===== PAGE 1 ===== ## WILDFIRE MITIGATION PLAN ===== PAGE 2 ===== ## TABLE OF CONTENTS I. Overview 1 A. Policy Statement 1 B. Purpose of the Wildfire Mitigation Plan 1 C. Service Territory 1 D. Organization of the Wildfire Mitigation Plan 1 II. Objectives of the Wildfire Mitigation Plan 2 III. Roles and Responsibilities 3 A. Utility Governance Structure 3 B. Wildfire Prevention 4 C. Wildfire Response and Recovery 4 D. Standardized Emergency Management System 5 IV. Wildfire risks and drivers associated with design, construction, operation, and maintenance 7 A. Particular Risks and Risk Drivers Associated with Topographic & Climatological Risk Factors 7 B. Enterprise-Wide Safety Risks 7 V. Wildfire Preventative Strategies 9 A. Low Fire Threat District 9 B. Design and Construction Standards 9 C. Vegetation Management 9 D. Inspections 10 E. Reclosing Policy 10 F. De-Energization 10 VI. Restoration of Service 10 VII. Plan Evaluation 11 A. Metrics and Assumptions for Measuring Plan Performance 11 B. Impact of Metrics on Plan 12 C. Monitoring and Auditing the Plan 12 D. Identifying and Correcting Deficiencies in the Plan 12 E. Monitoring the Effects of Inspections 12 Appendix I – 2021 Informational Response to WSAB ===== PAGE 3 ===== ### A. POLICY STATEMENT Victorville Municipal Utility Services' (VMUS) overarching goal is to provide safe, reliable, and economic electric service to its service territories. In order to meet this goal, Victorville Municipal Utility Services constructs, maintains, and operates its electrical lines and equipment in a manner that minimizes the risk of catastrophic wildfire posed by its electrical lines and equipment. ### B. PURPOSE OF THE WILDFIRE MITIGATION PLAN Victorville Municipal Utility Services entire electric supply system is located underground in conduit and vaults. Historically, underground electric lines have not been associated with catastrophic wildfires. The undergrounding of electric lines serves as an effective mitigation measure to reduce the potential of power-line ignited wildfires. Based on a review of local conditions and historical fires, VMUS has determined that its electrical lines and equipment do not pose a significant risk of catastrophic wildfire. Despite this low risk, VMUS takes appropriate actions to help its region prevent and respond to the increasing risk of devastating wildfires. In its role as a public agency, VMUS closely coordinates with other local safety and emergency officials to help protect against fires and respond to emergencies. In its role as a utility, VMUS follows all applicable design, construction, operation, and maintenance requirements that reduce safety risks associated with its system. This Wildfire Mitigation Plan describes the safety-related measures that VMUS follows to reduce its risk of causing wildfires. ### C. SERVICE TERRITORY Victorville Municipal Utility Services is only a distributor and does not own or operate any generating plants. The service area for Victorville Municipal Utility Services only includes the Southern California Logistics Airport (SCLA) and the Foxborough Industrial Park, less than 60 customers combined. VMUS only serves commercial and industrial customers. Southern California Edison serves all of the residents of the City of Victorville and any commercial / industrial customer not located within the VMUS territory. ### D. ORGANIZATION OF THE WILDFIRE MITIGATION PLAN This Wildfire Mitigation Plan included the following elements: • Objectives of the plan; • Roles and responsibilities for carrying out the plan; • Identification of key wildfire risks and risk drivers; • Description of wildfire prevention, mitigation, and response strategies and programs; Metrics for evaluating the performance of the plan and identifying areas for improvement; - Review and validation of the plan; and • Timelines. ===== PAGE 4 ===== ## Ⅱ ## OBJECTIVES OF THE WILDFIRE MITIGATION PLAN The primary goal of this Wildfire Mitigation Plan is to describe VMUS' existing programs, practices, and measures that effectively reduce the probability that VMUS' electric supply system could be the origin or contributing source for the ignition of a wildfire. To support this goal, VMUS regularly evaluates the prudent and cost-effective improvements to its physical assets, operations, and training that can help reduce the risk of equipment-related fires. The secondary goal of this Wildfire Mitigation Plan is to improve the resiliency of the electric grid. As part of the development of this plan, VMUS assesses new industry practices and technologies that will reduce the likelihood of an interruption (frequency) in service and improve the restoration (duration) of service. ===== PAGE 5 =====
ROLES AND RESPONSIBILITIES
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### A. UTILITY GOVERNANCE STRUCTURE
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VMUS Wildfire Mitigation Plan June 15, 2021
