Case 3:14-cr-00175-WHA Document 1057 Filed 04/25/19 Page 1 of 6

1
2
3
4
5
6
7
8
9
10
11
12
13
14
15

JENNER & BLOCK LLP
Reid J. Schar (pro hac vice)
RSchar@jenner.com
353 N. Clark Street
Chicago, IL 60654-3456
Telephone: +1 312 222 9350
Facsimile: +1 312 527 0484
CLARENCE DYER & COHEN LLP
Kate Dyer (Bar No. 171891)
kdyer@clarencedyer.com
899 Ellis Street
San Francisco, CA 94109-7807
Telephone: +1 415 749 1800
Facsimile: +1 415 749 1694
CRAVATH, SWAINE & MOORE LLP
Kevin J. Orsini (pro hac vice)
korsini@cravath.com
825 8th Avenue
New York, NY 10019
Telephone: +1 212 474 1000
Facsimile: +1 212 474 3700
Attorneys for Defendant PACIFIC GAS AND ELECTRIC
COMPANY

16
UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF CALIFORNIA
SAN FRANCISCO DIVISION

17
18
19
20

UNITED STATES OF AMERICA,
Plaintiff,

21
22
23
24

v.
PACIFIC GAS AND ELECTRIC COMPANY,

Case No. 14-CR-00175-WHA
MEMORANDUM RE SECOND
AMENDMENT TO PACIFIC GAS
AND ELECTRIC COMPANY’S
(U 39 E) WILDFIRE MITIGATION
PLAN

Defendant.

25
26
27
28

MEMORANDUM RE SECOND AMENDMENT TO PACIFIC GAS AND ELECTRIC COMPANY’S (U 39 E)
WILDFIRE MITIGATION PLAN
Case No. 14-CR-00175-WHA

 Case 3:14-cr-00175-WHA Document 1057 Filed 04/25/19 Page 2 of 6

1

Defendant Pacific Gas and Electric Company (“PG&E”) respectfully submits this

2

memorandum to notify the Court of its filing of a Second Amendment to its Wildfire Safety Plan

3

(the “Second Amendment”), originally filed February 6, 2019, corrected February 12, 2019, and

4

amended February 14, 2019 (the “Plan”). PG&E’s Second Amendment, which was filed with the

5

California Public Utilities Commission (“CPUC”) today, seeks to amend certain targets whose

6

completion dates are at risk due to external factors beyond PG&E’s control; modify certain targets to

7

allow for improvements to the original Plan based on lessons learned; and clarify certain descriptions

8

of programs in the Plan to avoid misinterpretation of meaning and scope. In addition, PG&E is

9

notifying the CPUC of expected cost increases in certain programs and correcting minor errors in

10

Attachment E to the Plan. Attached as Exhibit A to this filing is a chart summarizing PG&E’s

11

proposed changes to the Plan targets. Attached as Exhibit B to this filing is PG&E’s Second

12

Amendment, filed with the CPUC on April 25, 2019, which describes each proposed change in detail

13

along with the basis for each change.

14

PG&E’s Plan provides considerable detail about what PG&E proposes to do in 2019 in

15

advance of the wildfire season, during the wildfire season, and in subsequent years to continue to

16

reduce the risk of wildfires. To accomplish this objective, PG&E proposed in its Plan specific

17

targets that were tangible, quantifiable, and auditable, reflecting substantial increases of work over

18

prior years. In developing the Plan, PG&E recognized that there were significant execution risks,

19

arising from sources both external and internal to PG&E, to accomplishing the expanded and

20

accelerated scope of planned work. These challenges, outlined in Table 9 of the Plan, include

21

inclement weather, the availability of equipment, materials, and qualified personnel, and

22

legal/regulatory issues (e.g., objections from property owners or governmental agencies, and

23

environmental permitting requirements), which could impact the timing and scope of the programs

24

proposed in the Plan.

