EXHIBIT O

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ALJ/SRT/PVA/jt2 Date of Issuance 6/3/2019

Decision 19-05-036 May 30, 2019

BEFORE THE PUBLIC UTILITIES COMMISSION OF THE STATE OF CALIFORNIA

Order Instituting Rulemaking to Implement 

Electric Utility Wildfire Mitigation Plans 

Pursuant to Senate Bill 901 (2018).

Rulemaking 18-10-007

GUIDANCE DECISION ON 2019 WILDFIRE MITIGATION PLANS 

SUBMITTED PURSUANT TO SENATE BILL 901

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Table of Contents

Title Page

GUIDANCE DECISION ON 2019 WILDFIRE MITIGATION PLANS 

SUBMITTED PURSUANT TO SENATE BILL 901 ...................................................... 1

Introduction and Summary............................................................................................. 2

1. Procedural Background........................................................................................... 5

2. Organization of Individual Wildfire Mitigation Plan Decision ........................ 9

3. State Response to Wildfires .................................................................................. 10

4. Requirements of SB 901 ......................................................................................... 11

5. Meaning of Commission Approval of WMP Under SB 901 ............................ 13

5.1. Parties’ Comments on What Approval Means Under SB 901................. 13

5.1.1. IOU and CCUE Comments – WMP Approval is Relevant to 

Prudent Manager Test for Cost Recovery............................................. 13

5.1.2. Other Party Comments – WMP Approval Has No Impact on 

Later Cost Recovery ................................................................................. 17

5.2. Discussion of What Approval Means Under SB 901 ................................ 20

6. Metrics, Monitoring and Reportng Required of All WMP Filers.................... 25

7. Evaluation of Current Inspection Plans .............................................................. 27

8. Integration of GRC Process with WMP Review ................................................ 28

9. Off Ramps................................................................................................................ 29

10. Future WMPs .......................................................................................................... 30

10.1.Party Comments – Future WMPs................................................................ 30

10.2.Discussion – Future WMPs........................................................................... 33

11. Consultation with CAL FIRE Has Occurred...................................................... 37

12. Conclusion............................................................................................................... 38

13. Comments on Proposed Decision........................................................................ 38

14. Assignment of Proceeding .................................................................................... 39

Finding of Fact................................................................................................................. 39

Conclusions of Law ........................................................................................................ 40

ORDER ............................................................................................................................. 40

Appendix A – List of Requirements in SB 901 for WMPs

Appendix B – Cross Reference SB 901 – Wildfire Mitigation Plans

Appendix C – List of Acronyms

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GUIDANCE DECISION ON 2019 WILDFIRE MITIGATION PLANS 

SUBMITTED PURSUANT TO SENATE BILL 901

Introduction and Summary

Catastrophic wildfires have devastated California in recent years. The

Legislature enacted Senate Bill 901 in 2018 mandating action by this Commission 

on Wildfire Mitigation Plans of the electrical corporations we regulate. This 

decision addresses issues that are common to all of the Wildfire Mitigation Plans. 

It is one in a series of decisions the Commission is issuing at the same time to act 

on the 2019 Wildfire Mitigation Plans of the three large California investor 

owned electric utilities, the three small and multijurisdictional utilities, and two 

independent transmission owners. 

Along with this decision, the Commission is issuing separate decisions 

addressing the individual Wildfire Mitigation Plans submitted by Pacific Gas 

and Electric Company, Southern California Edison Company, and San Diego 

Gas and Electric Company, and a single combined decision on the Wildfire 

Mitigation Plans of PacifiCorp, Bear Valley Electric Service and Liberty Utilities. 

Finally, we issue a single decision on the Wildfire Mitigation Plans of 

independent transmission owners Trans Bay Cable LLC and NextEra Energy 

Transmission West, LLC., now known as Horizon West Transmission LLC.

This decision addresses issues that are common to all of the Wildfire 

Mitigation Plans, and applies to the Wildfire Mitigation Plans of all respondent 

electrical corporations. Specifically, this guidance decision interprets Senate 

Bill 901; describes the procedural background of the proceeding; orders all 

electrical corporations to collect data and file reports on this year's Wildfire 

Mitigation Plans; initiates a process to establish "metrics" to evaluate the Wildfire 

Mitigation Plans and makes clear that these metrics should focus on the success 

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of mitigation at lowering the risk of catastrophic wildfires and not simply

program targets such as the number of trees removed or wires replaced; and 

creates a process for next year's Wildfire Mitigation Plans. 

Generally speaking, the key and most costly aspects of the individual 

Wildfire Mitigation Plans consist of vegetation management; system hardening 

such as widespread electric line replacement with covered conductors designed 

to lower wildfire ignitions; new inspection programs; and “situational 

awareness” technology such as weather stations, high definition cameras, and 

use of computer modeling, weather and wind data and machine learning to 

predict where wildfires are most likely to strike. The individual Wildfire 

Mitigation Plan decisions focus on these issues because they are the ones on 

which parties provided the most input.

In order to ensure that the Wildfire Mitigation Plans actually reduce the 

risk and occurrence of wildfire, the Commission directs the electrical 

corporations to track data and assess outcomes, so that next year’s plans reflect 

this year’s lessons. We also require reporting this year on 2019 Wildfire 

Mitigation Plan achievements. Senate Bill 901 requires useful metrics that 

measure whether a Wildfire Mitigation Plan is effective in mitigating 

catastrophic wildfires. The “metrics” the electrical corporations currently use 

tend to focus on inputs (number of actions taken such as trees cut or miles of 

conductor installed) rather than outputs or results (effectiveness of the action in 

reducing the risk of wildfire ignition and spread). The statute requires a focus on 

outcomes: “A description of the metrics the electrical corporation plans to use to 

evaluate the plan’s performance and the assumptions that underlie the use of those 

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metrics.”1 This decision orders one or more workshops led by the Commission’s 

Safety and Enforcement Division for the electrical corporations to work with 

Commission staff, parties, and other stakeholders to improve the metrics for next 

year. We allow the electrical corporations to track data they characterize as 

“metrics,” but they should not use the term to describe what are actually 

“program targets.” Using the “metrics” label for program targets such as the 

number of trees cut down causes confusion given SB 901. We also list data the 

filers should capture.

It is important to point out what this decision does and does not do. 

Senate Bill 901 is explicit that approval of Wildfire Mitigation Plans does not 

constitute approval of the costs associated with the actions in the plan. Rather, 

cost recovery is a separate matter to be addressed in each utility’s General Rate 

Case. Thus, while the electrical corporations in some cases submitted high-level 

cost estimates, the Order Instituting Rulemaking initiating this case made clear 

that such information was only an aid to understanding the overall magnitude of 

the Wildfire Mitigation Plans and where the largest expenditures may occur. 

However, we do not approve costs here, because the statute does not allow it. 

We also do not find that substantial compliance with an element of a Plan, or all 

elements of a Plan, establishes that the electrical corporation acted prudently 

when it later seeks to recover its costs. Senate Bill 901 did not redefine the 

“prudent manager” test. 

There are limits on what can be accomplished in this proceeding, as the 

strict statutory deadlines – three months to approve the Wildfire Mitigation 

Plans, with very limited exceptions – provide little time to evaluate each Plan’s 

 

1 Public Utilities Code Section 8386(c)(4) (emphasis added).

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effectiveness. At the same time, this is only the first of what we anticipate will be 

many Wildfire Mitigation Plan proceedings, so this decision contains many 

substantive and procedural requirements for future plans based on lessons 

learned this year. 

We understand the need for haste: all Californians deserve comprehensive 

action before the wildfire season. We hope and expect improvement in the 

Wildfire Mitigation Plans each year through engineering and technological 

advances, but we will not solve the problem of catastrophic wildfires in one year. 

We and the electrical corporations we oversee are but a piece of the solution to 

mitigating catastrophic wildfires.

1. Procedural Background

The Commission opened this proceeding via an Order Instituting

Rulemaking (OIR) issued on October 25, 2018. The intent of the OIR is to

implement the provisions of Senate Bill (SB) 901 requiring electrical corporations 

under the Commission’s jurisdiction to submit annual Wildfire Mitigation Plans 

(WMP or Plan). The OIR provided guidance on the form and content of the

initial WMPs, provided a timeline for review of the 2019 WMPs on the 

three-month schedule set forth in SB 901, and noted that in future years the 

Commission would refine the content of and process for review and

implementation of WMPs to be filed in future years.

The OIR named the three large California investor-owned electric utilities 

(IOUs) as respondents: Pacific Gas and Electric Company (PG&E), Southern 

California Edison Company (SCE), and San Diego Gas & Electric Company 

(SDG&E). It also required Plan filing by three small or multijurisdictional IOUs: 

Liberty Utilities/CalPeco Electric (Liberty), Bear Valley Electric Service, a 

division of Golden State Water Company (Bear Valley or BVES), and Pacific 

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Power, a division of PacifiCorp (PacifiCorp). We address each of the large IOUs’ 

Plans in an individual decision and the three small and multijurisdictional IOUs 

in a single decision. 

In a ruling dated January 17, 2019, the assigned Administrative Law Judge 

(ALJ) added four Independent Transmission Owners (ITOs) as respondents and 

ordered the ITOs to file WMPs, naming Citizens Transmission LLC; Startrans IO, 

LLC (Startrans); Trans Bay Cable LLC; and Trans-Elect NTD Path 15, LLC. This 

decision ratifies that ruling. 

By ruling dated January 31, 2019, the ALJ granted the motion of Citizens 

Transmission LLC (whose correct name is Citizens Sunrise Transmission) to be 

relieved from the obligation to file a 2019 WMP. The ALJ did so after SDG&E 

confirmed by a filing dated January 30, 2019 that it has all operation and 

maintenance obligation for the line Citizens leases.

Other ITOs also sought dismissal or relief from the obligation to file a 

WMP this year. This decision does not grant dismissal but relieves DATC 

Path 15, LLC (the successor in interest to Trans-Elect NTD Path 15, LLC) and 

Startrans of the obligation to file a 2019 WMP based on their assertion that a third 

party not regulated by this Commission is obligated to operate and maintain the 

relevant independent transmission line. 

DATC Path 15, LLC2 is the current holder of transmission rights on the 

Path 15 Upgrade transmission project, which rights it acquired from the entity 

identified in the ALJ’s January 31, 2019 ruling, Trans-Elect NTD Path 15, LLC. 

DATC filed a motion to be removed as a respondent on March 4, 2019 on the 

ground that the Western Area Power Administration (WAPA) is solely 

 

2 DATC Path 15, LLC is indirectly owned by Duke-American Transmission Company LLC.

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responsible for operation and maintenance of the line. DATC supported its 

claim by a declaration under penalty of perjury by the President of DATC 

Path 15, LLC. Since we do not regulate WAPA, a federal agency organized 

under the United States Department of Energy, we do not have a second party 

corroborating DATC’s assertion. Nonetheless, we relieve DATC Path 15, LLC 

from the obligation to file a WMP in 2019, but do not dismiss it as a respondent.