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===== PAGE 6 ===== The City of Victorville is a general law city that operates under a Council-Manager form of government. VMUS is governed by a five-member City Council. The council appoints the City Manager, who oversees the daily operations of the City. ### B. WILDFIRE PREVENTION VMUS staff is responsible for electric facility design, maintenance, and inspection, including vegetation management. Although VMUS' electrical distribution system is 100% underground, VMUS follows best practices to prevent ignition of wildfires from its equipment. These items include: VMUS performs routine maintenance of all distribution facilities. VMUS adheres to a seasonal weed abatement and vegetation management schedule to maintain at-risk sites. VMUS maintains GO95, GO165, and GO174 standard clearances as part of regular maintenance cycles. VMUS abides by the National Electric Safety Code (NESC) Rule 012 and Rule 218 standards to abate trees, shrubs, weeds, and grass at all VMUS facilities. - Electric system operates in a manner that will minimize potential wildfire risks. - Take all reasonable and practicable actions to minimize the risk of a catastrophic wildfire caused by VMUS electric facilities. Coordinate with federal, state, and local fire management personnel as necessary or appropriate to implement VMUS' Wildfire Mitigation Plan. - Immediately report fires to local fire departments, VMUS administration, and other City Officials, pursuant to existing VMUS practices and the requirements of this Wildfire Mitigation Plan. Coordinate with City Emergency Operations Center to disseminate safety warnings, emergency public information, and evacuation notices to local businesses. VMUS adheres to City of Victorville personnel code 2.36 for Employee Disaster Notification and Reporting. - Take corrective action when the staff witnesses or is notified that fire protection measures have not been properly installed or maintained. Comply with relevant federal, state, and industry standard requirements, including the industry standards established by the California Public Utilities Commission (CPUC). ### C. WILDFIRE RESPONSE AND RECOVERY VMUS field staff utilize hard line telephones, cellular telephones, and portable radios to communicate with internal and external stakeholders during an outage or emergency. VMUS' Outage Management System auto generates notifications to field and administrative staff. The City of Victorville maintains a two-way UHF band radios for communications enhanced by two DMR repeaters to extend the coverage area. The City radios can have up to 1,024 channels; of which twenty are currently programmed channels (eleven use repeaters and nine are simplex). The City of Victorville owns one Iridium satellite phone that is issued to the City's Emergency Management Coordinator or his designee during an emergency. VMUS, along with other key City personnel, have access to a Government Emergency Telecommunications Services (GETS) card and PIN provided by Homeland Security to allow for the capability to respond to National Security and Emergency Preparedness (NS/EP) events. Using the Wireless Priority Services (WPS) with GETS can increase the probability of a call completion in both wireless and wireline networks. ===== PAGE 7 ===== In addition to the City of Victorville Fire Department, Mission Fire Rescue (Mission) services the Southern California Logistics Airport. VMUS and airport staff are able to communicate with Mission Fire Rescue through 400-megahertz radios or by calling their station directly. Additionally, the control tower has a direct line to Mission's fire station, which rings throughout the station and opens the bay doors alerting them of an emergency. CONFIRE provides dispatch services for the City of Victorville Fire Department and Mission. They have the capability of patching in Apple Valley Fire Protection District, CAL FIRE, and contacting several other agencies such as Southwest Gas, Southern California Edison, AMR and other local agencies to assist in an emergency. CONFIRE also functions as the operational area dispatch for the County of San Bernardino, and can coordinate mutual aid as needed. At the county level, a San Bernardino County Emergency Operations Center (EOC) talk group is programmed into an 800-megahertz frequency band radio and is used to communicate with EOCs within San Bernardino County during a disaster or emergency. The City of Victorville contracts with San Bernardino County Sheriffs. They too utilize 800-megahertz frequency band radios to communicate and have the capability to patch in California Highway Patrol, CAL FIRE, and other county resources to assist during emergencies. City of Victorville also maintains a reporting hotline to notify the city for code violations, hazards, safety concerns, and overgrown landscaping and weeds. Additionally, the City allows its constituency to report any code violations on line via the City's website. VMUS adheres to California Public Utility Commission GO 95, 165, and 174 for all system infrastructure inspection, maintenance, and reporting. ### D. STANDARDIZED EMERGENCY MANAGEMENT SYSTEM As a local governmental agency1, VMUS has planning, communication, and coordination obligations pursuant to the California Office of Emergency Services' Standardized Emergency Management System (“SEMS”) Regulations2, adopted in accordance with Government Code section 8607. The SEMS Regulations specify roles, responsibilities, and structures of communications at five different levels: field response, local government, operational area, regional, and state.3 Pursuant to this structure, VMUS annually coordinates and communicates with the relevant safety agencies as well as other relevant local and state agencies. When activated, VMUS serves as the Utilities Unit Leader under the Operations Section Chief as part of the City Victorville Emergency Operations Center. In the event that the incident centered on VMUS facilities, VMUS would serve as the Operations Section Chief. ===== PAGE 8 ===== Under the SEMS structure, a significant amount of preparation is done through advanced planning at the county level, including the coordination of effort of public, private, and nonprofit organizations. San Bernardino County serves as the Operational Area and is guided by the California Office of Emergency Services Southern Region. The Operational Area includes local and regional organizations that bring relevant expertise to the wildfire prevention and recovery planning process. These participants are listed below:
AgencyAddressContactPhone No.