25

As PG&E implements these goals, challenges persist. For example, both the Wildfire Safety

26

Inspection Program (“WSIP”) inspections and Enhanced Vegetation Management (“EVM”) program

27

apply heightened criteria compared to historical routine work. As a result, PG&E is identifying

28

1
MEMORANDUM RE SECOND AMENDMENT TO PACIFIC GAS AND ELECTRIC COMPANY’S (U 39 E)
WILDFIRE MITIGATION PLAN
Case No. 14-CR-00175-WHA

 Case 3:14-cr-00175-WHA Document 1057 Filed 04/25/19 Page 3 of 6

1

greater numbers of necessary actions, which require additional resources. PG&E has hired and will

2

continue to hire the qualified resources necessary to complete this work safely and with a high

3

standard of quality, and PG&E will continue to assess the needs of these new programs as PG&E

4

learns through executing the Plan. Despite PG&E’s best efforts, several external execution risks

5

over which PG&E has no control threaten PG&E’s ability to strictly comply with certain of its

6

original targets. These external factors, the delays associated with them, and PG&E’s proposed

7

amendments to account for the delays include:

8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28

(1) The unusually long federal shutdown, which according to the FAA
will delay issuance of certifications for fire suppression helicopters
that PG&E applied for in 2018 to approximately six weeks past the
Plan’s May 2019 target date, at the earliest. PG&E proposes to amend
the date by which it will put these fire suppression helicopters into
operation to be “as soon as feasible after receipt of the necessary FAA
certification”. (See Second Amendment to Pacific Gas and Electric
Company’s (U 39 E) Wildfire Mitigation Plan, dated April 25, 2019
(“CPUC Submission”), attached hereto as Exhibit B, at 8.)
(2) Unusually wet weather over the 2018-2019 winter, which has made
certain transmission and distribution structures inaccessible and
hindered drone inspections that are a part of PG&E’s WSIP. A
number of WSIP transmission and distribution inspections also have
been delayed due to property owner objections and governmental
permitting or environmental requirements. Notwithstanding these
access limitations, PG&E will strive to perform at least one of the
following types of inspections by May 1, 2019 on each of the
structures that are inaccessible, as conditions permit: visual ground,
visual climbing, drone imagery or helicopter imagery. However,
PG&E proposes to amend its targets to provide that for specific
locations where these external factors do not permit completion of
inspections by the target date, they may be completed “as soon
thereafter as is feasible in light of weather conditions and other
external factors”. (Id. at 9-12.)
(3) Similarly, completing all of the priority “B” WSIP repair work
PG&E targeted for completion by May 31, 2019 (transmission and
substation) and June 30, 2019 (distribution) may be delayed beyond
the current completion dates due to inspections that were delayed
because of external factors described above, property owner
objections, governmental permit requirements or environmental
regulations including local tree protection ordinances and other
2
MEMORANDUM RE SECOND AMENDMENT TO PACIFIC GAS AND ELECTRIC COMPANY’S (U 39 E)
WILDFIRE MITIGATION PLAN
Case No. 14-CR-00175-WHA

 Case 3:14-cr-00175-WHA Document 1057 Filed 04/25/19 Page 4 of 6

environmental regulations.1 Although local land use restrictions do
not apply to CPUC-regulated work by investor-owned utilities, private
citizens nonetheless frequently protest the work. PG&E proposes to
amend its targets to provide that for specific locations where these
external factors do not permit completion of corrective actions by the
target date, they may be completed “as soon thereafter as is feasible in
light of weather conditions and other external factors”. (Id. at 13-15.)

1
2
3
4
5

(4) The same weather-related conditions and government permit
requirements impeding WSIP inspections are hindering PG&E crews
from accessing and SCADA enabling approximately five line
reclosers. PG&E proposes to amend its targets to provide that for
specific locations where these external factors do not permit PG&E
crews to SCADA-enable line reclosers, this may be done “as soon
thereafter as is feasible in light of weather conditions and other
external factors”. (Id. at 15-16.)

6
7
8
9
10
11

PG&E is working diligently to overcome these external challenges to avoid delays. PG&E’s

12

land and environmental management, external affairs, and customer care teams are working closely

13

with PG&E’s work execution teams to reduce potential delays caused by property owners,

14

governmental agencies, and environmental permitting requirements. PG&E will also seek assistance

15

from the Federal Monitor to address these challenges, where necessary. PG&E is nevertheless

16

seeking to amend the targets before the CPUC approves a final version of the Plan in recognition

17

that external factors may prevent full completion by the original target dates despite PG&E’s best

18

efforts.

