 5 --- --- Regulators/Capacitors Overhead 1 21 5 5 --- --- Underground 1 2 3 3 --- --- Padmounted 1 2 5 5 --- --- Overhead Conductor and Cables 1 21 5 5 --- --- Streetlighting 1 2 x x --- --- Wood Poles under 15 years 1 2 x x --- --- Wood Poles over 15 years which have not been 1 2 x x 10 10 subject to intrusive inspection Wood poles which passed intrusive inspection --- --- --- --- 20 20 (1) Patrol inspections in rural areas shall be increased to once per year in Extreme and Very High Fire Threat Zones in the following counties: Imperial, Los Angeles, Orange, Riverside, Santa Barbara, San Bernardino, San Diego, and Ventura. Extreme and Very High Fire Threat Zones are designated on the Fire and Resource Assessment Program (FRAP) Map prepared by the California Department of Forestry and Fire Protection’s Fire and Resource or the modified FRAP Map prepared by San Diego Gas & Electric Lodi Electric Utility Wildfire Mitigation Plan Version 1.0 XXXXXX, XX, 2019 17 Company (SDG&E) and adopted by Decision 12-01-032 in Phase 2 of Rulemaking 08-11-005.The fire threat map is to be used to establish approximate boundaries and Utilities should use their own expertise and judgment to determine if local conditions require them to adjust the boundaries of the map. F. RECLOSING POLICY In contrast with the majority of electric utilities in California, at present, LEU does not have any reclosers deployed downstream of LEU’s substations. All of LEU’s circuit breakers have reclosing functionality, controlled by SCADA. They are programmed to have a single reclose operation with a 3 second delay. LEU has the capability, should it be deemed necessary, to change the relay or reclosing settings during adverse conditions. G. DE-ENERGIZATION LEU has the authority to preemptively shut off power due to fire-threat conditions; however, this option will only be used in extraordinary circumstances. Due to minimal risk of LEU’s electrical supply facilities causing a power-line ignited wildfire, LEU is not adopting specific protocols for de-energizing any portions of its electric distribution system. LEU will re-evaluate this determination in future updates to this Wildfire Mitigation Plan. Since the practice of de-energizing lines (aka “Public Safety Power Shutoff”) is undertaken as a preventative measure to prevent a potential event of unknown certainty, based largely upon weather predictions of unknown accuracy, it carries the risk of being undertaken unnecessarily. While utilities in certain sparsely populated, hard-to-access wildland areas will occasionally conduct a de-energization, the decision to do so in dense urban population centers such as the City of Lodi, introduces its own safety concerns: • A large percentage of Lodi’s signalized intersections do not have battery backups. During loss of power, numerous four-way arterial intersections (and others) lose their traffic-signal and street-lighting, greatly increasing the risk of traffic accidents. • Depending on the area involved, de-energization may remove the primary source of power to certain Water Utility infrastructure, whose wells, pumps and other assets are distributed across LEU’s territory. The continued delivery of water is integral to combating fires and providing safe clean drinking water to the residents of the City. • Lodi occasionally reaches high summertime temperatures. Upon loss of power, certain vulnerable residents who depend on air conditioning can suffer heat-related medical issues. Lodi Electric Utility Wildfire Mitigation Plan Version 1.0 XXXXXX, XX, 2019 18  • Some customers’ medical conditions require specialized powered medical equipment. While the best-practice would be for these customers to maintain backup sources and to pre-arrange exit plans, many do not. Further, these customers do not always identify themselves to LEU, creating the situation where any powerline under consideration for de-energization risks disconnecting an unknown number of these critical customers. • Industry-wide, many house fires have been caused by customers who attempt to use a stove during a power outage, mistakenly leaving it in the on position, and are not present when power is restored. • Under fire-threat conditions, which may already cause first responders to be stretched thin, de-energization imposes additional demands on first responders, such as combating looting, controlling unpowered intersections, evacuating residents, responding to heat- related medical issues, etc. and more. • Cell phones, laptops, electric cars, and other battery-powered objects are unable to charge during loss-of-power. • During Northern California’s 2017 wildfires, five persons died, unable to open their garage-doors after loss of power27. • Once the conditions triggering de-energization have passed, many utilities will methodically patrol every section of every line to verify their condition is acceptable for re-energization (e.g. free of tree-branches and in good condition). Unlike a momentary outage with an instantaneous restoration, this inspection process can be very lengthy and increases each of the above impacts. 