Reasonableness Review: SDG&E’s Operation and Management of its Facilities Prior to the Guejito Fire In evaluating SDG&E’s operation and management of its facilities in connection to the Guejito Fire, the Commission must determine whether SDG&E employed reasonable judgment in its operation and management of its facilities in the period leading up to the ignition of the Guejito Fire. The record shows that SDG&E utilized its Corrective Maintenance Program to perform patrol and detailed (overhead) inspections of P196387 and P196394 prior to the Guejito Fire ignition. SDG&E asserts its failure to identify the 3.3 foot clearance violation merely shows the utility was not perfect; we disagree. SDG&E’s use of patrol and overhead inspection protocols may be reasonable. The repeated failure of these patrols to identify the clearance violation is not reasonable. While SDG&E’s testimony highlights its Corrective Maintenance Program, the existence of the Corrective Maintenance Program is not sufficient to establish that SDG&E fulfilled its duty to be a reasonable and prudent manager. At the same time, the lack of inspection records indicates a failure to act prudently. The fact that the Cox line was installed in 2001, 6 years before the fire, and that no inspection records affirmatively reference compliance with GO 95 clearance requirements is problematic. Moreover, we find the 6-year gap in inspection records (from 2001 to 2007) to be indicative of imprudent management. SDG&E asserts that to find its failure imprudent would be to interpret the prudence standard as a perfection standard. We disagree. Documentation of compliance with objective clearance standards at some point during the many years the Cox line was installed is not equivalent to perfection.
Dr. Peterka elaborated on his methodology. Essentially, Dr. Peterka explained that he validated his WRF results with 2007 observed data from the Automated Surface Observing System (ASOS) located at the Ramona Airport. Dr. Peterka stated, “the largest 3-second gust measured at the Ramona Airport during [October 2007] was 55 mph. Based on the ESDU procedure used to estimate the 3-second gust from the WRF simulations, the gusts are predicted to be between 60 and 76 mph, or 9 to 38 percent higher than the actual measurements. The validation exercise is dependent on the overall match between ASOS and WRF wind speeds and directions….as well as the comparison of peak gusts. This validation supports my methodologies.” Dr. Peterka explained that he believed the RAWS and ASOS data were obtained from stations that were improperly sited. Dr. Peterka asserts that the improper siting resulted in recorded wind speeds that are too low. For this reason, Dr. Peterka discarded the 2007 RAWS and ASOS and came up with a result that is 9 to 38 percent higher. In addition to providing analyses of the wind and weather events surrounding the ignition of the 2007 Wildfires, SDG&E’s experts highlighted the utility’s involvement in developing the Santa Ana Wildfire Threat Index (SAWTI). SDG&E notes, “to develop the SAWTI, SDG&E and UCLA worked to configure the WRF model by calibrating it against actual observations of temperatures, winds, and dew points collected from SDG&E weather stations during Santa Ana wind events.” SDG&E highlights that the SAWTI allows an individual to understand the fire potential by comparing it to past and present conditions. As such, SDG&E’s experts utilized the SAWTI in testifying that the wind and weather conditions in San Diego County in 2007 had the largest fire potential since 1984. Because of this, SDG&E maintains that it had no way to