AMR, American Medical Response14828 7th Street\nVictorville, CA 92392Administration760.952.7400
Kaiser Permanente High Desert Medical Offices14011 Park Ave.\nVictorville, CA 92392Administration833.574.2273
St. Mary's Hospital Medical Center18300 Highway 18\nApple Valley, CA 92307Administration760.242.2311
Desert Valley Hospital16850 Bear Valley Rd.\nVictorville, CA 92395Administration760.947.5773
Victorville Municipal Utility Services18374 Phantom West\nVictorville, CA 92394Hotline877.760.8687
Victorville Municipal Utility Services18374 Phantom West\nVictorville, CA 92394Administration760.243.6340
Victorville Municipal Utility Services – Management18374 Phantom West\nVictorville, CA 92394Director of Utilities760.243.6341
Victorville Fire Department14343 Civic Drive\nVictorville, CA 92392Fire Chief760.955.5230
Victorville Fire Department14343 Civic Drive\nVictorville, CA 92392Division Chief760.955.5231
Victorville Fire Department14343 Civic Drive\nVictorville, CA 92392Emergency Medical Services Coordinator760.955.5237
Victorville Fire Department14343 Civic Drive\nVictorville, CA 92392Emergency Management Coordinator760.243.6344
SCLA – Airport Operations18374 Phantom West\nVictorville, CA 92394Hotline760.243.1915
SCLA Management18374 Phantom West\nVictorville, CA 92394Airport Director760.243.1910
Victorville – Police Department14176 Amargosa Rd.\nVictorville, CA 92392Police Chief760.241.1186
Victorville – Public Works14177 Mc Art Rd.\nVictorville, CA 92392Director760.243.6332
Victorville – City Management14343 Civic Drive\nVictorville, CA 92392City Manager760.955.5029
Victorville – City Management14343 Civic Drive\nVictorville, CA 92392PIO760.955.5028
Victorville – Traffic & Transportation14343 Civic Drive\nVictorville, CA 92392Traffic Engineer760.955.5156
San Bernardino County: Dept. of Environmental Health385 N. Arrowhead Ave. #2\nSan Bernardino, CA 92415Administration800.442.2283
Mission Aviation Fire Rescue1055 E. 3rd Street\nCorona, CA 92879Administration844.321.2733
Mission Aviation Fire Rescue – Station 31918550 Readiness St.\nVictorville, CA 92394Fire Chief760.246.6479
Pursuant to the SEMS structure, VMUS participates in annual training exercises. Training exercises include workshops and tabletop exercises. A sample of topics covered include earthquake safety, disaster response & management, and NIMS/SEMS/ICS compliance. ===== PAGE 9 ===== WILDFIRE RISKS AND DRIVERS ASSOCIATED WITH DESIGN, CONSTRUCTION, OPERATION, AND MAINTENANCE ### A. PARTICULAR RISKS AND RISK DRIVERS ASSOCIATED WITH TOPOGRAPHIC AND CLIMATOLOGICAL RISK FACTORS Due to VMUS's distribution system being 100% underground, the primary risk drivers for wildfire within VMUS's service territory are the following: Earthquake • Flooding ### B. ENTERPRISEWIDE SAFETY RISKS Earthquake profile - There are two major faults/fault zones that directly affect VMUS. They are the San Andreas Fault and the Helendale Fault zones. The City of Victorville sits in the middle of both faults. The San Andreas Fault is the longest fault in California and is known to cause powerful earthquakes, as big as a magnitude eight (8.0).4 This fault is located south-west of Victorville. The Helendale Fault creates smaller, yet more frequent earthquakes and is located northeast of the city. The most recent major earthquake to affect the City of Victorville was the Ridgecrest earthquake, approximately 82 miles north of the city. This earthquake struck July 5, 2019 and had a magnitude of 7.1. Large earthquakes occurring in many parts of the Southern California region could affect the City of Victorville. However, the degree to which the earthquakes are felt, and the damages associated with them may vary. At risk from earthquake damage are critical facilities, buildings, bridges, highways and roads; hazardous materials facilities; sewer, water, natural gas pipelines; earth dams; petroleum pipelines; and private property located in the city. The relative or secondary earthquake hazards, which are liquefaction, ground shaking, amplification, and earthquake-induced landslides, can be just as devastating as the earthquake. Flooding profile - There are four types flooding conditions that exist within the City of Victorville area; flooding in defined watercourses; ponding; sheet flow; and dam inundation. Flooding within defined watercourses occurs within drainage channels and immediately adjacent floodplains. Ponding occurs when water flow is obstructed due to manmade obstacles and other roadways, where they cross-defined watercourses. Sheet flow occurs when capacities of defined watercourses are exceeded and water flows over broad areas. Known flood-prone areas noted in the General Plan as well as recorded in city maintenance files, include:
DIRSTREETDISTANCEDIRECTIONCROSS STREETDIR
N/SRancho RdManning StW/B
S/SRancho Rd100E/OEL Evado RdE/B
W/SEnramada Rd100N/OCahuenga RdS/B
E/SEnramada Rd150S/OCahuenga RdS/B
E/SCahuenga Rd150N/OHopland StN/B
/SEl EvadoFigueroa RdS/B