Similarly, Startrans filed a motion to be dismissed from the proceeding on 

March 25, 2019. Startrans claims it is a minority owner of the line, but that the 

line is operated and maintained by publicly owned utility Los Angeles 

Department of Water and Power (LADWP). Startrans’ General Manager filed a 

declaration swearing to the foregoing facts. As with DATC, we relieve Startrans 

of the obligation of filing a WMP in 2019, but do not dismiss it as a respondent.

The remaining ITO in the January 17, 2019 ruling, Trans Bay Cable LLC, 

filed a WMP as required on February 6, 2019. An entity not named in the 

foregoing ruling, Horizon West Transmission LLC., formerly known as NextEra 

Energy Transmission West, LLC (Horizon West)3 filed a WMP with regard to a 

new transmission line, the Suncrest Dynamic Reactive Power Support Project 

approved late last year in Decision (D.) 18-10-030. The Commission addresses 

the Trans Bay Cable LLC and Horizon West WMPs in a single ITO decision.

Parties commented on the OIR on November 18, 2018.4 PG&E, SCE, 

SDG&E, Liberty, PacifiCorp, Bear Valley, Trans Bay Cable LLC, and Horizon 

 

3 NextEra Energy Transmission West LLC changed its name to Horizon West Transmission, 

LLC, and filed a notice of name change in this proceeding on March 21, 2019. It will henceforth 

be referred to as Horizon West.

4 On November 18, 2018, each of the IOUs filed comments on the OIR, jointly or in 

combination. The following additional parties also filed comments on the OIR: The Utility 

Reform Network (TURN); Green Power Institute (GPI); the Commission’s Public Advocates’ 

Footnote continued on next page

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West submitted WMPs on the February 6, 2019 due date.5 On February 13, 2019, 

the Commission held a day-long workshop at which parties and members of the 

public were provided presentations about each WMP by the filers, and were able 

to ask questions and make statements. After the February 13, 2019 workshop, 

parties were asked to suggest topics that required additional attention for 

discussion at follow-up workshops. On February 26, 2019, a half-day workshop 

took place on the meaning of SB 901 approval of WMPs, and a full-day workshop 

occurred on February 27, 2019, to examine the filers’ vegetation management 

plans as well as conductors and related system hardening. Over 300 people 

attended the workshops.

Two prehearing conferences took place in the proceeding, the first on 

November 14, 2018 and the second on February 26, 2019. The Assigned 

Commissioner issued a scoping ruling after the first prehearing conference. The 

parties were given an opportunity to request hearings, and on the prescribed 

deadline of February 20, 2019, two parties – The Utility Reform Network (TURN)

 

Office (Cal Advocates); Hans Laetz on behalf of Zuma Beach FM Broadcasters (Zuma Beach); 

California Municipal Utilities Association (CMUA); the Commission’s Office of the Safety 

Advocate (OSA); the City of Laguna Beach (Laguna Beach); Pacific Bell Telephone Company, 

d/b/a AT&T California, AT&T Mobility1 and AT&T Corp. (AT&T); the California Cable and 

Telecommunications Association (CCTA); East Bay Municipal Utility District (EBMUD); 

Mussey Grade Road Alliance (MGRA); Coalition of California Utility Employees (CCUE); and 

Small Business Utility Advocates (SBUA). Several additional parties sought and obtained party 

status; those that filed comments are listed below.

5 On April 25, 2019, PG&E filed a second amended WMP proposing to extend the timelines on 

many of its major wildfire mitigation efforts. We do not act on those proposals in this decision 

since they were filed too late to be considered and to receive party comment. Phase 2 of this 

proceeding will consider the matter and filings associated with it. This decision does not 

approve actions proposed or described in the PG&E second amended WMP even if PG&E has 

already conducted those actions.

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and Protect Our Communities Foundation (POC) – did so. At the February 26, 

2019 prehearing conference the ALJs denied both motions.

The ALJ also issued a ruling on January 30, 2019 ordering respondents to 

this proceeding to reimburse the Commission for expenses related to the 

engagement of an independent evaluator to review and inspect electrical 

facilities and operational practices for compliance with Commission General 

Orders, statutory requirements and all other applicable decisions and 

orders. This decision ratifies that ruling.

The intervenors (those not filing WMPs) filed comments on the WMPs on 

March 13, 2019, and the IOUs and ITOs filed reply comments on March 22, 2019.6 

Thereafter, the proceeding was submitted for decision.

2. Organization of Individual Wildfire Mitigation Plan 

Decisions

Public Utilities Code Section 8386(c) contains a list of 19 elements each 

electrical corporation must include in its WMP. (The Commission may also 

direct the inclusion of material, making the full list 20 items long.) The WMPs 

and the individual decisions acting on them differ in structure from the statutory 

list because the focus is on the elements on which parties made comments, 

particularly: 

 

6 On March 13, 2019, the following intervenors filed comments on the WMPs: William B. 

Abrams (Abrams), California Environmental Justice Alliance (CEJA), California Farm Bureau 

Federation (CFBF), California Large Energy Consumers Association (CLECA), CCUE, GPI, 

EBMUD, Energy Producers and Users Coalition (EPUC), The County of Los Angeles

(LA County ), City of Malibu (Malibu), MGRA, OSA, POC, Cal Advocates, The City and County 

of San Francisco (CCSF), SBUA, and TURN. Additionally, the following parties jointly filed 

comments: AT&T and CCTA; The County of Mendocino, The County of Napa, The County of 

Sonoma, and The City of Santa Rosa; and Peninsula Clean Energy Authority (PCEA) and 

Sunrun Inc.. On March 22, 2019, the following IOUs and ITOs filed reply comments: PG&E, 

SCE, SDG&E, Liberty, Bear Valley, and Horizon West.

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• inspection and maintenance (Section 8386(a) and (c)(9));

• vegetation management (Section (c)(8));

• system hardening (Section 8386(c)(12));

• situational awareness (Section 8386(c)(3));

• de-energization (Sections 8386(c)(6) and (7));

• disaster preparedness and customer outreach (Sections 

8386(c)(16), (17), (18)); and 

• metrics for evaluating the Plans (Sections 8386(c)(4), (5) and (19)). 

In addition, several of the items listed under Section 8386(c) are not 

mitigation activities, but general requirements that apply to one or more 

mitigation measures or to the WMP as a whole. For example, several sections

require the filer to prioritize risk (Sections 8386(c)(3)(10), (11) and (15)). We 

discuss risk in the context of the mitigation measures noted above, since the 

WMP is supposed to target mitigation measures where they will have the 

greatest impact. Similarly, Section 8386(c)(14) relates to wildfire threat maps, 

which govern where mitigation occurs. 

Each individual decision explains whether the WMP contains all the 

required elements in Section 8386(c) and addresses any deficiencies. Further, 

each decision contains as Appendix B a chart cross-referencing the statute with 

the WMP organizational structure, so it is clear that the Plans meet the statutory 

requirement.

3. State Response to Wildfires

Some history of California’s experience with catastrophic wildfires over 

the past dozen years is in order. Catastrophic wildfires took place in Southern 

California in 2007, and SDG&E ultimately was found responsible for three 

catastrophic wildfires, named Rice, Witch and Guejito. After the 2007 wildfires, 

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the Commission stepped up efforts to mitigate the risk of utility-sourced 

wildfires, as well as more broadly incorporating potential safety risks in 

decision-making. Among other actions and orders, the Commission required 

that IOUs prioritize their asset management and expenditure plans according to 

a safety risk-ranking; strengthened its regulations governing the minimum safety 

standards of overhead electrical infrastructure (e.g., General Order (GO) 95); 

updated the state’s fire maps; and opened a companion proceeding to this one, 

Rulemaking (R.) 18-12-005, to examine existing rules on electric grid 

de-energization (i.e., turning off power at times of high fire threat, sometimes 

known as Public Safety Power Shutoffs or PSPS). Despite our best efforts to date, 

utility-caused wildfires are still occurring, and the Commission recognizes the 

need to redouble wildfire prevention efforts.

4. Requirements of SB 901

Senate Bill (SB) 901 builds on the public utilities’ existing 

Commission-regulated wildfire mitigation and vegetation management plans. 

SB 901 is a comprehensive plan of action for forest management and wildfire 

mitigation and suppression across the state in multiple sectors. With respect to 

utility infrastructure-related wildfire risks, SB 901 requires electrical corporations 

to submit WMPs each year. Pub. Util. Code Section 8386(b). A complete list of 

the 19 elements each WMP must contain is set forth in SB 901 appears in 

Appendix A to this decision. Appendix B to this decision cross references the 

WMPs with the statutory requirements. 

These annual WMPs must include, among other things:

• “Protocols for ... deenergizing portions of the electrical 

distribution system that consider the associated impacts on 

public safety, as well as protocols related to mitigating the public 

safety impacts of those protocols, including impacts on critical 

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first responders and on health and communication 

infrastructure,” Pub. Util. Code § 8386(c)(6);

• Actions the filer will pursue “to ensure its system will achieve the 

highest level of safety, reliability, and resiliency, and to ensure 

that its system is prepared for a major event, including hardening 

and modernizing its infrastructure with improved engineering, 

system design, standards, equipment, and facilities, such as 

undergrounding, insulation of distribution wires, and pole 

replacement,” Pub. Util. Code § 8386(c)(12);

• The filer’s “preventative strategies and programs ... to minimize 

the risk of its electrical lines and equipment causing catastrophic 

wildfires, including consideration of dynamic climate change 

risks,” Pub. Util. Code § 8386(c)(3);

• Metrics to evaluate the WMP’s performance, Pub. Util. Code 

§ 8386(c)(4);

• A ranking of “all wildfire risks, and drivers for those risks,”

throughout the filer’s service territory, which shall include 

wildfire risk and risk mitigation information contained in the 

utility’s Safety Model Assessment Proceeding (S-MAP) and Risk 

Assessment Mitigation Phase (RAMP) filings,7

(Commission-mandated programs to compel risk-based utility 

management and spending), Pub. Util. Code § 8386(c)(10) 

(emphasis added);

• Vegetation Management Plans, Pub. Util. Code § 8386(c)(8);

• Inspection plans for the filer’s electric infrastructure, Pub. Util. 

Code § 8386(9); and

• Improvements to the Commission’s fire mapping, Pub. Util. 

Code § 8386(c)(14).

 

7 Not all of the parties that filed WMPs are subject to RAMP and S-MAP, but the large IOUs 

are.

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The Commission’s task pursuant to SB 901 is to approve, subject to 

modification, the statutory WMPs after verifying compliance with “all applicable 

rules, regulations, and standards, as appropriate.” Pub. Util. Code § 8386(d).

5. Meaning of Commission Approval of WMP 

Under SB 901

A topic that generated a great deal of discussion in the proceeding was the 

effect of WMP approval under SB 901. The IOUs contend that approval of a 

WMP, and “substantial compliance” with the plan, is determinative of whether 

the utility acted as a “prudent manager” when the utility seeks cost recovery for 

the activities in the Plan. Many intervenors, in contrast, assert that approval of a 

WMP has no bearing on whether the IOU has a right to cost recovery, since the 

statute expressly defers review of program costs to IOUs’ general rate cases 

(GRCs). These parties assert that approval of the WMP has no effect on whether 

an IOU seeking cost recovery acted reasonably by meeting the prudent manager 

standard.8 We discuss these arguments below.

