POU Response: VMUS meets or exceeds all applicable design, operation, maintenance, and inspection requirements, including the CPUC's General Orders 95, 128, and 165. Further, VMUS' system is also almost entirely underground, which provides significant protections against power-line ignited wildfires. In light of these existing mitigation measures and because VMUS' system is not affected by PSPS events and is outside of the CPUC's High Fire Threat District (HFTD), VMUS has not identified any additional mitigation measures or any resource shortages.
WSAB Recommendation #8: Describe annual visual patrols on potentially impacted circuits and the risks the POU is inspecting for. Describe whether and how system inspections lead to system improvements. Describe line patrols before, during, and/or after a critical fire weather event, such as a Red Flag Warning with strong winds, or following a fire that burned in areas where electric facilities are or could have been impacted.
POU Response: VMUS Staff regularly conduct patrols and inspections of the system in compliance with CPUC General Orders 95, 128, and 165. VMUS corrects any safety hazards discovered on its system in accordance with these regulations. Because VMUS' system is almost entirely underground, VMUS does not perform any additional inspections after Red Flag Warnings or high wind events.
WSAB Recommendation #9: Describe options considered by POU (including through the joint efforts of the POU associations) to identify previously unidentified risks that could lead to catastrophic wildfires.
POU Response: The California Municipal Utilities Association (CMUA) will be holding a special meeting of its Wildfire Preparedness, Response, and Recovery Working Group this fall, which will be focused on risk drivers for power-line caused catastrophic wildfires and innovative mitigation options. CMUA plans to invite a broad range of utility staff, state agency staff (including the WSAB), industry experts, and academics to participate in this discussion. As part of this meeting, the working group will discuss unidentified wildfire risk drivers and mitigation measures that could address these risks. Based on the input provided during this meeting, CMUA will produce a publicly-available, post-meeting report that summarizes the group's conclusions and recommendations. VMUS' staff will participate in CMUA's meeting and will discuss any changes that VMUS has made to its operations in response to the conclusions and recommendations of the working group in a future WMP.
D. Risk Assessment
7