E/SEl Evado100N/OTawney Ridge LnN/B
4 https://www.earthquakeauthority.com/California-Earthquake-Risk/Faults-By-County
VMUS Wildfire Mitigation Plan
June 15, 2021
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VMUS Wildfire Mitigation PlanJune 15, 20218
S/SClovis St350W/OOrick PlE/B
N/SClovis StOrick PlW/B
N/SEto Camino Rd25E/OBarranca WayW/B
S/SEto Camino Rd25E/OCazadero RdE/B
S/STawney Ridge Ln20E/OSueno LnE/B
N/STawney Ridge LnGreenHill Dr.W/B
N/SLa Mesa Rd40W/OPacoima RdW/B
E/SAmethyst Rd100S/OSierra RdN/B
S/SBear Valley Rd300E/OAmethyst RdN/B
N/SBear Valley Rd150W/ODunia RdW/B
W/SAvalon Rd20N/OMolino Dr.S/B
E/SAvalon Rd75N/OHughes RdN/B
N/SHughes Rd150E/OAvalon RdW/B
S/SHughes Rd700W/OAvalon RdE/B
S/SPebble Beach Dr.25W/OArrowhead Dr.E/B
N/SPebble Beach Dr.300E/OArrowhead Dr.W/B
W/S1st AveTalpa StS/B
N/S1st Ave50E/ODean AveW/B
W/S2nd Ave50S/OTalpa StS/B
E/S2nd Ave25N/OKayuga StN/B
N/SKayuga St50W/O2nd AveW/B
S/SKayuga St50E/O3rd AveE/B
S/SPonca St50E/O3rd AveE/B
N/SPonca St25W/O2nd AveW/B
E/SDean Ave100S/OCalcite AveN/B
W/SDean Ave50N/OGrant StS/B
W/SCalcite Ave25N/OCalcite PlS/B
E/SCalcite Ave300S/ODean AveN/B
W/SCobalt Rd25S/OPalmdale RdS/B
E/SCobalt Rd25N/OCameron StN/B
N/SLuna Rd200W/OTopaz RdW/B
S/SLuna Rd200E/OHWY 395E/B
W/SCantina Dr.100S/OLa Mesa RdS/B
E/SCantina Dr.400N/OBear Valley RdN/B
S/SBear Valley Rd300E/OHWY 395E/B
S/SBear Valley Rd400E/OTopaz RdE/B
N/SBear Valley Rd500E/OTopaz RdW/B
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W/SCobalt Rd500N/OBear Valley RdS/B
W/SCobalt Rd50S/OBear Valley RdS/B
E/SCobalt RdHomestead Dr.N/B
E/SCobalt Rd200N/OSycamore StN/B
S/SSycamore St200E/ORichmond AveE/B
N/SSycamore St20E/OChisholm Tr.W/B
N/SLa Mesa Rd50W/OWrangler LnW/B
S/SLa Mesa Rd200W/OStanford Dr.E/B
S/SLa Mesa Rd100E/OMesa Linda AveE/B
W/SMonte Vista Rd300S/OPalmdale RdS/B
N/SBear Valley Rd350W/OHWY 395W/B
S/SBear Valley Rd200E/OMonte Vista RdE/B
E/SMonte Vista Rd300S/OMaricopa RdN/B
### V. WILDFIRE PREVENTATIVE STRATEGIES ### A. LOW FIRE THREAT DISTRICT The CPUC's Fire Threat Map includes three Tiers/Levels of fire threat risk. Tier 1 consists of areas that have the lowest hazards and risks, tier 2 consists of areas where there is an elevated risk for destructive electric line-ignited wildfires, and tier 3 consists of areas where there is an extreme risk for destructive electric line-ignited wildfires. The City of Victorville is located in Tier 1. Despite the city's classification of Tier 1, VMUS is cognoscente of the potential dangers; and therefore, implements practices that go above the required industry standards as described below. ### B. DESIGN AND CONSTRUCTION STANDARDS VMUS' electric facilities are designed and constructed to meet or exceed the relevant federal, state, or industry standard. VMUS treats CPUC General Orders (GO) 95 and 128 as a key industry standard for design and construction standards for underground electrical facilities. VMUS meets or exceeds all standards in GO 95 and 128. Additionally, VMUS monitors and follows, as appropriate, the National Electric Safety Code. ### C. VEGETATION MANAGEMENT VMUS meets or exceeds the minimum industry standard vegetation management practices. For distribution level facilities, VMUS meets: (1) Public Resources Code section 4292; (2) Public Resources Code section 4293; (3) CPUC GO 95, 128, 165, and 174. ### D. INSPECTIONS VMUS meets or exceeds the minimum inspection requirements provided in CPUC GO 165 and 174. As ===== PAGE 12 ===== described above, VMUS currently does not have any overhead power lines located within or near a Tier 2 or Tier 3 Fire Threat District; however, VMUS staff uses their knowledge of the specific environmental and geographical conditions of VMUS' service territory to determine if any particular areas require more frequent inspections. If VMUS staff discovers a facility in need of repair that is owned by an entity other than VMUS, VMUS will issue a notice to repair to the facility owner and work to ensure that necessary repairs are completed promptly. ### E. RECLOSING POLICY VMUS' electrical system is primarily underground and has no automatic re-closures in service. In a relayed event, re-closures will be handled on a case-by-case basis after circuit and equipment inspections have been performed. VMUS does not change substation relay settings. ### F. DE-ENERGIZATION VMUS has the authority to preemptively shut off power due to fire-threat conditions; however, this option will only be used in extraordinary circumstances. Due to the minimal risk of VMUS' electrical supply facilities causing a power-line ignited wildfire, VMUS is not adopting specific protocols for de-energizing any portions of its electric distribution system. VMUS will re-evaluate this determination in future updates to this Wildfire Mitigation Plan. ### VI. RESTORATION OF SERVICE VMUS' electric distribution system is completely underground. However, we are interconnected with SCE's transmission and distribution systems, much of which