5.1. Parties’ Comments on What Approval Means 

Under SB 901

5.1.1. IOU and CCUE Comments – WMP Approval 

is Relevant to Prudent Manager Test for Cost 

Recovery

The IOUs and Coalition of California Utility Employees (CCUE) make two 

basic arguments about the meaning of SB 901 approval: first, that approval has 

bearing on whether they may recover costs of implementing their WMPs in their 

 

8 For a discussion of the prudent manager standard in the catastrophic wildfire context, see the 

Commission’s decision on SDG&E’s application for cost recovery for the 2007 wildfires, 

D.17-11-033, and the decision denying rehearing, D.18-07-025. On November 13, 2018 and 

January 30, 2019, respectively the California Court of Appeal and California Supreme Court 

denied review of the decision denying cost recovery. 

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GRC; and second, that approval and “substantial compliance” with the approved 

WMP is evidence that they meet the “prudent manager” standard that will be at 

issue when they seek cost recovery. 

PG&E states that approval of a plan by the Commission creates 

compliance obligations on the part of the utility. Therefore, it asserts, the 

utilities’ activities to execute the plans must be deemed reasonable if they are in 

substantial compliance with the approved plans, and the utilities must be 

allowed recovery of just and reasonable costs to implement those plans. “To do 

otherwise would constitute an unfunded mandate.”9 PG&E requests that the 

Commission’s approval of its WMP expressly acknowledge that the utilities will 

be allowed recovery of just and reasonable costs to implement the approved 

programs, and, subject to reasonableness review, the utilities retain discretion to 

reprioritize work to address changing conditions, new information, or as a result 

of external factors beyond their control. PG&E also asks that it be allowed to 

seek cost recovery outside the GRC schedule for costs related to its WMP: 

In light of the multi-year intervals between GRCs and the likely 

substantial costs to implement annual plans, the Commission should 

also authorize utilities to seek interim cost recovery via application, 

with costs subject to refund upon reasonableness review in the GRC, 

to provide utilities with the revenues to implement the plans.10 

 

9 PG&E Reply Comments filed March 22, 2019, at 3. References to comments and reply 

comments filed on the WMPs refer to the filer and the page numbers. Intervenor comments

were filed on March 13, 2019, and electrical corporation reply comments were filed on 

March 22, 2019.

10 PG&E, at 30.

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SCE asserts that it takes a “middle ground” by asking that approval of a 

WMP be evidence that SCE acted as a prudent manager when it later seeks cost 

recovery in a GRC.11 SCE states:

Here, SCE is recommending the Commission develop an upfront 

approach that appropriately takes into account the fact that many of 

the factors listed in [Public Utilities Code] Section 451.1 substantially 

overlap with the content of the utilities’ WMPs. Furthermore, under 

SCE’s proposed framework, the Commission would use several of 

the remaining factors listed in Section 451.1 to apportion 

disallowances if a utility fails to substantially comply with its WMP 

and that non-compliance is linked to a wildfire ignition. This is an 

appropriate approach that holds utilities accountable for managing 

wildfire risk without subjecting them to uncertain and prolonged 

cost recovery.12

Acknowledging that SB 901 does not refer to the “prudent manager” test, 

SCE nonetheless states that the Commission should interpret the statute to 

include one:

Further, as the Joint Utilities have made clear, while the statutory 

language does not explicitly mandate that substantial compliance 

with the approved WMP is equivalent to a finding that the utilities 

met the “prudent manager” standard, neither does it preclude such 

an interpretation. It is well within the Commission’s inherent 

authority to interpret the statute in a common-sense manner to make

that determination.13

 

11 The IOUs are on different GRC cycles, and SCE has sought cost recovery for a large part of its 

WMPs in a separate “Grid Safety and Resiliency Program (GSRP)” application, 

Application 18-09-002. The fact that SCE filed and the Commission is considering the GSRP 

application outside the GRC process has no bearing on the meaning of SB 901.

12 SCE, at 3.

13 Id. 

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SCE remarks that an early ruling in the proceeding required the furnishing 

of certain cost data,14 and that that ruling represents a decision that the 

Commission would be determining costs in this proceeding.

SDG&E recommends that, in approving WMPs, the Commission should 

determine that when an electric utility substantially complies with its approved 

Plan, the electric utility has been prudent for purposes of cost recovery 

applications, including but not limited to Public Utilities Code Section 451.1. A 

utility that does not substantially comply is subject to penalties, and if such 

non-compliance is the proximate cause of a wildfire or wildfire costs, the 

Commission may disallow recovery of all, or a portion of, the wildfire costs. 

SDG&E also asserts that even though SB 901 does not mention the prudent 

manager standard, the Commission is free to interpret the law to allow one here: 

“Even if the statute is not explicit in this regard, it is within the Commission’s 

right to interpret the law. SDG&E is required to put forth mitigations in a 

Wildfire Mitigation Plan and after the Commission approves the Plan, if SDG&E 

complies with the Plan, then SDG&E should be deemed prudent.”15

CCUE supports the IOUs, asserting that Commission approval should 

establish compliance requirements and that substantial compliance with a plan 

means the utility acted reasonably and prudently. The remedy for lack of 

substantial compliance, according to CCUE, is a penalty. “It makes no sense to 

say that the plans are mere goals and then mandate penalties if a utility fails to 

 

14 While the ruling asked for high level cost data, it cited the OIR in this proceeding making 

clear that such costs would not be considered in this proceeding. This issue is discussed in the 

discussion section.

15 SDG&E, at 4.

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comply with the goal.”16 Like SCE, CCUE argues that certain required 

components of the plans mirror the factors the Commission must consider, 

pursuant to Public Utilities Code Section 451.1, in determining whether a utility 

can recover costs and expenses arising from a catastrophic wildfire. Therefore, 

CCUE asserts, approval must mean that substantial compliance with the plan 

equates to reasonable and prudent actions by the utility.17

Some respondent electrical corporations asked the Commission to allow 

them interim rate relief, subject to refund. This decision does not resolve those 

requests.

5.1.2. Other Party Comments – WMP Approval Has 

No Impact on Later Cost Recovery

By contrast, many parties assert that SB 901 requires keeping approval of 

the WMPs separate from a judgment on reasonableness of any associated 

expenditures. They assert that the statute requires that reasonableness be left to 

GRC applications. They oppose treating the WMP proposals as compliance 

requirements, and allege that SB 901 does not support the IOUs’ claim that a 

finding of substantial compliance with the targets in a WMP satisfies the prudent 

manager standard.

18 Some of these parties advocate that approval be limited to 

verifying the plans comply with Section 8386(c), i.e., that they address whether 

the WMPs contain each of the 19 components of Section 8386(c).

19

 

16 CCUE, at 5.

17 Id. at 7-8.

18 POC, TURN, Cal Advocates, MGRA, Abrams, CLECA, CEJA, CCSF, CFBF, Malibu, GPI, 

SBUA, and LA County make this argument.

19 These parties are TURN, CEJA, CCSF, EPUC, Malibu, and SBUA.

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CLECA asserts that the plain meaning of SB 901 requires that a 

reasonableness determination occur in a GRC.20 SBUA notes that Public Utilities 

Code Section 451.1 identifies 12 factors the Commission must consider in 

determining whether to authorize cost recovery, and the WMPs are just a part of 

one of those factors.

21

Others assert that the statutory language deferring cost recovery to a GRC 

was intentional. The 3-month schedule allowed for Commission consideration of 

a WMP does not allow time for development of the evidentiary record necessary 

to determine reasonableness of programs or costs.

22 The cost estimates are by no 

means sufficiently precise to merit a determination as to their reasonableness.

23

TURN states that SB 901’s process is nothing new:

The Commission’s longstanding rate case practice makes it clear that 

the determination of whether the costs of a utility program are just 

and reasonable is a two-step process, which can be broadly 

summarized as: (1) whether the program itself is necessary, 

reasonable in scope and pace, and otherwise cost-effective; and (2) if 

so, whether the costs to perform the scope of work that is found to 

be reasonable are themselves reasonable. The first step is often the 

most important and, under the utilities’ interpretation, would 

somehow be resolved by this case, despite the strikingly inadequate 

record that this case affords for making such a determination. 

(TURN, at 5.)

TURN likens this case to the Commission’s approach to energy storage, 

asserting that the Commission first approved a framework, and in later more 

 

20 CLECA, at 4-7; CEJA, at 3; EPUC, at 7; CFBF, at 4-5; Malibu, at 1; SBUA, at 2-3.

21 SBUA, at 3-4.

22 Malibu, at 4; POC, at 2-3; MGRA, at 3; Cal Advocates, at 3; CCSF, at 2-3; TURN, at 1-8; SBUA, 

at 1-2.

23 CFBF, at 4; Cal Advocates, at 3.

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cost-specific proceedings determined cost recovery. TURN cites the 

Commission’s approval of Smart Grid Development Plans (SGDP) in 

D.10-06-047, where the Plans “are guidance documents, and approval of the 

SGDP does not constitute a determination of the reasonableness of any specific 

project.”24 

TURN also analogizes this approach to the Commission's past approach to 

a PG&E program called Cornerstone, where the Commission stated:

. . . our overarching policy is that PG&E must provide reliable 

electric service to its customers. However, that alone is insufficient 

reason for approving Cornerstone. We also have the obligation to 

ensure that rates are reasonable. Whether characterized as a policy 

or a basic ratemaking principle, for a capital program or project such 

as Cornerstone, there must be a compelling demonstration of need. 

A broad policy such as the desirability of maintaining or improving 

electric distribution reliability can only be implemented at the 

program or project level if there is demonstrated need for the 

particular programs or projects. PG&E has the burden to 

demonstrate such need for Cornerstone.25

Similarly, Green Power Institute (GPI) suggests the Commission take a 

similar approach here as in the Integrated Resource Plan process, where 

approval does not guarantee cost recovery, “although it can authorize specific 

procurements that are included in the plans.... As far as we can tell, no such 

authorizations were requested in the February 6, 2019, WMP filings.”26

TURN distinguishes the power procurement statute (Assembly Bill 

(AB) 5727) from SB 901:

 

24 TURN, at 2-3, quoting D.10-06-047 at 21 & 124.

25 TURN, at 5, quoting D.10-06-048, at 16.

26 GPI, at 2.

27 Stats. 2002, Ch. 835.

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Section 454.5(d) states that one objective of the AB 57 procurement 

plans is to “eliminate the need for after-the-fact reasonableness 

reviews” and replace it with a process to verify that contracts are 

administered in accord with the terms of the contract. In stark 

contrast with that language, Section 8386(g) reaffirms the role of rate 

cases and the just and reasonable requirement under Section 451 and 

451.1. 