27 https://www.sacbee.com/news/politics-government/capitol-alert/article218811560.html Lodi Electric Utility Wildfire Mitigation Plan Version 1.0 XXXXXX, XX, 2019 19  VI. COMMUNITY OUTREACH AND PUBLIC AWARENESS LEU will present the draft version of this plan to the Lodi City Council during public meetings. Currently LEU plans to hold two public meetings before adopting this plan. LEU will contract with an independent third party to perform an annual audit of this Wildfire Mitigation Plan. The audit findings will be presented to the Lodi City Council at a public meeting where the general public will have the opportunity to provide comments. In addition, LEU will post this plan on the LEU website www.lodielectric.com and make it available for public review in the City Clerk’s office. VII. RESTORATION OF SERVICE LEU has an Electric Emergency Plan (EEP) which governs the order in which loads are restored to service. The EEP shows the order in which circuits are to be brought up following a city wide blackout. Vital loads are restored first followed by non-vital loads. In the event of a partial outage, circuits will be brought back as conditions permit in the order of priority listed in the EEP. Lodi Electric Utility Wildfire Mitigation Plan Version 1.0 XXXXXX, XX, 2019 20  VIII. EVALUATING OF THE PLAN A. METRICS AND ASSUMPTIONS FOR MEASURING PLAN PERFORMANCE LEU 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. METRIC 1: FIRE IGNITIONS For purposes of this metric, a fire ignition is defined as follows: • An LEU facility was associated with the origin of the fire28; • 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 • LEU has knowledge that the fire occurred. In future Wildfire Mitigation Plans, LEU will provide the number of fires that occurred that were less than 10 acres in size. Any fires greater than 10 acres will be individually described. METRIC 2: WIRES DOWN The second metric is the number of distribution and transmission wires downed within LEU’s service territory. For purposes of this metric, a wires-down event includes any instance where an electric transmission or primary distribution conductor falls to the ground or on to a foreign object. LEU will not normalize this metric by excluding unusual events, such as severe storms. Instead, LEU will supplement this metric with a qualitative description of any such unusual events. B. IMPACT OF METRICS ON PLAN In the initial years of this plan, LEU anticipates that there will be relatively limited data gathered through these metrics. However, as the data collection history becomes more robust, LEU will be able to identify areas of its operations and service territory that are disproportionately impacted. LEU will then evaluate potential improvements to the plan. C. MONITORING AND AUDITING THE PLAN 28 Origin of the Fire distinguishes from fires of external origin e.g. a discarded cigarette butt, arson etc., which then spreads to involve utility facilities. This distinction is in keeping with the goal of identifying and minimizing utility-sources of fire, and not diluting the metric’s value with fires of unrelated origin. Lodi Electric Utility Wildfire Mitigation Plan Version 1.0 XXXXXX, XX, 2019 21 This Wildfire Mitigation Plan will be presented to the Lodi City Council. LEU will present this plan to the Lodi City Council on an annual basis. Additionally, a qualified independent evaluator will present a report on this plan to the Lodi City Council. D. IDENTIFYING AND CORRECTING DEFICIENCIES IN THE PLAN The LEU Wildfire Mitigation Plan will be internally audited for completeness and effectiveness annually in preparation for the presentation to the Lodi City Council. Additionally, a third-party auditor will review the plan and provide feedback to LEU and the Lodi City Council as described in VIII.C. Findings from the above audits will be recorded by LEU’s Operations Division and appropriate corrections to the Wildfire Mitigation Plan and supporting procedures and processes will be made. E. MONITORING THE EFFECTIVENESS OF INSPECTIONS A key mitigation measure against wildfires in LEU’s service territory is foliage management. LEU uses contract tree trimmers who audit the foliage in need of management and they perform the actual foliage management. LEU then performs independent