19

In addition to these changes, PG&E proposes to modify the Plan to accommodate

20

improvements to certain of the enhanced wildfire mitigation measures included in the Plan. First,

21

after beginning construction of its first pilot Resilience Zone—an area that can be energized by an

22

alternative power supply during a Public Safety Power Shutoff (“PSPS”)—PG&E made

23

improvements to the design to maximize risk reduction. These design changes require PG&E to

24

obtain additional land rights, which may delay the completion of construction of the Resilience

25

Zone. (Id. at 16-17.) Second, PG&E found that certain subjective criteria in its EVM program made

26

1

27
28

PG&E expects to complete all priority “A” (highest priority) tags on the timeline outlined in the
current Plan.
3
MEMORANDUM RE SECOND AMENDMENT TO PACIFIC GAS AND ELECTRIC COMPANY’S (U 39 E)
WILDFIRE MITIGATION PLAN
Case No. 14-CR-00175-WHA

 Case 3:14-cr-00175-WHA Document 1057 Filed 04/25/19 Page 5 of 6

1

Quality Assurance (“QA”) audits difficult where professional judgments differ. PG&E has modified

2

the EVM program to apply objective criteria to eliminate these differences and proposes to modify

3

the Plan’s QA audit target to focus on the existing requirement of performing QA audits of 100% of

4

the EVM work and reworking of any trees that were missed or incorrectly worked. (Id. at 17-19.)

5

PG&E also seeks to clarify certain targets to avoid misinterpretation of the scope or meaning

6

of the language in the Plan. First, PG&E proposes to amend the description of its vegetation

7

management patrols to avoid implying that it will document its inspection of each of the more than

8

100 million trees with a potential strike path to an overhead line. While all trees that require work

9

will be documented, memorializing the inspection of each tree would significantly and unnecessarily

10

delay the inspection process. (Id. at 19.) Second, PG&E proposes to amend its description of its re-

11

energization of lines following a PSPS to clarify that PG&E will patrol all lines in areas identified as

12

meeting the PSPS de-energization criteria. PG&E will exercise operational judgment consistent

13

with standard utility industry practices to determine whether safety requires patrolling lines in areas

14

not affected by the extreme weather and fire danger conditions necessitating de-energization, but

15

were shut off only because of the interconnected nature of the grid. (Id. at 20-21.) Finally, PG&E is

16

notifying the CPUC of expected cost increases in two programs and correcting minor errors in

17

Attachment E to the Plan, which provides cost estimates for the programs in the Plan. (Id. at 21-22.)

18
19
20
21
22
23
24
25
26
27
28

4
MEMORANDUM RE SECOND AMENDMENT TO PACIFIC GAS AND ELECTRIC COMPANY’S (U 39 E)
WILDFIRE MITIGATION PLAN
Case No. 14-CR-00175-WHA

 Case 3:14-cr-00175-WHA Document 1057 Filed 04/25/19 Page 6 of 6

Respectfully Submitted,

1
2

Dated: April 25, 2019

JENNER & BLOCK LLP

3
4

By:

5
6

/s/ Reid J. Schar
Reid J. Schar (pro hac vice)

CRAVATH, SWAINE & MOORE LLP

7
8

By:

9
10

/s/ Kevin J. Orsini
Kevin J. Orsini (pro hac vice)

CLARENCE DYER & COHEN LLP

11
12
13
14
15

By:

/s/ Kate Dyer
Kate Dyer (Bar No. 171891)

Attorneys for Defendant PACIFIC GAS
AND ELECTRIC COMPANY

16
17
18
19
20
21
22
23
24
25
26
27
28

5
MEMORANDUM RE SECOND AMENDMENT TO PACIFIC GAS AND ELECTRIC COMPANY’S (U 39 E)
WILDFIRE MITIGATION PLAN
Case No. 14-CR-00175-WHA