TURN concludes, “Prudence requires not just completing a certain amount 

of work, but doing it right.”28 Energy Users and Producers Coalition (EPUC)

makes the same point: “the utilities’ approach tortures the ‘reasonable manager’ 

standard by assuming that completing work as targeted is per se reasonable 

regardless of the way in which the utility performed the work or circumstances 

that might have made performance unreasonable.”29

5.2. Discussion of What Approval Means Under 

SB 901

Approval of the WMP does not determine whether, at the time an IOU 

seeks recovery for the costs of carrying out its plan, the IOU complied with the 

prudent manager standard. Indeed, approval of a WMP here is not dispositive 

of an IOU’s ultimate cost recovery for the operations and maintenance costs of 

hardening its system, managing vegetation, increasing situational awareness and 

taking the other steps to mitigate wildfire risk.

There is a second set of costs at issue when catastrophic wildfires occur: 

liability costs attributable to claims against the electrical corporation for personal 

injury and property damage. Recovery of those costs is governed by Public 

Utilities Code Section 451 and 451.1, as well as case law. SB 901 modified the 

 

28 TURN, at 11.

29 EPUC, at 9.

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requirements for utility recovery of liability costs by adding Section 451.1, which 

explicitly governs “an application by an electrical corporation to recover costs 

and expenses arising from a catastrophic wildfire occurring on or after January 1, 

2019.”30 One of the factors relevant to recovery of such costs – which occur after 

a catastrophic wildfire – is “The electrical corporation’s compliance with 

regulations, laws, commission orders, and its wildfire mitigation plans prepared 

pursuant to Section 8386, including its history of compliance.”31 

However, this proceeding does not deal with those liability costs, or an 

electrical corporation’s eligibility to recover them. Instead, we are examining 

planned wildfire mitigation – that is, future activity to reduce the likelihood that 

utility infrastructure is the source of catastrophic wildfire ignition and to make 

utility infrastructure more resistant to wildfire. With that distinction in mind, we 

proceed to a discussion of what approval means for mitigation costs included in 

a WMP.

SB 901’s drafters separated WMP approval from cost recovery for the 

mitigation measures. The statute defers all consideration of cost to the GRC: 

The commission shall consider whether the cost of implementing 

each electrical corporation’s plan is just and reasonable in its GRC

application. Nothing in this section shall be interpreted as a 

restriction or limitation on Article 1 (commencing with Section 451) 

of Chapter 3 of Part 1 of Division 1. Pub. Util. Code § 8386(g). 

Section 451 requires a utility seeking to pass costs to ratepayers to prove 

such costs are reasonable:

All charges demanded or received by any public utility, or by any 

two or more public utilities, for any product or commodity 

 

30 Pub. Util. Code § 451.1(a).

31 Pub. Util. Code § 451.1(a)(9) (emphasis added).

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furnished or to be furnished or any service rendered or to be 

rendered shall be just and reasonable. Every unjust or unreasonable 

charge demanded or received for such product or commodity or 

service is unlawful.

Thus, the requirement that a utility demonstrate its costs are just and 

reasonable is not altered by SB 901, which leaves Section 451 untouched. Given 

the express language of Section 8386(g), the Commission should consider cost 

recovery related to WMPs in GRCs, not in this proceeding.

Another provision of SB 901 affirms that cost recovery is not assured upon 

WMP approval: Section 8386(j) directs the Commission, in a subsequent 

proceeding, to review costs in the fire risk mitigation memorandum account (one 

of two memorandum accounts discussed in SB 901 allowing an electrical 

corporation to track its mitigation costs) and disallow recovery of costs that are 

unreasonable.

Each electrical corporation shall establish a memorandum account to 

track costs incurred for fire risk mitigation that are not otherwise 

covered in the electrical corporation’s revenue requirements. The 

commission shall review the costs in the memorandum accounts and 

disallow recovery of those costs the commission deems 

unreasonable.

Under this provision, costs are not deemed reasonable until the 

Commission conducts a “review [of] the costs.” Section 8386(g) makes clear that 

this review must occur in a GRC, as noted above. The electrical corporations 

may establish this memorandum account without a Commission decision, but 

the Commission must later review and approve recovery of the amounts 

recorded. 

Similarly, the second memorandum account authorized in SB 901 for 

electrical corporations (the “Section 8386(e) memorandum account”) is simply a 

tracking mechanism, but this one requires Commission approval. Establishment 

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of the memorandum account has nothing to do with the later determination of 

whether the costs in the account are reasonable and therefore recoverable. 

Section 8386(e) provides for a memorandum account to “track costs”; it says 

nothing about cost recovery. 

(e) .... At the time it approves each plan, the commission shall authorize

the utility to establish a memorandum account to track costs incurred 

to implement the plan. (Emphasis added.)

We allow the establishment of the Section 8386(e) memorandum account 

in the accompanying decisions approving the electrical corporations’ WMPs. 

The IOUs’ incorrect position that “substantial compliance” ensures WMP 

cost recovery is based on the penalty provision in SB 901, which allows for 

Commission-imposed penalties if an IOU does not substantially comply with its 

Plan. Section 8386.1 sets forth the penalty provision:

The commission shall assess penalties on an electrical corporation 

that fails to substantially comply with its plan. In determining an 

appropriate amount of the penalty, the commission shall consider all 

of the following:

(a) The nature and severity of any noncompliance with the plan, 

including whether the noncompliance resulted in harm.

(b) The extent to which the commission has found that the electrical 

corporation complied with its plans in prior years.

(c) Whether the electrical corporation self-reported the 

circumstances constituting noncompliance.

(d) Whether the electrical corporation implemented corrective 

actions with respect to the noncompliance.

(e) Whether the electrical corporation knew or in the exercise of 

reasonable care should have known of the circumstances 

constituting noncompliance.

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(f) Whether the electrical corporation had previously engaged in 

conduct of a similar nature that caused significant property damage 

or injury.

(g) Any other factors established by the commission in a rulemaking 

proceeding, consistent with this section.

This provision has nothing to do with cost recovery for the costs of 

implementing a WMP. Ratemaking and the imposition of penalties are two 

separate exercises; one allows a utility to pass costs to ratepayers if it acts 

reasonably, while the other allows the Commission to impose penalties on a 

utility for misconduct. Thus, the “substantial compliance” provision in SB 901 is 

relevant to whether penalties are proper, not whether rate recovery is 

appropriate. If in the future there are proceedings to consider whether penalties 

are appropriate, we will examine what is meant by “substantial compliance” 

under the statute.

SCE’s citation to an early ruling in the case seeking high-level cost 

information is not relevant. The ruling asked for “Cost estimates for each item in 

the WMP in order for the Commission to weigh the potential cost implications of 

measures proposed in the plans,” but also cited the Order Instituting 

Rulemaking’s statement on cost: “The Commission will not consider or approve 

explicit expenditures in wildfire mitigation plans in this proceeding; however, in 

evaluating the proposed plans the Commission may weigh the potential cost 

implications of measures proposed in the plans.”32 The ruling sought cost 

information so the Commission could understand the magnitude of certain 

mitigation elements, but made clear that it would neither “consider” nor 

“approve” those costs here. 

 

32 See OIR 18-10-007, at 4 (emphasis added).

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The question remains: what does WMP approval mean? Here again the 

statute provides the answer: approval means that every WMP contains 19 

elements that the SB 901 Legislature deemed essential to catastrophic wildfire 

mitigation. Those elements are aimed at ensuring an electrical corporation has 

plans in place to protect the public from catastrophic wildfire. Without SB 901, 

existing wildfire-prevention and other safety requirements might not include all 

of the elements on the list.

6. Metrics, Monitoring and Reporting Required of All 

WMP Filers

This section discusses the metrics, monitoring and reporting requirements 

the Commission will require all Wildfire Mitigation Plan filers to follow, and will 

develop in Phase 2 of this proceeding. Individual requirements addressing 

specific deficiencies in individual Plans appear in the Plan-specific decisions. 

Metrics that track the number of elevated fire danger days, whether based 

on Red Flag Warnings issued by the National Weather Service, utility-provided 

"Fire Potential Index" ratings, or National Fire Danger Rating System (NFDRS)

data, and the number and types of potential ignition events (wires down, blown 

fuses, vegetation contact, and similar events) that occur on those days are 

imperative for providing the type of insight needed to better understand and 

properly analyze the risk of catastrophic fires caused by electrical lines and 

equipment.

Some of the WMPs provide this type of useful metrics:

 Wire Down Events Within High Fire-Threat District (HFTD)

Areas33

 

33 PG&E WMP, at 134.

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o The number of wires down events within HFTD areas, when 

the FPI is rated as very-high or higher;

 Equipment Caused Ignitions in HFTD Areas34;

 Vegetation Caused Outages in HFTD Areas35;

o The number of vegetation caused outages within HFTD areas, 

when the Fire Potential Index (FPI) is rated as very-high or 

higher;

 Vegetation Caused Ignitions in HFTD Areas36;

 Faults on Circuits in HFTD37;

o Counts of all faults on HFTD circuits associated with contact 

from object or equipment failures;

 Number of Conventional Blown Fuse Events38;

 Number of NFDRS “Very Dry” and “Dry” Days

The Commission's Safety and Enforcement Division (SED) will, through 

one or more workshops, work with all stakeholders, including the WMP filers, 

to develop a common template for capturing metrics of this type. These 

workshops should result in a list of metrics that provides the Commission, the 

Department of Forestry and Fire Protection (CAL FIRE), related agencies and 

researchers tools to evaluate the effectiveness of the WMPs at mitigating 

catastrophic wildfires. This is the statutory mandate, not simply program targets 

that measure how many actions an electrical corporation takes in the areas a Plan 

 

34 Id.

35 Id. at 136.

36 Id.

37 SCE WMP, at 93 (using SCE’s own "High Fire Risk Areas," on which we discuss concerns in 

the decision on SCE's WMP).

38 BVES WMP at 53.

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lists (e.g., how many trees it cuts down). To avoid confusion, these program 

targets should not be described as “metrics” in the future.

SED will kick off this workshop process later this year. Other topics may 

also be considered during the workshop(s), and those topics, along with 

scheduling and other logistics will be spelled out in future rulings.

7. Evaluation of Current Inspection Plans

One aspect of SB 901 merits a special mention. Public Utilities Code 

Section 8386(c)(19)(C) requires electrical corporations to "Monitor and audit the 

effectiveness of electrical line and equipment inspections, including inspections 

performed by contractors, carried out under the plan and other applicable 

statutes and commission rules." Because many of the existing inspection 

practices include simple drive-by patrols or are limited to visual observation, 

they may not be effective in detecting anything but the most egregious problems 

with overhead utility poles, lines and other equipment. The WMPs filed do little 

to address this issue. 

In order to comply with Section 8386(c)(19)(C), future WMPs must include 

a discussion of how the utility evaluates the effectiveness of routine inspection 

programs developed in accordance with existing regulations such as the 

Commission's infrastructure inspection requirements in GO 165.39 At a 

minimum, the discussion should detail what the inspection is looking for, the 

 

39 Both PG&E and SCE plan “enhanced” inspections in their WMPs, asserting the new 

inspections will exceed General Order (GO) requirements. However, with respect to the 

minimum inspection frequencies provided by GO 165, GO 95, Rule 31.2 states, “Lines shall be 

inspected frequently and thoroughly for the purpose of ensuring they are in good condition so 

as to conform with these rules....” As such, it is not necessarily beyond GO 95 requirements to 

conduct inspections more frequently or thoroughly than specified in GO 165, as those are 

minimum requirements.