is overhead and exposed to wind, rain and lightning. This is our primary source of vulnerability to potential electrical service interruptions during rain and windstorms such as the ones that can be precipitated by El Niño. Our underground electric distribution system is designed, and has been constructed, with redundant sources of feed. These do not guarantee the elimination of outages but can facilitate service restoration and reduce the duration of such outages. Preparation in advance of predicted storms: Since, as discussed in the introduction, our primary trouble source during storms is outages on SCE's transmission and distribution lines, many of which are overhead, we will patrol, to the extent practical, SCE's primary interconnect lines for any potential trouble spots or vulnerabilities. We will also double check the loading conditions of our underground lines to satisfy ourselves that alternate sources have the capacity to serve the electric load (customers) in the event that it is necessary. Our underground system will be patrolled in advance of storms for any open trenches or excavations at construction sites to minimize water intrusion into the underground system. Although the underground system is designed to operate under such conditions, small pinholes in splices or cable can cause problems, including possible electrical shorts/faults that can interrupt service to customers. Likewise, after the storm, each underground vault, manhole or other structure will be inspected for water intrusion and pumped, when necessary, in accordance proper utility practice and environmental guidelines. All vehicular equipment, tools, and appurtenances will be thoroughly inspected for proper operation. All operating personnel will be placed on standby in the event of weather related problems. The VMUS operations and admin staff will be prepared for handling of trouble calls from customers and dispatching ===== PAGE 13 ===== to field personnel. Call Center support includes: Outage Management System (OMS) Field Dispatching • Coordinating with VMUS' Qualified Emergency Electrical contractors - Customer Callbacks Response Prioritization: First Priority: Response to imminent threats to life and/or public property Second Priority: Removals of immediate hazards (fallen trees, power poles, etc.) Third Priority: Clearing of arterial roadways Fourth Priority: Maintenance of traffic control/closures to prevent potential accidents Fifth Priority (Post Storm Activity): Follow-up work such as addressing storm-related potholes and residual clean-up of all streets that have remained in a "passable and drivable" state Referral Protocol: Flooding of structures on private property- Businesses will be advised to call 911 for Fire Department assistance Facilities associated with private utilities will be referred to appropriate company All storm related issues involving streets, curbs and gutters, sidewalks, trees in the right of way, catch basins, and miscellaneous drainage facilities will be referred to the City's Maintenance and Operations Division. During EOC activation period, all routine maintenance programs and requests will be suspended and deferred. ### VII. PLAN EVALUATION ### A. METRICS AND ASSUMPTIONS FOR MEASURING PLAN PERFORMANCE VMUS will track the following metric to measure the performance of this Wildfire Mitigation Plan: (1) Number of fire ignitions caused by utility equipment. ===== PAGE 14 ===== ### 1. Metric 1: FIRE IGNITIONS For purposes of this metric, a fire ignition is defined as follows: VMUS facility was associated with the fire; The fire was self-propagating and of a material other than electrical and/or communication facilities; - The resulting fire traveled greater than one linear meter from the ignition point; and - VMUS has knowledge that the fire occurred. In future Wildfire Mitigation Plans, VMUS will provide the number of fires that occurred that were less than one (1) acre in size within VMUS' service territory. Any fires greater than one acre will be individually described. ### B. IMPACT OF METRICS ON PLAN In the initial years, VMUS anticipates that there will be relatively limited data gathered through the metric. However, as the data collection history becomes more robust, VMUS will be able to identify areas of its operations and service territory that are disproportionately impacted. VMUS will then evaluate potential improvements to the plan. ### C. MONITORING AND AUDITING THE PLAN This Wildfire Mitigation Plan will be presented to the Victorville City Council. VMUS staff will review the plan on an annual basis and bring updates to the Council as needed. ### D. IDENTIFYING AND CORRECTING DEFICIENCIES IN THE PLAN Based on the recommendations of the Victorville Fire Department and the Victorville City Council, VMUS will correct any identified deficiencies. ### E. MONITORING THE EFFECTIVENESS OF INSPECTIONS VMUS' Utility Maintenance Management System (UMMS) is used to collect all data subject