 Case Document 1057-1 Filed 04/25/19 Page 1 of 5

Exhibit A

Case 3:14-cr-00175-WHA Document 1057-1 Filed 04/25/19 Page 2 of 5
 

SUMMARY OF AMENDMENTS AND CLARIFICATIONS TO TARGETS AND METRICS IN 2019 WILDFIRE SAFETY PLAN
CHANGES TO TABLE 9: 2019 WILDFIRE SAFETY PLAN TARGETS1

Section 

Redline of Relevant Changes 
2019 Target 

Title 

Execution Risk 

Operational Practices 
4.1.1

Recloser
Operations

SCADA enable all remaining line reclosers (approximately 285) in Tier 2 and
Tier 3 HFTD areas by June 1, 2019, or, for impacted locations, as soon
thereafter as is feasible in light of weather conditions and other external
factors.

Qualified personnel or material limitations.
Design, estimating or construction delays.

Disable any remaining manual reclosing devices in advance of exposure to
elevated wildfire risk conditions.
Daily operations conformance with TD-1464B-001 and monitor program for
effectiveness.
4.1.4

Aviation
Resources

Operate four heavy-lift helicopters to aid in fire suppression and restoration
efforts by May 2019, available at CALFIRE’s discretion as soon as feasible
after receipt of the necessary FAA certification.

Delays securing CALFIRE carding by
May 2019.2

Wildfire Safety Inspections Programs
4.2.1

Wildfire Safety
Inspection
Program (WSIP),
Distribution

There are 685,000 poles located in the HFTD areas and adjacent areas with
structures in close proximity and high risk of fire spread into the adjacent
HFTD.
1) Complete a WSIP enhanced inspection of all 685,000 poles in the HFTD
areas by May 31, 2019, or, for impacted locations, as soon thereafter as is
feasible in light of weather conditions and other external factors.
2) Complete high priority corrective actions created from deficiencies
identified resulting from these enhanced inspections by June 30, 2019, or, for

1) qualified workforce availability; and
2) materials availability for repairs.
Access limitations:
1) inclement weather (snow, rain, wind,
washed out roads, etc.);
2) property owner objections; and
3) Access rights (environmental permits,
government owned land access permits).

                                                       
1

  Numbers in Table 9 are approximated for purposes of presentation in this table.

2

Carding is the process of reviewing aircraft, support equipment and pilots each year to ensure they all meet the Cal Fire contract requirements. The
Federal Government shut down delayed PG&E’s request for a 133 Certificate that is required for the Cal Fire carding and contract.

 

 Case 3:14-cr-00175-WHA Document 1057-1 Filed 04/25/19 Page 3 of 5
 

Section 

4.2.2

Title 

WSIP,
Transmission

Redline of Relevant Changes 
2019 Target 
impacted locations, as soon thereafter as is feasible in light of weather
conditions and other external factors.
There are approximately 50,000 poles and towers (structures) in the HFTD
areas and adjacent areas with structures in close proximity and high risk of fire
spread into the adjacent HFTD.
1) Complete a WSIP enhanced inspection of all 50,000 structures by May 1,
2019, or, for impacted locations, as soon thereafter as is feasible in light of
weather conditions and other external factors. (Approx. 9,377 inspections
were completed in December 2018.)
2) Complete all high priority corrective actions identified during these
inspections by May 31, 2019, or, for impacted locations, as soon thereafter as
is feasible in light of weather conditions and other external factors.

Execution Risk 

1) qualified workforce availability; and
2) materials availability for repairs.
Access limitations:
1) inclement weather (snow, rain, wind,
washed out roads, etc.);
2) property owner objections; and
3) Access rights (environmental permits,
government owned land access permits).
Scheduling Transmission segments out of
service (customer impact and clearance
process) may limit timeliness of repairs.

4.2.3

WSIP, Substation

There are approximately 200 sites located in HFTD areas. These sites include
substations, switching stations, and hydro power houses.

1) qualified workforce availability; and
2) materials availability for repairs.