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number of each type of inspection conducted, the cost of each type of inspection, 

and a listing of the top five violations or hazards identified by each inspection 

program, including its location and GO 95, Rule 18 priority level rating.

8. Integration of GRC Process with WMP Review

The WMP statute refers to the Commission’s safety-oriented processes 

carried out during GRCs.

40 We interpret the inclusion of those processes to 

reflect a desire to ensure the safety work in GRCs is incorporated into WMPs. 

We agree that both processes are important to a consideration of the adequacy of 

utility safety efforts.

Our recent decision in the S-MAP/GRC context adopted an approach that 

prioritizes actions based on their “Risk-Spend Efficiency.” The approach uses a 

tool called Multi-Attribute Value Function (MAVF)41 that provides a single value 

to measure the combined effects of each mitigation measure on a certain risk 

event. The process involves performing risk assessments and ranking risks using 

safety, reliability, and other attributes. This approach provides a means to 

compare the programs against each other for effectiveness, especially when 

multiple overlapping programs are proposed for the same assets and intended to 

mitigate the same risk event (i.e., increased vegetation clearing coupled with 

installing covered conductor and expanded de-energization practices). 

 

40 SB 901 requires a ranking of “all wildfire risks, and drivers for those risks,” throughout the 

filer’s service territory, which shall include wildfire risk and risk mitigation information 

contained in the utility’s S-MAP and RAMP filings, Commission-mandated programs to compel 

risk-based utility management and spending), Pub. Util. Code § 8386(c)(10).

41 D.18-12-014 (adopting a settlement agreement updating the S-MAP procedure).

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Including such analysis in the WMPs42 would provide the Commission a 

transparent and effective way to balance overlapping programs in the WMP and 

assess which programs are needed and effective. As stated above, the statute 

requires “all relevant wildfire risk and risk mitigation information that is part of 

the Safety Model Assessment Proceeding and Risk Assessment Mitigation Phase 

filings.” This quantitative information is relevant, and the process of conducting 

these analyses may allow stakeholders to better understand the cost effectiveness 

of proposed mitigations.43

Future large IOU WMP filings must provide the elements necessary to 

evaluate mitigation programs and strategies using a singular value to measure 

the combined effects of various mitigation measures, as now required in S-MAP 

and facilitated through MAVF.

9. Off Ramps

It is essential that there be a process for modifying, reducing, increasing, or 

ending mitigation measures that are not working, or otherwise require 

modification. Therefore, all electrical corporations named as respondents shall 

file via a Tier 3 Advice Letter “Reports on Possible Off Ramps” describing any 

concerns about the effectiveness of any program in the WMP. The first Advice 

Letter shall be filed no later than 6 months from the effective date of this decision 

 

42 Most of the IOU WMPs justify inspection and hardening program proposals as being 

informed by an internal risk assessment. However, that risk assessment is often a black box

with insufficient description of the supporting information and rationale for proposed 

programs. Future filings should provide documentation of the risk analysis used to justify the 

proposals. A “trust us, we know what we are doing” approach to risk assessment is not 

appropriate given recent wildfire activity. 

43 Other advantages of MAVF are listed in D.18-12-014 at 44.

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and the second one no later than 12 months after the effective date of this 

decision.

The reports shall clearly describe the concern, contain a specific proposal 

for action, including if applicable a recommendation to modify, reduce, increase,

or end the specific mitigation identified, and include any expert or other 

authoritative information available on the efficacy of the mitigation.

10. Future WMPs

10.1. Party Comments – Future WMPs

Many parties commented on items IOU respondents should include in 

their 2020 WMPs, and asked for a process in the future that gives all stakeholders 

more time to review the Plans. The workshop(s) we will conduct in Phase 2 of 

this proceeding should help address many of these concerns.

MGRA recommends that parties have more time to review Plans in future

wildfire proceedings, with an open discovery period of about two months prior 

to the utilities’ WMP filing. The CFBF recommends that the Commission stagger 

IOU WMP filings in the future and extend the deadline for Plan approvals, as the 

statute allows. The Commission’s Public Advocates Office (Cal Advocates)

recommends a “Notice of Intent” process to allow parties an opportunity to 

identify shortcoming of the utilities’ WMP before they formally file their plans. 

SBUA suggests that utilities file their future WMPs through an application 

process in a consolidated proceeding so that future proceedings will allow for 

intervenor testimony and evidentiary hearings.

SCE disagrees with the above suggestions. SCE states that adjusting 

and/or extending the WMP filing schedule or decision date timeline would add 

unnecessary uncertainty regarding the approval of the utilities’ proposed 

mitigation efforts, and would potentially delay the implementation of critical 

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wildfire mitigation work. SCE also maintains that evidentiary hearings are not 

necessary to develop a sufficient record, and that hearings are counterproductive 

and hinder the timely approval of the utilities’ annual plans. SCE recommends 

maintaining the existing February WMP filing and 90-day review/decision 

period in future WMP proceedings.

TURN recommends that the Commission set a second phase in this 

proceeding to receive concurrent opening and reply comments on 

recommendations for future WMPs. In addition, TURN recommends that the 

future wildfire mitigation plans should 1) be more focused on preventing 

catastrophic wildfires, not simply ignitions, 2) provide more analysis concerning 

the effectiveness of past and current investments and operational strategies, 

3) quantify the incremental risk reductions that any new proposed program 

provides, and 4) include a discussion about how the plans comply with all 

applicable rules, regulations and standards. 

In response, SCE explains that the factors affecting catastrophic wildfire, 

such as wind speeds and relative humidity, are beyond SCE’s reasonable control. 

Thus, SCE’s WMP focuses on factors that SCE can reasonably control, of which 

the predominant factor is the number of ignitions caused by utility 

infrastructure. SCE explains that its RAMP proceeding conducted a “baseline 

risk analysis” and a “mitigation effectiveness analysis,” and both analyses 

support SCE’s WMP incremental activities. SCE is working to advance its risk 

analysis capabilities to better understand wildfire risks and the effectiveness of 

an individual risk mitigation.

Cal Advocates also recommends that future utilities wildfire plans should 

1) list the evidence and metrics that will demonstrate compliance of each 

proposed activity/program, and 2) include detailed cost information concerning 

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the specifics of a program, with a more narrow cost estimate range than 

proposed in this proceeding, and provide high-level revenue requirement 

impacts for the subsequent five years following the plan. 

SCE explains that it currently lists the evidence and the goals and metrics 

to demonstrate compliance for each activity. SCE also suggests that 

Cal Advocates address concerns for cost reasonableness in proceedings where 

the utilities are seeking cost recovery. 

OSA recommends that, in the future, utilities establish a framework for 

managing wildfire risk based on best safety management practices of similarly 

complex industries. As an example, OSA cites to the Plan-Do-Check-Act model, 

a safety management framework developed for the natural gas pipelines. At a 

minimum, OSA proposes that the utilities develop and incorporate quality 

assurance programs, management of change controls, incident investigation and 

root cause analyses in their next set of wildfire mitigation plans. SCE agrees with 

OSA that future WMPs should include quality assurance programs, management 

of change controls, incident investigation and root cause analyses.

CLECA proposes that a common lexicon of standard terms be developed 

in a subsequent phase of this proceeding, so that the next round of wildfire 

mitigation plans can use this common lexicon. 

POC recommends that future WMPs provide analyses on the effectiveness 

of mitigation per dollar spent. SCE agrees that cost-efficiency of risk mitigating 

strategies should be a contributing factor in the selection of wildfire mitigations, 

but notes that cost-efficiency should not be the only factor for consideration. SCE 

explains that the utilities also consider other factors, such as funding, labor 

resources, and technology when selecting mitigation plans.

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CEJA recommends that future WMPs 1) consider more effective outreach 

efforts to the community, particularly for the more vulnerable populations, 

2) focus on increasing the resiliency of affected communities, and 3) explore how 

to effectively harden the system against catastrophic wildfires. SCE feels that its 

current WMP already addresses CEJA’s concerns. 

PG&E agrees in reply comments with the recommendation of several 

parties to include improvements in future plans, stating that its WMP 

contemplates “continuous improvement.” PG&E agrees with CLECA that the 

decision on this year’s WMPs should include a timeline for the next WMP 

proceeding. PG&E states that it does not oppose the future steps suggested by 

several parties including OSA, Cal Advocates, and MGRA, but recommends that 

the Commission convene a pre-hearing conference after acting on this year’s 

WMPs to determine next steps before the filing of the 2020 plans.

10.2. Discussion – Future WMPs

We agree with the parties that assessment of risk is essential to 

determining where to conduct wildfire mitigation, and that the WMPs filed this 

year do not always show that electrical corporations are targeting the area of 

greatest risk. We therefore believe steps are necessary to ensure that risk is given 

adequate consideration in next year’s WMP filings. 

A proper risk analysis takes into account where and when the risk of 

wildfire is greatest. There are two primary components that determine fire 

spread potential: (1) the native fuel system and topography where the ignition 

occurs, and (2) the climatological conditions (i.e., temperature, relative humidity, 

wind speed/direction) present when the ignition occurs. 

As shown by the IOU ignition data reported to the Commission for 

2014-2018, most utility-caused ignitions result in very small fires. The critical 

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factors in differentiating between ignitions likely to be contained to a small area 

and catastrophic wildfires (that is, fire spread potential) are where an ignition 

occurs and when the ignition occurs. Certain parts of the state are more 

susceptible to rapid fire growth than others due to factors in the area: typical 

climate and wind conditions, fuel systems, and topography. These factors, along 

with proximity to people and property, formed the basis for the development of 

the CPUC Fire-Threat Map and subsequent HFTD and its elevated (Tier 2) and 

extreme (Tier 3) risk zones. 

Mitigating ignitions that occur in the HFTD should be prioritized, as these 

represent areas where an ignition could be problematic, given the simultaneous 

existence of climatological conditions consistent with high rates of fire spread. 

Consideration could be given to differentiating between the risk of ignitions in 

different HFTD Tiers. 

The HFTD can be used as a straightforward, universal measure to identify 

areas susceptible to catastrophic wildfire promulgation. However, the HFTD 

covers over 44% of the land area in the state. As such, the HFTD, in and of itself, 

may be of insufficient granularity to appropriately prioritize the highest risk 

areas for targeting of certain mitigation efforts. Some utilities have recognized 

this shortcoming and have internally employed more refined categorization and 

delineation of HFTD areas. For example, PG&E uses 91 Fire Index Areas that 

span the HFTD; Bear Valley Electric Service has prioritized “high-risk areas” (a 

subset of its HFTD area) where it focuses much of its wildfire mitigation efforts. 