to GO165. Quarterly inspection and maintenance reports are generated for all electric distribution facilities. Maintenance history for each piece of equipment is archived in the UMMS. Additionally, VMUS' substation inspection and maintenance program complies with GO174 guidelines as well as manufacturer specifications, standards, and recommendations. VMUS performs regular inspections of all substation components including recording and analysis of all alarms, fluid levels, meters, and Load Tap Changer settings. Although VMUS does not fall under the jurisdiction of the California Public Utilities Commission (CPUC), VMUS would cooperated with the CPUC's Utilities Safety and Reliability Branch and their requests for periodic audits. ===== PAGE 15 =====
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## APPENDIX I ===== PAGE 16 ===== RESPONSES TO WILDFIRE SAFETY ADVISORY BOARD'S 2021 GUIDANCE ADVISORY OPINION June 15, 2021 # VICTORVILLE MUNICIPAL UTILITY SERVICES WILDFIRE MITIGATION PLAN 2021 INFORMATIONAL RESPONSE ===== PAGE 17 ===== ### I. PURPOSE OF THIS 2021 INFORMATIONAL RESPONSE The California Wildfire Safety Advisory Board (WSAB) issued the Guidance Advisory Opinion for the 2021 Wildfire Mitigation Plans of Electric Publicly Owned Utilities and Cooperatives (“2021 WSAB Guidance Advisory Opinion”) on December 15, 2020. Victorville Municipal Utility Services (VMUS) provides this document to the WSAB in order to respond to each of the recommendations included in the 2021 WSAB Guidance Advisory Opinion. VMUS has provided a narrative response and/or a cross reference to the location in the adopted Wildfire Mitigation Plan (WMP) where the topic is addressed. ### II. CONTEXT SETTING INFORMATION WSAB requested that POUs provide an informational table to assist the Staff and Board members in understanding the unique characteristics of each POU.
Table 1: Context-Setting Information
Utility NameVictorville Municipal Utility Services (VMUS)
Service Territory Size6 square miles
Owned Assets☐ Transmission ☒ Distribution ☐ Generation
Number of Customers Served33 customer accounts
Population Within Service TerritoryN/A people
Customer Class MakeupNumber of AccountsShare of Total Load (MWh)
0% Residential;0% Government;0% Agricultural;0% Small/Medium Business;100% Commercial/Industrial0% Residential;0% Government;0% Agricultural;0% Small/Medium Business;100% Commercial/Industrial
Service Territory Location/Topography10% Agriculture0% Barren/Other0% Conifer Forest0% Conifer Woodland99% Desert0% Hardwood Forest0% Hardwood Woodland0% Herbaceous
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0% Shrub\n1% Urban\n0% Water
Service Territory Wildland Urban Interface2 (based on total area)0% Wildland Urban Interface;\n0% Wildland Urban Intermix;
Percent of Service Territory in CPUC High Fire Threat Districts (based on total area)☒Includes maps\nTier 2: 0%\nTier 3: 0%
Prevailing Wind Directions & Speeds by Season☒ Includes maps\nWinter (Dec., Jan., and Feb.): Wind direction is North/North East with an average speed of 4.3K or 4.95 MPH.\nSpring (Mar., April, and May): Wind direction is North/North East with an average speed of 6K or 6.9 MPH.\nSummer (June, July, and Aug.): Wind direction is North/North East with an average speed of 5.3K or 6.1 MPH.\nFall (Sept., Oct., and Nov.): Wind direction is North/North East with an average speed of 4.3K or 4.95 MPH.
Miles of Owned Lines Underground and/or OverheadOverhead Dist.: 0.034 miles\nOverhead Trans.: 0 miles\nUnderground Dist.: 21 miles\nUnderground Trans.: 0 miles
Explanatory Note 1 – Measurements in Circuit Miles.
Explanatory Note 2 – VMUS owns the electrical infrastructure that is all underground and services industrial and commercial customers only.
Percent of Owned Lines in CPUC High Fire Threat DistrictsOverhead Distribution Lines as % of Total Distribution System (Inside and Outside Service Territory)
Tier 2: 0%\nTier 3: 0%
Overhead Transmission Lines as % of Total Transmission System (Inside and Outside Service Territory)
Tier 2: 0%\nTier 3: 0%
Customers have ever lost service due to an IOU PSPS event?☐ Yes ☒ No
Have customers ever been notified of a potential loss of service to due to a forecasted IOU PSPS event?☐ Yes ☒ No
2 This data shall be based on the definitions and maps maintained by the United States Department of Agriculture, as most recently assembled in The 2010 Wildland-Urban Interface of the Conterminous United States, available at https://www.fs.fed.us/nrs/pubs/rmap/rmap_nrs8.pdf. ===== PAGE 19 =====
Has developed protocols to pre-emptively shut off electricity in response to elevated wildfire risks?☐ Yes ☒ No
Has previously pre-emptively shut off electricity in response to elevated wildfire risk?☐ Yes ☒ NoIf yes, then provide the following data for calendar year 2020: N/A.
### III. CROSS REFERENCE TO STATUTORY REQUIREMENTS WSAB requested that POUs provide a clear roadmap as to where each statutory requirement is addressed within the POU WMP.