inspections/patrols which are focused in part on foliage in the vicinity of power lines. In addition, LEU Staff performs patrols and inspections referencing GO 165 as a guideline. The purpose of these inspections is to identify system issues and deficiencies. The results of these patrols and the associated corrective action are recorded and managed to closure through a Computer Maintenance Management System (CMMS). The findings of these patrols together with any trending provided by the metrics tracked in VIII.A of this plan will provide evidence of the effectiveness of the LEU Wildfire Mitigation plan. Lodi Electric Utility Wildfire Mitigation Plan Version 1.0 XXXXXX, XX, 2019 22  IX. INDEPENDENT AUDITOR Public Utilities Code section 8387(c) requires LEU 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 Lodi Electric Utility’s website and presented to the Lodi City Council at a public meeting. LEU, a member of the Northern California Power Agency (NCPA), will leverage the expertise of NCPA in selecting and engaging an independent evaluator as required in PUC Section 8387(c). The above-referenced evaluator will perform an audit of the LEU Wildfire Mitigation Plan annually. The third-party evaluator will be provided the plan and given the opportunity to audit the LEU processes as necessary to complete the audit. The bulk of the audit should be performed on site at LEU’s main office located at 1331 S. Ham Lane, Lodi, CA 95242. Some amount of electronic information sharing in preparation for the audit and following the audit will be allowed. Following the completion of the audit, the third-party evaluator shall provide an outbrief with relevant LEU staff and prepare a written report of findings which shall be presented to the Lodi City Council at a public meeting. All records associated with these audits shall be retained by LEU for at least five years. X. CROSS REFERENCES TO SB-901 REQUIREMENTS CROSS REFERENCES TO SB 901 REQUIREMENTS Location in Requirement Statutory Language POU Template Persons PUC § 8387(b)(2)(A): An accounting of the responsibilities of Section III Responsible persons responsible for executing the plan. Objectives of PUC § 8387(b)(2)(B): The objectives of the wildfire mitigation Section II the Plan plan. PUC § 8387(b)(2)(C): A description of the preventive strategies and programs to be adopted by the local publicly owned Preventive electric utility or electrical cooperative to minimize the risk of Section V Strategies its electrical lines and equipment causing catastrophic wildfires, including consideration of dynamic climate change risks. PUC § 8387(b)(2)(D): A description of the metrics the local Evaluation publicly owned electric utility or electrical cooperative plans Section VIII.A Metrics to use to evaluate the wildfire mitigation plan’s performance and the assumptions that underlie the use of those metrics. Lodi Electric Utility Wildfire Mitigation Plan Version 1.0 XXXXXX, XX, 2019 23  PUC § 8387(b)(2)(E): A discussion of how the application of Impact of Section VIII.B previously identified metrics to previous wildfire mitigation Metrics plan performances has informed the wildfire mitigation plan. PUC § 8387(b)(2)(F): Protocols for disabling reclosers and deenergizing portions of the electrical distribution system that Deenergization consider the associated impacts on public safety, as well as Section V.F Protocols protocols related to mitigating the public safety impacts of Section V.G those protocols, including impacts on critical first responders and on health and communication infrastructure. PUC § 8387(b)(2)(G): Appropriate and feasible procedures for Section III.D notifying a customer who may be impacted by the Customer Section III.E deenergizing of electrical lines. The procedures shall consider Notification Section III.F the need to notify, as a priority, critical first responders, health Procedures Section V.G care facilities, and operators of telecommunications infrastructure. Vegetation PUC § 8387(b)(2)(H): Plans for vegetation management. Section V.D Management PUC § 8387(b)(2)(I): Plans for inspections of the local publicly Inspections owned electric utility’s or electrical cooperative’s electrical Section V.E infrastructure. 