When an ignition occurs (i.e., under what conditions) is just as important 

as where an ignition occurs. Even if an ignition occurs in a Tier 3 HFTD, that 

does not mean that there will automatically be a large, catastrophic wildfire. 

Hypothetically, if an equipment failure takes place, creating a potential ignition 

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source during a wet winter storm, the likelihood of a wildfire occurring is 

negligible. If the same failure takes place on a day with high temperatures, low 

relative humidity, during high wind conditions, and in the presence of a 

receptive fuel bed, the probability of a catastrophic wildfire increases

tremendously. 

As with using the HFTD map to identify locations where ignitions should 

be avoided, there are tools that can inform conditions during which ignitions 

should be avoided because they are more likely to result in a large catastrophic 

fire. As a starting point, Red Flag Warnings (RFWs), issued by the National 

Weather Service, are intended to capture weather and climate conditions 

commensurate with high fire danger. However, RFWs are not very effective 

from an operational perspective because they are being issued more frequently 

and can span coverage of multiple counties, thus lacking the granularity needed 

to effectively target mitigation efforts. 

Alternatively, all the large IOUs are all developing or have developed their 

own FPI, which is a more granular fire danger rating tool than RFW. IOUs are 

already using FPIs to inform “Operating Conditions” that trigger certain work 

restrictions, special operating protocols (e.g., disabling reclosers), and inspection 

and maintenance activities. Still, there are issues and limitations that make using 

FPIs problematic. FPIs are developed in-house by IOUs and there is no 

independent scientific verification of the approaches used. FPIs do not have 

consistent rating systems (i.e., number of rating categories, nomenclature, and the 

like). The workshop(s) SED runs later this year may address FPI consistency.

We expect the reporting, workshop(s), and process requirements we 

discuss below and order in these decision to factor in the foregoing analysis, and 

focus on demonstrating that the WMPs actually target areas of greatest risk.

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The Commission is aware that the expedited nature of the WMP approval 

process has caused many parties concern. We have learned a great deal about 

improvements that can be made in future plans. To that end, we order all 

respondent electrical corporations in this proceeding to file and serve reports and 

conduct other follow up, and anticipate workshop(s), facilitated by SED, later 

this year. 

Our aim is for next year’s WMP process to start this year. The reporting 

requirements and recommendations for 2020 involve devising better metrics to 

measure mitigation effectiveness; creating databases and data sets for future 

analysis; and working with experts in the field, including those who were 

involved in the Wildfire Technology Innovation Summit sponsored by the 

Commission and several other agencies on March 20-21, 2019. 

The reporting and other follow-up actions we require of all electrical 

corporations subject to our jurisdiction (in addition to any individual reporting 

identified in individual WMP decisions and the “Report on Possible Off Ramps” 

discussed in the previous section) shall be the following:

1. All electrical corporation respondents should, by July 30, 2019, 

file and serve on the service list for this proceeding a report 

entitled “Data Collection for Wildfire Mitigation Plans” that: 

a) includes a “Data and Map Product Catalogue” that lists, 

identifies, and describes all datasets and map productions the 

electrical corporation possesses, collects and maintains that 

could be useful in assessing the effectiveness of its Wildfire 

Mitigation Plan (WMP) in reducing catastrophic wildfire risk; 

b) provides a “Data Dictionary” detailing the data tables, 

attribute column headers, sample attributes, alias, description, 

and metadata about the datasets and map products identified in 

(a); c) proposes metrics to assess whether the Wildfire Mitigation 

Plans are having or will have the desired result ( i.e. – a reduction 

in the risk of catastrophic wildfire); d) suggests new areas of data 

collection that could assist in assessing WMP effectiveness and 

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align utility data collection efforts; e) proposes a schedule for 

collecting and using the data for future wildfire mitigation 

efforts; and f) proposes a manner of making the data available to 

third party researchers for the purposes of improving wildfire 

mitigation. Before making this filing, the electrical corporations 

should consult experts in data analysis, including, if relevant, 

presenters at the Wildfire Technology Innovation Summit, to 

ensure they gather the data in a manner that allows assessment, 

including using common data gathering methods across all 

respondent electrical corporations. The filing shall include the 

results of this consultation. Parties may comment on the filing on 

August 21, 2019. The workshop(s) discussed elsewhere in this 

decision will consider this material along with other matters. 

Parties will have an opportunity to propose topics for 

workshop(s).

2. Further, later this year, SED will convene one or a series of 

workshops for the purpose of kicking off next year’s WMPs. The 

workshops should include discussion of: a) proper metrics; b)the 

timing of WMP filing, including whether to stagger large IOU 

filings and those of the small and multijurisdictional utilities; 

c) discovery and data exchange in 2019 that will assist 

stakeholders in assessing and commenting on the WMPs; and 

d) other process improvements to reduce the time constraints 

faced during this proceeding to date, and other related issues. 

11. Consultation with CAL FIRE Has Occurred

SB 901 requires that the Commission and CAL FIRE consult on the review 

of each wildfire mitigation plan (Pub. Util. Code § 8386(b)) and that the two 

agencies have a memorandum of understanding in place to facilitate this 

consultation (Pub. Util. Code § 8386.5).44 The Commission has met these 

 

44 Section 8386.5 provides: “The commission and the Department of Forestry and Fire 

Protection shall enter into a memorandum of understanding to cooperatively develop 

consistent approaches and share data related to fire prevention, safety, vegetation management, 

and energy distribution systems. The commission and the department shall share results from 

various fire prevention activities, including relevant inspections and fire ignition data.”

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requirements, but neither this decision nor the decisions on the individual WMPs 

purport to speak for CAL FIRE.

12. Conclusion

The WMP decisions the Commission issues in this proceeding are but one 

action the state and its regulated electrical corporations will take to mitigate the 

risk of catastrophic wildfire. This will be an annual process, and we expect 

continuous improvement as our actions here are an important element of the 

collective state efforts to mitigate risks of catastrophic wildfires. As such, the 

annual WMP process will be iterative, and will require reporting, monitoring, 

evaluation and updating to ensure the electrical corporations are targeting the 

greatest risk with effective programs. 

Pursuant to SB 901, the costs of the actions in the WMP will be the subject 

of review at a later time, in the context of individual GRCs. Thus, nothing in this 

decision should be interpreted as a determination that those costs are reasonable 

or that any respondent has acted as a prudent manager. Any provision in a 

WMP that represents that approval of the Plan constitutes a determination on 

cost, reasonableness, or prudency is disapproved.

13. Comments on Proposed Decision

The proposed decision of ALJs Thomas and Allen in this matter was 

mailed to the parties in accordance with Section 311 of the Public Utilities Code 

and comments were allowed under Rule 14.3 of the Commission’s Rules of 

Practice and Procedure. In accordance with the May 7, 2019 ALJ ruling, parties 

filed separate comments on the guidance proposed decision and one set of 

comments regarding the proposed decisions on electrical corporations’ 

individual WMPs. The following parties filed comments addressing the guidance 

proposed decision: on May 15, 2019, Rural County Representatives of California

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and on May 16, 2019, California Environmental Justice Alliance. On May 20, 

2019, the following filed comments: Bear Valley Electric Service, California Farm 

Bureau Federation, California Large Energy Consumers Association, City of 

Malibu, Energy Producers and Users Coalition, Green Power Institute, Ruth 

Henricks, Mussey Grade Road Alliance, Pacific Gas and Electric Company, 

PacifiCorp, Protect Our Communities Foundation, Public Advocates Office, 

San Diego Gas & Electric Company, Small Business Utility Advocates, 

Southern California Edison Company, and The Utility Reform Network. 

Reply comments were filed on May 28, 2019 by California Environmental 

Justice Alliance, California Large Energy Consumers Association, City of 

Malibu, City and County of San Francisco, Ruth Henricks, Mussey Grade Road 

Alliance, Pacific Gas and Electric Company, PacifiCorp, Protect Our 

Communities Foundation, Public Advocates Office, San Diego Gas & Electric 

Company, Small Business Utility Advocates, Southern California Edison 

Company, and The Utility Reform Network. We have made changes throughout 

this decision addressing party comments.

14. Assignment of Proceeding

Michael Picker is the assigned Commissioner and Sarah R. Thomas and 

Peter V. Allen are the assigned ALJs for this proceeding.

Finding of Fact

The “metrics” the respondent electrical corporations propose focus on

activities or inputs such as the numbers of trees cut down or miles of covered 

conductors installed.

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Conclusions of Law

1. Senate Bill 901 (SB 901) does not provide for the Commission to approve 

cost recovery for the costs of a Wildfire Mitigation Plan (WMP) or the programs 

the WMP proposes in the Commission’s decision approving the WMP.

2. SB 901 provides for cost recovery related to the WMP in a General Rate 

Case.

3. SB 901 does not provide that Commission approval of a WMP is 

dispositive of whether the WMP filer acted reasonably and prudently when the 

filer seeks recovery of WMP-related costs.

4. SB 901 requires WMPs to contain metrics that allow the Commission, 

CAL FIRE and other stakeholders to assess whether the WMPs will reduce the 

risk and impact of catastrophic wildfires. Many of the activities the electrical 

corporations label as “metrics” are program targets.

5. The Commission should require additional reporting and activity to assist 

with the WMP process next year, and to help evaluate the effectiveness of the 

mitigation measures in this year’s WMPs.

ORDER

IT IS ORDERED that:

1. All electrical corporations named as respondents shall file two Tier 3

Advice Letters entitled “Reports on Possible Off Ramps,” describing any 

concerns about the effectiveness of any program in their individual Wildfire 

Mitigation Plans. The first Advice Letter shall be filed and served on the service 

list for this proceeding no later than 6 months from the effective date of this 

decision and the second Advice Letter shall be filed and served no later than 

12 months after the effective date of this decision. Each report shall clearly 

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describe the concern, contain a specific proposal for action, including if 

applicable a recommendation to reduce or end the specific mitigation identified, 

and include any expert or other authoritative information available on the 

efficacy of the mitigation. 

2. All electrical corporation respondents shall, by July 30, 2019, file and serve 

on the service list for this proceeding a report entitled “Data Collection for 

Wildfire Mitigation Plans” that: a) includes a “Data and Map Product 

Catalogue” that lists, identifies, and describes all datasets and map productions

the electrical corporation possesses, collects and maintains that could be useful 

in assessing the effectiveness of its Wildfire Mitigation Plan (WMP) in reducing 

catastrophic wildfire risk; b) provides a “Data Dictionary” detailing the data 

tables, attribute column headers, sample attributes, alias, description, and 

metadata about the datasets and map products identified in (a); c) proposes 

metrics to assess whether the Wildfire Mitigation Plans are having or will have 

the desired result ( i.e. – a reduction in the risk of catastrophic wildfire); d)

suggests new areas of data collection that could assist in assessing WMP 

effectiveness and align utility data collection efforts; e) proposes a schedule for 

collecting and using the data for future wildfire mitigation efforts; and f) 

proposes a manner of making the data available to third party researchers for the 

purposes of improving wildfire mitigation. Before making this filing, the 

electrical corporations shall consult experts in data analysis, including, if 

relevant, presenters at the Wildfire Technology Innovation Summit 

co-sponsored by this Commission on March 20-21, 2019, to ensure they gather 

the data in a manner that allows assessment, including using common data 

gathering methods across all respondent electrical corporations. The filing shall 

include the results of this consultation. Parties may comment on the filing on 

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August 21, 2019. The workshop(s) discussed elsewhere in this decision will 

consider this material along with other matters. Parties will have an 

opportunity to propose topics for workshop(s).