Table 2: Cross References to Statutory Requirements
RequirementStatutory LanguageLocation in WMP
Persons ResponsiblePUC § 8387(b)(2)(A): An accounting of the responsibilities of persons responsible for executing the plan.Section 3-B Page 4
Objectives of the PlanPUC § 8387(b)(2)(B): The objectives of the wildfire mitigation plan.Section 2 Page: 2
Preventive StrategiesPUC § 8387(b)(2)(C): A description of the preventive strategies and programs to be adopted by the local publicly owned electric utility or electrical cooperative to minimize the risk of its electrical lines and equipment causing catastrophic wildfires, including consideration of dynamic climate change risks.Section 5 Page 9
Evaluation MetricsPUC § 8387(b)(2)(D): A description of the metrics the local publicly owned electric utility or electrical cooperative plans to use to evaluate the wildfire mitigation plan’s performance and the assumptions that underlie the use of those metrics.Section 7-A Page 11
Impact of MetricsPUC § 8387(b)(2)(E): A discussion of how the application of previously identified metrics to previous wildfire mitigation plan performances has informed the wildfire mitigation plan.Section 7-B Page 12
Deenergization ProtocolsPUC § 8387(b)(2)(F): 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.Section 5-E & F Page 10
Customer Notification ProceduresPUC § 8387(b)(2)(G): Appropriate and feasible procedures for notifying a customer who may be impacted by the deenergizing of electrical lines. The procedures shall consider the need to notify, as a priority, critical first responders, healthSection 6 Page 11
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care facilities, and operators of telecommunications infrastructure.
Vegetation ManagementPUC § 8387(b)(2)(H): Plans for vegetation management.Section 5-C Page 9
InspectionsPUC § 8387(b)(2)(I): Plans for inspections of the local publicly owned electric utility’s or electrical cooperative’s electrical infrastructure.Section 5-D Page 10
Prioritization of Wildfire RisksPUC § 8387(b)(2)(J): A list that identifies, describes, and prioritizes all wildfire risks, and drivers for those risks, throughout the local publicly owned electric utility’s or electrical cooperative’s service territory. The list shall include, but not be limited to, both of the following: (i) Risks and risk drivers associated with design, construction, operation, and maintenance of the local publicly owned electric utility’s or electrical cooperative’s equipment and facilities. (ii) Particular risks and risk drivers associated with topographic and climatological risk factors throughout the different parts of the local publicly owned electric utility’s or electrical cooperative’s service territory.Section 4 Page 7
CPUC Fire Threat Map AdjustmentsPUC § 8387(b)(2)(K): Identification of any geographic area in the local publicly owned electric utility’s or electrical cooperative’s service territory that is a higher wildfire threat than is identified in a commission fire threat map, and identification of where the commission should expand a high fire threat district based on new information or changes to the environment.Section 5-A Page 9
Enterprise-wide RisksPUC § 8387(b)(2)(L): A methodology for identifying and presenting enterprise wide safety risk and wildfire-related risk.Section 4-B Page 7
Restoration of ServicePUC § 8387(b)(2)(M): A statement of how the local publicly owned electric utility or electrical cooperative will restore service after a wildfire.Section 6 Page 10
Monitor and AuditPUC § 8387(b)(2)(N): A description of the processes and procedures the local publicly owned electric utility or electrical cooperative shall use to do all of the following (i) Monitor and audit the implementation of the wildfire mitigation plan. (ii) Identify any deficiencies in the wildfire mitigation plan or its implementation, and correct those deficiencies. (iii) Monitor and audit the effectiveness of electrical line and equipment inspections, including inspections performed by contractors, that are carried out under the plan, other applicable statutes, or commission rules.Section 7-C Page 12
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Qualified Independent EvaluatorPUC § 8387(c): The local publicly owned electric utility or electrical cooperative shall contract with a qualified independent evaluator with experience in assessing the safe operation of electrical infrastructure to review and assess the comprehensiveness of its wildfire mitigation plan. The independent evaluator shall issue a report that shall be made available on the Internet Web site of the local publicly owned electric utility or electrical cooperative, and shall present the report at a public meeting of the local publicly owned electric utility’s or electrical cooperative’s governing board.