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: Prioritization of (i) Risks and risk drivers associated with design, construction, Section IV.A Wildfire Risks operation, and maintenance of the local publicly owned electric Section IV.B 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. PUC § 8387(b)(2)(K): Identification of any geographic area in the local publicly owned electric utility’s or electrical CPUC Fire cooperative’s service territory that is a higher wildfire threat Threat Map than is identified in a commission fire threat map, and Section IV.C Adjustments identification of where the commission should expand a high fire threat district based on new information or changes to the environment. Enterprisewide PUC § 8387(b)(2)(L): A methodology for identifying and Section IV.B Risks presenting enterprisewide safety risk and wildfire-related risk. Lodi Electric Utility Wildfire Mitigation Plan Version 1.0 XXXXXX, XX, 2019 24  PUC § 8387(b)(2)(M): A statement of how the local publicly Restoration of owned electric utility or electrical cooperative will restore Section VII Service service after a wildfire. 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. Monitor and (ii) Identify any deficiencies in the wildfire mitigation plan or its implementation, and correct those deficiencies. Section VIII.C-E Audit (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. 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 Qualified comprehensiveness of its wildfire mitigation plan. The Independent independent evaluator shall issue a report that shall be made Section IX Evaluator 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. Lodi Electric Utility Wildfire Mitigation Plan Version 1.0 XXXXXX, XX, 2019 25  Information NOT REQUIRED BY SB 901 Template Topic Location in POU Template Policy Statement Section I.A Purpose of the Plan Section I.B Background Section I.C Organization of the Plan Section I.D Coordination with water utilities Section III.D Coordination with communication companies Section III.E Standardized Emergency Management Systems Section III.F High Fire Threat District Section V.A Weather Monitoring Section V.B Design and Construction Section V.C Community Outreach Section VI Lodi Electric Utility Wildfire Mitigation Plan Version 1.0 XXXXXX, XX, 2019 26 WILDFIRE MITIGATION PLAN UPDATE 10/15/2019 TIMELINE • 2011 – 2017: CA experienced consecutive dry years with significantly below average precipitation • 9/24/2016: CA. enacts SB 1028. Wildfire-plan required only upon local- level determination of “significant risk of catastrophic wildfire” • 10/8/2017: Series of fires (Tubbs, Atlas, Nuns, more), ravage Northern California: • 44 Deaths, 9,100 structures destroyed/damaged, 228,000 acres scorched • 12/12/2017: Cal Fire and US Forest Service report states there are at least 129 Million dead trees in CA. (largely drought-caused) • 2018 wildfire season brings yet more devastation: • 103 deaths, 24,000 structures destroyed/damaged, 1.5 Million acres scorched • 9/21/2018: CA. enacts SB 901 CA. SB 901 • All local electric utilities must prepare a Wildfire Mitigation Plan • Various required elements include: • Enterprise-wide safety risks • Identification of specific topographic risks • Protocols for reclosers • Vegetation management • Consideration of deenergization protocols and resulting impacts • Metrics • Review by a “qualified independent evaluator” • Presented at a public meeting • Approved by local board • Submitted to the State • Complete all of the above by Jan. 1, 2020 (and annually thereafter) LODI’S SB 901 PROGRESS • Grappling with new requirements • 34,000 word unfunded-mandate • Inaugural undertaking • Aggressive timelines, racing the clock • Over the last several months, Staff has been authoring a draft plan • Solicited comments and feedback from multiple entities including: • Lodi Fire Department • Lodi Police Department • Lodi Public Works Department • Lodi Parks Department • Risk Management, City Attorney, City Manager • NCPA • As required by SB 901, LEU has contracted with an independent auditor who is now reviewing the plan • Subsequent to the auditor’s feedback and the correction of any plan- deficiencies, LEU will present this plan to Council DISCUSSION • Drought • CA construction grade • Wind • Contact between vegetation and powerlines LODI SPECIFICS • Wildfire is a great risk for utilities with miles of hard-to-access lines traversing dead-forests and varied terrain, in sparsely populated areas with minimal visibility • LEU serves a dense urban area • High-visibility on utility assets & quick discovery of any issues • No asset is more than a 10-minute drive from LEU’s office resulting in quick identification of any issues • Beneficial geography: • Bordered to the North by a river • Terrain is flat, lacking steep-slopes and other fire-exacerbating features • Beneficial land-use • Surrounded by miles of grapes. Grapes’ open-space, moisture- content and active management, are often considered an excellent fire-break LODI SPECIFICS LEU SPECIFICS • With contact between vegetation and powerlines implicated in many of the recent wildfires, vegetation management (AKA “Tree Trimming”) is one of the best risk-reduction tools Lodi has • LEU currently budgets $750,000 per year in external resources alone • LEU exceeds industry standards • Vegetation-management occasionally requires a firm-stance with customers LEU SPECIFICS LEU regularly patrols the system looking for anomalies. LEU abides by industry inspection standards such as CPUC’s General-Order 165: Patrol Detailed Intrusive Maximum Inspection Cycles in Years Urban Rural Transformers Overhead 1 21 5 --- Underground 1 2 3 --- Padmounted 1 2 5 --- Switching/Protective Devices Overhead 1 21 5 --- Underground 1 2 3 --- Padmounted 1 2 5 --- Regulators/Capacitors Overhead 1 21 5 --- Underground 1 2 3 --- Padmounted 1 2 5 --- Overhead Conductor and Cables 1 21 5 --- Streetlighting 1 2 x --- Wood Poles under 15 years 1 2 x --- Wood Poles over 15 years which have not 1 2 x 10 been subject to intrusive inspection Wood poles which passed intrusive --- --- --- 20 inspection LODI’S WATER RESOURCES • The City operates 28 groundwater wells having a pumping capacity of 37,910 gallons per minute • The Surface Water Treatment Plant, has a capacity of 10-million gallons per day • Seven wells are fitted with emergency diesel powered generators • The City has 4.1 million gallons of water storage, spread across three different tanks, and is scheduled to receive an additional million-gallon storage tank in January of 2020, increasing storage capacity to 5.1 million gallons LODI’S FIRE-FIGHTING RESOURCES • In 2019/2020 Lodi’s Fire Department will have 57 personnel, including 55 firefighters, company officers, or chief officers • Staffed with professional firefighters 24/7/365 and maintains a constant high-level of readiness • Ranked by The Insurance Safety Office (ISO) in the top 95 percent for fire-mitigation effectiveness nationwide • Met the self-imposed National Fire Protection Association’s response time criteria of 6 minutes for 90% of all calls (8/7/2019) • Has the ability to pump water from the Mokelumne River – a nearly unlimited fire-water resource • Has access to wide-area mutual-aid resources, able to provide yet more water tenders and substantial additional resources DEENERGIZATION / PUBLIC SAFETY POWER SHUT-OFFS (PSPS) • Involves proactively shutting-off power to high-risk areas under high- fire danger conditions (e.g. high heat, high winds), until conditions have subsided • Can prevent certain fires if done correctly • Required to be considered and addressed under SB 901 DEENERGIZATION / PUBLIC SAFETY POWER SHUT-OFFS (PSPS) Introduces many hazards of its own: • Numerous four-way intersections lose their traffic-signals and street- lighting, increasing the risk of traffic accidents • Vulnerable residents who depend on air conditioning can suffer heat- related medical issues • Some customers’ medical conditions require powered medical equipment. While the best-practice would be for these customers to maintain backup sources and to pre-arrange exit plans, many do not. Further, these customers do not always identify themselves to LEU, creating the situation where any powerline under consideration for de- energization risks disconnecting an unknown number of these critical customers DEENERGIZATION / PUBLIC SAFETY POWER SHUT-OFFS (PSPS) • Industry-wide, many house fires have been caused by customers who attempt to use a stove during a power outage, mistakenly leaving it in the on-position, and are not present when power is restored • Cell phones, laptops, electric cars, and other battery-powered objects are unable to charge during loss-of-power • During Northern California’s 2017 wildfires, five persons died, unable to open their garage-doors after loss-of-power • Imposes additional demands on first-responders, (combating looting, controlling unpowered intersections, evacuating residents, responding to heat-related medical issues, etc. and more), who may already be stretched-thin due to fire-threat conditions DEENERGIZATION / PUBLIC SAFETY POWER SHUT-OFFS (PSPS) • Once the conditions triggering de-energization have passed, utilities often methodically patrol every section of every line to verify their condition is acceptable for re-energization (e.g. free of tree-branches and in good condition). This inspection process can be very lengthy and increases each of the above impacts. LEU reserves the right to conduct a PSPS should conditions warrant, however, LEU anticipates doing this extremely infrequently (zero times in the last hundred years) FINAL THOUGHTS • No electric utility is immune to fires • LEU’s Wildfire risk is greatly lowered by several beneficial factors • In over 100-years of operation, LEU is not known to have caused any widespread fire THANK YOU