3. Later this year, the Commission’s Safety and Enforcement Division is 

authorized to convene one or more workshops with the parties to this 

proceeding and other interested stakeholders for the purpose of initiating the 

2020 Wildfire Mitigation Plan (WMP) process. The workshop(s) will include 

discussion of: a) proper metrics; b) the timing of WMP filing, including whether 

to stagger large investor owned utility filings and those of the small and 

multijurisdictional utilities; c) discovery and data exchange in 2019 that will 

assist stakeholders in assessing and commenting on the WMPs; and d) other 

process improvements to reduce the time constraints faced during this 

proceeding to date, and other relevant matters. Additional details and other 

related issues about the workshop(s) will be provided by future ruling in this 

proceeding.

4. As part of the workshop(s), the Commission's Safety and Enforcement 

Division shall work with all stakeholders, including the Wildfire Mitigation Plan 

(WMP) filers, to develop a common template for capturing metrics. This process 

shall result in a list of metrics that provides the Commission, the Department of 

Forestry and Fire Protection, related agencies and researchers tools to evaluate 

the effectiveness of the WMPs at mitigating catastrophic wildfires. 

5. In order to comply with Public Utilities Code Section 8386(c)(19)(C), future 

Wildfire Mitigation Plans must include a discussion of how the utility evaluates 

the effectiveness of routine inspection programs developed in accordance with 

existing regulations such as the Commission's infrastructure inspection 

requirements in General Order (GO) 165. At a minimum, the discussion shall 

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detail the purpose of each inspection, the number of each type of inspection 

conducted, the cost of each type of inspection, and a listing of the top five 

violations or hazards identified by each inspection program, including its 

location and GO 95, Rule 18 priority level rating.

6. Nothing in this decision changes the notice, communication, outreach or 

other requirements of the Commission’s concurrent de-energization decision 

issued in Rulemaking 18-12-005. 

7. This decision ratifies all rulings issued in this proceeding.

8. This decision does not act on the second amended Wildfire Mitigation Plan 

distributed by Pacific Gas and Electric Company on April 25, 2019. Phase 2 of 

this proceeding will consider the matter and filings related to the second 

amended Wildfire Mitigation Plan.

9. This decision resolves all issues required by Senate Bill 901, Public Utilities 

Code Section 8386(c) for 2019, except as otherwise provided in this decision.

10. This proceeding remains open.

This order is effective today.

Dated May 30, 2019, at San Francisco, California. 

MICHAEL PICKER

 President

LIANE M. RANDOLPH

MARTHA GUZMAN ACEVES

CLIFFORD RECHTSCHAFFEN

GENEVIEVE SHIROMA

 Commissioners

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Appendix A

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Appendix A - List of Requirements in SB 901 for WMPs

8386.

(c) The wildfire mitigation plan shall include:

(1) An accounting of the responsibilities of persons responsible for 

executing the plan.

(2) The objectives of the plan.

(3) A description of the preventive strategies and programs to be adopted 

by the electrical corporation to minimize the risk of its electrical lines and 

equipment causing catastrophic wildfires, including consideration of dynamic 

climate change risks.

(4) A description of the metrics the electrical corporation plans to use to 

evaluate the plan’s performance and the assumptions that underlie the use of 

those metrics.

(5) A discussion of how the application of previously identified metrics to 

previous plan performances has informed the plan.

(6) Protocols for disabling reclosers and deenergizing portions of the 

electrical distribution system that consider the associated impacts on public 

safety, as well as protocols related to mitigating the public safety impacts of 

those protocols, including impacts on critical first responders and on health and 

communication infrastructure.

(7) Appropriate and feasible procedures for notifying a customer who may 

be impacted by the deenergizing of electrical lines. The procedures shall 

consider th need the notify, as a priority, critical first responders, health care 

facilities, and operators of telecommunications infrastructure.

(8) Plans for vegetation management.

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(9) Plans for inspections of the electrical corporation’s electrical 

infrastructure.

(10) A list that identifies, describes, and prioritizes all wildfire risks, and 

drivers for those risks, throughout the electrical corporation’s service territory, 

including all relevant wildfire risk and risk mitigation information that is part of 

Safety Model Assessment Proceeding and Risk Assessment Mitigation Phase 

filings. The list shall include, but not be limited to, both of the following:

(A) Risks and risk drivers associated with design, construction, operations, 

and maintenance of the electrical corporation’s equipment and facilities.

(B) Particular risks and risk drivers associated with topographic and 

climatological risk factors throughout the different parts of the electrical 

corporation’s service territory.

(11) A description of how the plan accounts for the wildfire risk identified 

in the electrical corporation’s Risk Assessment Mitigation Phase filing.

(12) A description of the actions the electrical corporation will take to 

ensure its system will achieve the highest level of safety, reliability, and 

resiliency, and to ensure that its system is prepared for a major event, including 

hardening and modernizing its infrastructure with improved engineering, 

system design, standards, equipment, and facilities, such as undergrounding, 

insulation of distribution wires, and pole replacement.

(13) A showing that the utility has an adequate sized and trained 

workforce to promptly restore service after a major event, taking into account 

employees of other utilities pursuant to mutual aid agreements and employees of 

entities that have entered into contracts with the utility.

(14) Identification of any geographic area in the electrical corporation’s 

service territory that is a higher wildfire threat than is currently identified in a 

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commission fire threat map, and where the commission should consider 

expanding the high fire threat district based on new information or changes in 

the environment.

(15) A methodology for identifying and presenting enterprise-wide safety 

risk and wildfire-related risk that is consistent with the methodology used by 

other electrical corporations unless the commission determines otherwise.

(16) A description of how the plan is consistent with the electrical 

corporation’s disaster and emergency preparedness plan prepared pursuant to 

Section 768.6, including both of the following:

(A) Plans to prepare for, and to restore service after, a wildfire, including 

workforce mobilization and prepositioning equipment and employees.

(B) Plans for community outreach and public awareness before, during, 

and after a wildfire, including language notification in English, Spanish, and the 

top three primary languages used in the state other than English or Spanish, as 

determined by the commission based on the United States Census data.

(17) A statement of how the electrical corporation will restore service after 

a wildfire.

(18) Protocols for compliance with requirements adopted by the 

commission regarding activities to support customers during and after a 

wildfire, outage reporting, support for low-income customers, billing 

adjustments, deposit waivers, extended payment plans, suspension of 

disconnection and nonpayment fees, repair processing and timing, access to 

utility representatives, and emergency communications.

(19) A description of the processes and procedures the electrical 

corporation will use to do all of the following:

(A) Monitor and audit the implementation of the plan.

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(B) Identify any deficiencies in the plan or the plan’s implementation and 

correct those deficiencies.

(C) Monitor and audit the effectiveness of electrical line and equipment 

inspections, including inspections performed by contractors, carried out under 

the plan and other applicable statutes and commission rules.

(20) Any other information that the commission may require.

(End of Appendix A)

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Appendix B

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Appendix B – Cross Reference SB 901-Wildfire Mitigation Plans

CROSS REFERENCE TABLE 1

Using SB 901 Organization

Code Reference §8386(c)

Wildfire 

Mitigation 

Plan 

section

(1) An accounting of the responsibilities of persons responsible for executing the 

plan. VI.A.

(2) The objectives of the plan. I.

(3) A description of the preventive strategies and programs to be adopted by the 

electrical corporation to minimize the risk of its electrical lines and equipment causing 

catastrophic wildfires, including consideration of dynamic climate change risks.

II.

(4) A description of the metrics the electrical corporation plans to use to evaluate the 

plan’s performance and the assumptions that underlie the use of those metrics. VI.B.

(5) A discussion of how the application of previously identified metrics to previous 

plan performances has informed the plan. VI.C.

(6) Protocols for disabling reclosers and deenergizing portions of the electrical 

distribution system that consider the associated impacts on public safety, as well as 

protocols related to mitigating the public safety impacts of those protocols, including 

impacts on critical first responders and on health and communication infrastructure.

IV.A.

(7) Appropriate and feasible procedures for notifying a customer who may be 

impacted by the deenergizing of electrical lines. The procedures shall consider th 

need the notify, as a priority, critical first responders, health care facilities, and 

operators of telecommunications infrastructure.

IV.F.

(8) Plans for vegetation management. IV.D.

(9) Plans for inspections of the electrical corporation’s electrical infrastructure. IV.B.

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Code Reference §8386(c)

Wildfire 

Mitigation 

Plan 

section

(10) A list that identifies, describes, and prioritizes all wildfire risks, and drivers for 

those risks, throughout the electrical corporation’s service territory, including all 

relevant wildfire risk and risk mitigation information that is part of Safety Model 

Assessment Proceeding and Risk Assessment Mitigation Phase filings. The list shall 

include, but not be limited to, both of the following:

(A) Risks and risk drivers associated with design, construction, operations, and 

maintenance of the electrical corporation’s equipment and facilities.

(B) Particular risks and risk drivers associated with topographic and climatological 

risk factors throughout the different parts of the electrical corporation’s service 

territory.

III.B.(1-5)

(11) A description of how the plan accounts for the wildfire risk identified in the 

electrical corporation’s Risk Assessment Mitigation Phase filing. III.B.6.

(12) A description of the actions the electrical corporation will take to ensure its 

system will achieve the highest level of safety, reliability, and resiliency, and to 

ensure that its system is prepared for a major event, including hardening and 

modernizing its infrastructure with improved engineering, system design, standards, 

equipment, and facilities, such as undergrounding, insulation of distribution wires, and 

pole replacement.

IV.

(whole 

section)

(13) A showing that the utility has an adequate sized and trained workforce to 

promptly restore service after a major event, taking into account employees of other 

utilities pursuant to mutual aid agreements and employees of entities that have 

entered into contracts with the utility.

V.B.3.

(14) Identification of any geographic area in the electrical corporation’s service 

territory that is a higher wildfire threat than is currently identified in a commission fire 

threat map, and where the commission should consider expanding the high fire threat 

district based on new information or changes in the environment.

III.D.

(15) A methodology for identifying and presenting enterprise-wide safety risk and 

wildfire-related risk that is consistent with the methodology used by other electrical 

corporations unless the commission determines otherwise.

III.A.

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Code Reference §8386(c)

Wildfire 

Mitigation 

Plan 

section

(16) A description of how the plan is consistent with the electrical corporation’s 

disaster and emergency preparedness plan prepared pursuant to Section 768.6, 

including both of the following:

(A) Plans to prepare for, and to restore service after, a wildfire, including workforce 

mobilization and prepositioning equipment and employees.

(B) Plans for community outreach and public awareness before, during, and after a 

wildfire, including language notification in English, Spanish, and the top three primary 

languages used in the state other than English or Spanish, as determined by the 

commission based on the United States Census data.