### IV. WSAB GUIDANCE ADVISORY OPINION RECOMMENDATIONS The WSAB Guidance Advisory Opinion identifies 14 specific recommendations that POUs are requested to address in their 2021 WMPs. As specified in Public Utilities Code § 8387(b)(1), each POU is required to perform a comprehensive revision to the POU's WMP at least once every three years. Pursuant to this guidance, the POUs will be updating their WMPs based on the direction of their local governing boards within this 3-year cycle. Because the WSAB's recommendations have been provided after the initial WMP submission, the POUs will have varying capacities to fully address each recommendation in their 2021 WMP. This Section IV restates each of the WSAB recommendations and provides an opportunity for each POU to respond. ### A. Plan Structure POU Response: See Sections II and III above. WSAB Recommendation #1: Provide context-setting information about the POU and provide a simple guide to where the statutory requirements are addressed within the WMP. WSAB Recommendation #2: Provide a short description of the POU's public review and approval (if required) for the WMP. This description may also include a brief explanation of the funding mechanisms for wildfire mitigation efforts. POU Response: The WMP was presented to and approved by the City of Victorville's City Council and public meeting of the City Council. WSAB Recommendation #3: Identify where the POU has posted the most recent Independent Evaluator (IE) Report and if your POU plans to enhance future IE reports, please summarize in what ways. ===== PAGE 22 ===== POU Response: The City's most recent IE report is available on the City's website at: ftp://ftp.cpuc.ca.gov/WSAB/POUandCoopWMPs/Victorville%20Municipal%20Utility%20Services%20-%20WMP%20and%20IE%20Report%20-%205.28.2020.pdf WSAB Recommendation #4: Develop, in collaboration with POU industry associations, WMP guidelines for future WMPs, understanding that it may take multiple cycles for POUs to integrate these recommendations into the WMPs. POU Response: This document is intended to include, as appropriate, responses to the recommendations in the WSAB's Guidance Advisory Opinion for the POUs' 2021 WMP. This document also represents the combined effort of the POU industry associations to further the development of a template to respond to the WSAB's Guidance Advisory Opinion in a future reporting WMP cycle. ### B. Customer Impacts WSAB Recommendation #5: Describe the potential impact investor-owned utilities (IOU) public safety power shutoff (PSPS) events could have on POU customers and how the POU manages these impacts. For POUs that are also balancing authorities, describe the criteria for wildfire related de-energizations. Responses shall only provide aggregated information that does not provide customer-specific information or other potentially sensitive data. POU Response: VMUS customers are unlikely to be directly impacted by an IOU PSPS event because VMUS is not on the Southern California Edison's PSPS circuit. WSAB Recommendation #6: Describe the utility customer communication plans with respect to wildfires and PSPS, and in particular describe the methods, content and timing used to communicate with the most vulnerable customers, such as Access and Functional Needs (AFN) customers, medical baseline customers, non-English speakers, and those at risk of losing water or telecommunications service. POU Response: Due to not being on an SCE PSPS circuit, this is not applicable. ### C. The Grid WSAB Recommendation #7: Provide details on each POU's system hardening and grid design programs, including: (1) the goals of the programs and the risk any particular program is designed to mitigate; (2) approach to PSPS mitigation and prevention; and (3) identify any resource shortages. ===== PAGE 23 ===== 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 ===== PAGE 24 ===== WSAB Recommendation #10: Describe the particular wildfire risks associated with system design and construction such as topography and location near the HFTD areas of another utility's service territory. Describe any G.O. 95 exempt assets and possible updates to G.O. 95 that could facilitate more resilient utility transmission and distribution assets. POU Response: VMUS' assessment of wildfire risks is discussed in Section IV of VMUS' WMP. VMUS' wildfire risk is minimal due to the system infrastructure being located underground, the low average wind speeds year-round, and because VMUS' service territory is located outside of the Tier 2 or 3 HFTD. ### E. SITUATIONAL AWARENESS TECHNOLOGY WSAB Recommendation #11: Provide context-setting information about the prevailing wind directions and speeds, differentiated by season, along with average weather conditions by season. Describe how and why situational awareness technology is installed, and where on the system. Describe the decision-making process regarding the installation of situational awareness technology, including constraints such as budgets, availability of equipment, knowledge to effectively deploy, or qualified personnel to install and monitor effectively. Identify any other agencies, utilities, or fire professionals that the data from these devices is shared with. POU Response: Situational awareness technology is not applicable due to VMUS' system infrastructure. ### F. VEGETATION MANAGEMENT WSAB Recommendation #12: Describe treatment plans for all types of vegetation associated with utility infrastructure, from the ground to the sky, which includes vegetation above and below electrical lines. POU Response: VMUS's vegetation management program is discussed in Section V of VMUS' WMP. VMUS meets or exceeds the minimum industry standard vegetation management practices. For distribution level facilities, VMUS meets: (1) Public Resources Code section 4292; (2) Public Resources Code section 4293; (3) CPUC GO 95, 128, 165, and 174. WSAB Recommendation #13: List the qualifications of any experts relied upon, such as scientific experts in ecology, fire ecology, fire behavior, geology, and meteorology. Specify the level of expertise of the POU staff that manages the contractors performing vegetation management. Describe measures each POU takes to ensure that POU staff and contractors comply with or verify compliance with Cal/OSHA standards on Minimum Approach Distances (MAD). ===== PAGE 25 ===== POU Response: Because VMUS' system is almost entirely underground, VMUS has minimal vegetation management requirements and, therefore, does not maintain specialized staff for ecology, fire ecology, fire behavior, geology, and meteorology. WSAB Recommendation #14: Describe whether the POU has considered innovative and alternative approaches to vegetation management. POU Response: Because VMUS' system is almost entirely underground, VMUS has minimal vegetation management requirements and, therefore, has not developed innovated or alternative approaches to vegetation management.