V.A.

V.B.

(17) A statement of how the electrical corporation will restore service after a wildfire. V.B.1.

(18) Protocols for compliance with requirements adopted by the commission 

regarding activities to support customers during and after a wildfire, outage reporting, 

support for low-income customers, billing adjustments, deposit waivers, extended 

payment plans, suspension of disconnection and nonpayment fees, repair processing 

and timing, access to utility representatives, and emergency communications.

V.C.

(19) A description of the processes and procedures the electrical corporation will use 

to do all of the following:

(A) Monitor and audit the implementation of the plan.

(B) Identify any deficiencies in the plan or the plan’s implementation and correct 

those deficiencies.

(C) Monitor and audit the effectiveness of electrical line and equipment inspections, 

including inspections performed by contractors, carried out under the plan and other 

applicable statutes and commission rules.

VI.D.

(20) Any other information that the commission may require. VII.A.

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CROSS REFERENCE TABLE 2

Using Wildfire Mitigation Plan Organization

Wildfire Mitigation Plan section

Code 

Reference 

§8386(c)

I. Objectives consistent with §8386(a) 

A. Categorized by following timeframes:

A. Before upcoming wildfire season

B. Before next Plan filing

C. Within next 5 years

2

II. Description of preventive strategies and programs 

B. Categorized by following timeframes:

A. Before upcoming wildfire season

B. Before next Plan filing

C. Within next 5 years

3

III. Risk Analysis and Risk Drivers

A. Safety and wildfire risk identification and assessment methodology 15

B. Wildfire risks and drivers list

C. Listed in the following categories:

1. Design and Construction

2. Inspection and Maintenance

3. Operational Practices

4. Situational/Conditional Awareness

5. Response and Recovery

10

C. Description of how plan accounts for wildfire risk identified in RAMP 11

D. Service territory fire-threat evaluation 14

IV. Wildfire Prevention Strategies and Programs

D. Operational practices 6

12

E. Inspection and maintenance plans 9

F. System hardening to achieve highest level of safety, reliability, and 

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Wildfire Mitigation Plan section

Code 

Reference 

§8386(c)

resiliency

G. Vegetation management plan 8

H. Situational awareness protocols and determination of local conditions

I. De-energization protocol 7

J. Alternative technologies

K. Post-incident recovery, restoration, and remediation activities

V. Emergency Preparedness and Response

A. General description of overall plan

B. Description of consistency with emergency preparedness and response 

plan 16

1. Service restoration plan 17

2. Emergency communications

3. Workforce adequacy showing 13

C. Customer support in emergencies

1.1.1. Protocols for compliance with CPUC requirements 18

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Wildfire Mitigation Plan section

Code 

Reference 

§8386(c)

VI. Performance Metrics and Monitoring

A. Accounting of responsibilities 1

B. Description of metrics and assumptions 4

C. Discussion on how previous metrics performance has informed current plan 5

D. Processes and procedures for:

1. Plan monitoring and auditing

2. Identifying and correcting Plan deficiencies 

3. Monitoring and auditing effectiveness of equipment and line inspections

19

VII.Any other information the CPUC may require

A. Cost information 20

(End of Appendix B)

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Appendix C

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Appendix C – List of Acronyms

A. Application

AT&T AT&T Mobility Wireless Operations Holdings, Inc.,Pacific 

Bell Telephone Company, and AT&T Corp.

AB Assembly Bill

Abrams William B. Abrams

ACS Arc Suppression Coils

AGP Annual Grid Patrol

Air Operations SCE’s Air Operations Department

ANSI American National Standards Institute

AR automatic reclosers

Bear Valley or 

BVES

Bear Valley Electric Service, a division of Golden State 

Water Company

BLF Branch Line Fuses

BVLOS Beyond Visual Line of Sight

C3 Customer Crew Communications

Cal Advocates Public Advocates Office fka Office of Ratepayer Advocates

CAISO California Independent System Operator

CAL FIRE California Department of Forestry and Fire Protection

Cal OES California Office of Emergency Services

CARE California Alternate Rates for Energy

CEJA California Environmental Justice Alliance

CB Circuit Breaker

CCC Customer Contact Center

CCSF The City and County of San Francisco

CCUE Coalition of California Utility Employees

CCTA California Cable and Telecommunications Association

CCWD Contra Costa Water District

Cell Critical Energy Infrastructure Information

CEMA Catastrophic Event Memorandum Account

CEQA California Environmental Quality Act

CERP Company Emergency Response Plan

CFBF California Farm Bureau Federation

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CIRT Centralized Inspection Review Team

Citizens Citizens Sunrise Transmission LLC

CLF current-limiting fuses

CMUA California Municipal Utilities Association

CPUC California Public Utilities Commission or Commission

CSWC California State Warning Center

CUEA California Utilities Emergency Association

CWSP Community Wildfire Safety Program

D. Decision

DATC Duke American Transmission Company

DATC Path 15 Trans-Elect NTD Path 15, LLC

DDS Distribution Design Standards

DFA Distribution Fault Anticipation

DFM Dead Fuel Moisture

DIIP Distribution Infrared Inspection Program

DIMP Distribution Inspection and Maintenance Program

DOH Distribution Overhead Construction Standards

DRI Drought Relief Initiative

EBMUD East Bay Municipal Utility District

Eel Edison Electric Institute

EOC Emergency Operations Center

EOI enhanced overhead inspections

EONS Emergency Outage Notification System

EPIC Electric Program Investment Charge

EP&R Emergency Preparedness and Response

EPUC/IS Energy Producers and Users Coalition and Indicated 

Shippers

ERO Emergency Response Organization

ESA Energy Savings Assistance

ETOR Estimated Time of Restoration

EVM enhanced vegetation management

FEMA Federal Emergency Management Agency

FERA Family Electric Rate Assistance

FERC Federal Energy Regulatory Commission

FHPMA Fire Hazard Prevention Memorandum Account

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FHSZ Fire Hazard Severity Zone

FIA Fire Index Area

FiRM Fire Risk Mitigation 

FMEA Failure Modes and Effects Analysis

FPI Fire Potential Index

FPP Fire Prevention Plan

FRP fiber reinforced polymer

GIS Geographic and Information System

GO General Order

GPI Green Power Institute

GRC General Rate Case

GSRP Grid Safety and Resiliency Program

GSW Golden State Water Company

HD high definition

Henricks Ruth Henricks

HFRA High Fire Risk Areas

HFTD High Fire Threat District

HHZ High Hazard Zones

HPCC High Performance Computing Cluster

HTMP Hazard Tree Management Program

I. Investigation

ICS Incident Command System

IMT Incident Management Team

IOUs Investor-Owned Utilities

IPI Intrusive Pole Inspection program

IR Infrared

ISA International Society of Arborculture

ITO Independent Transmission Owners

IVR Integrated Voice Recording

km Kilometer

kV Kilovolt

LAC Local Assistance Center

LA County Los Angeles County

LADWP Los Angeles Department of Water and Power

Laguna Beach The City of Laguna Beach

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Liberty Liberty Utilities (CALPECO Electric) LLC

LiDAR light detection and ranging technology

Malibu The County of Los Angeles, City of Malibu

MA Memorandum Account

MAA Mutual Assistance Agreements

MADEC meter alarming for downed energy conductor

MAVF Multi-Attribute Value Framework

Mendocino The County of Mendocino

MGRA Mussey Grade Road Alliance or Mussey Grade

Mph Miles per hour

MVCD Minimum Violation Clearance Distance

Napa The County of Napa

NIMS National Incident Management System

NEET-West Next Era Energy Transmission West LLC

NERC North American Reliability Corporation

NFDRS National Fire Danger Rating System

NFPA National Fire Protection Association

NIFC National Interagency Fire Center

NIMS National Incident Management System

NWS National Weather Service

OA Operability Assessment

OCP Overhead Conductor Program

ODI Overhead Detail Inspection 

ODRM Outage Database and Reliability Metrics

OEM Offices of Emergency Management

OES Office of Emergency Services

OIR Order Instituting Rulemaking

OMS Outage Management System

OSA The Commission’s Office of Safety Advocates

PacifiCorp Pacific Power, a division of PacifiCorp

Paradise Town of Paradise

PCB polychlorinated biphenyls

PCEA Peninsula Clean Energy Authority

PEV Post Enrollment Verification

PG&E Pacific Gas and Electric Company

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PI Pole Inspections

PIH Pre-installed Interconnection Hubs

PLP Pole Loading Program

PMO Program Management Office

POC Protect Our Communities

POMMS PG&E Operational Mesoscale Modeling System

PRC Public Resources Code

PSPS Public Safety Power Shut-Off or De-Energization

PTZ pan-tilt-zoom

PUC Public Utilities Code

QA Quality Assurance

QC Quality Control

QCG Quality Control Group

AM Quality Management

QO Quality Oversight

R. Rulemaking

RAMP Risk Assessment Mitigation Phase

RAR remote-controlled automatic reclosers

RAWS Remote Automated Weather Stations

RCRC Rural County Representatives of California

REACH Relief for Energy Assistance through Community Help

REFCL Rapid Earth Fault Current Limiter

RFW Red Flag Warnings

ROW Right-of-Way

Santa Rosa The City of Santa Rosa

SAWTI Santa Ana Wildfire Threat Index

SB901 Senate Bill 901

SBUA Small Business Utility Advocates

SCADA Supervisory Control and Data Acquisition

SCE Southern California Edison Company

SDG&E San Diego Gas & Electric Company

SE D Commission’s Safety and Enforcement Division

SIMP Substation Inspection and Maintenance Program

SIPT Safety and Infrastructure Protection Teams

S-MAP Safety Model Assessment Proceedings

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SOB Standard Operating Bulletin

Sonoma County of Sonoma

SOPP Storm Outage Prediction Model

SoCalGas Southern California Gas Company

SmartMeter Brand Name for Automated Metering Initiative

SME Subject MaTTER Experts

Sunrun Sunrun Inc.

Startrans Startrans IO, LLC

T&D SCE’s Transmission and Distribution business unit

TBC Trans Bay Cable LLC

TICII Transmission Infrared and Corona Inspection Initiative 

TIMP Transmission Inspection and Maintenance Program

TURN The Utility Reform Network

UAS Advanced Unmanned Aerial Systems

UAV unmanned aerial vehicle

UDI Underground Inspection Program

USFS U.S. Forest Service

USGS United States Geological Survey

VM Vegetation Management

WAPA Western Area Power Administration

WCCP Wildfire Covered Conductor Program

WEIMAR Western Energy Institute Mutual Assistance Roster

WECC Western Electricity Coordinating Council

WMP or Plan Wildfire Mitigation Plan

WRF Weather Research and Forecasting

WRMAG Western Region Mutual Assistance Agreement for

Electric Utilities

WSIP Wildfire Safety Inspection Program

WSOC Wildfire Safety Operations Center

WSP Wildfire Safety Plan

Zuma Beach Hans Laetz on behalf of Zuma Beach FM Broadcasters

(End of Appendix C)

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