1) Complete WSIP enhanced inspections for all sites located in HFTD areas
by May 1, 2019.
2) Complete all high priority corrective actions created from deficiencies
identified resulting from these enhanced inspections by May 31, 2019, or, for
impacted locations, as soon thereafter as is feasible in light of weather
conditions and other external factors.
4.4

Vegetation Management

4.4.3

Inspecting Trees
with a Potential
Strike Path to
Power Lines

Assess more than 100 million trees with potential strike path on all routine and
CEMA Patrols

2 

Access limitations due to inclement weather
(snow, rain, wind, washed out roads, etc.)
Scheduling equipment out of service
(customer impact and clearance process) may
limit timeliness of repairs.

 Case 3:14-cr-00175-WHA Document 1057-1 Filed 04/25/19 Page 4 of 5
 

Section 

Redline of Relevant Changes 
2019 Target 

Title 

4.6

Public Safety Power Shutoff Program

4.6.2.2

Resilience Zones

Operationalize one resilience zone as soon as feasible after by June 1, 2019.
Evaluate performance and effectiveness through post-event review.
Incorporate learnings into future Resilience Zone establishment.

Execution Risk 

Reliability of back-up generation equipment.
Delays or trained personnel limitations
associated with construction crew availability.

Continue efforts to develop Resilience Zones in other towns in alignment with
system hardening and targeted sectionalizing efforts.
4.6.4

Re-energization
Strategy

Re-energize only when confirmed safe to do so and only after lines within
areas triggering the PSPS decision all protection zones are patrolled and clear
of defects or damage. PG&E will exercise operational judgment to determine
whether distribution lines in areas that did not experience the PSPS triggering
conditions but were only interrupted because of the de-energization of other
lines should be patrolled. Prioritize as directed to maximize public safety and
minimize outage impacts and duration.

Large scale events.
Extensive facility damage during PSPS event.
Trained and qualified workforce limitations.
Access to difficult terrain. Aerial patrol
limitations.
Concurrent natural disasters in de-energized
areas impacting workforce availability.

 

3 

 Case 3:14-cr-00175-WHA Document 1057-1 Filed 04/25/19 Page 5 of 5
 

CHANGES TO SECTION 6.2.4 – VEGETATION MANAGEMENT TARGETS AND INDICATORS

Redline of Relevant Changes 
Section 6.2.4: Vegetation Management Targets and Indicators
Target #4: Quality Assurance Results in HFTD Areas


Measures the completion results of QA review of EVM and Drought Response Program work performed on electric distribution power line
segments within the HFTD area;



Calculated as a percentage: the number of trees correctly worked to the EVM or Drought and Tree Mortality scope identified during audits
divided by all in-scope trees reviewed through audits;



The target is met by achieving a 92 percent “meets expectations” performance in the QA audits. Given that 2019 will be the first full year of the
EVM program, performing QA review performed on 100 percent of EVM work and reworking Aany trees found to have been through the QA
reviews that were missed or incorrectly worked through the QA reviews will be reworked to meet the relevant program scope.

 

4 

 Case Document 1057-2 Filed 04/25/19 Page 1 of 25

Exhibit 

Case 3:14-cr-00175-WHA Document 1057-2 Filed 04/25/19 Page 2 of 25
 

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)

R.18-10-007
(Issued October 25, 2018)

SECOND AMENDMENT TO
PACIFIC GAS AND ELECTRIC COMPANY’S (U 39 E)
WILDFIRE MITIGATION PLAN

ALYSSA KOO
CHARLES MIDDLEKAUFF
Pacific Gas and Electric Company
77 Beale Street, B30A
San Francisco, CA 94105
Telephone:
(415) 973-3386
Facsimile:
(415) 973-5520
Email:
Alyssa.Koo@pge.com
April 25, 2019

 

Attorneys for
PACIFIC GAS AND ELECTRIC COMPANY

 Case 3:14-cr-00175-WHA Document 1057-2 Filed 04/25/19 Page 3 of 25
 
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).

R.18-10-007
(Issued October 25, 2018)

SECOND AMENDMENT TO
PACIFIC GAS AND ELECTRIC COMPANY’S (U 39 E)
WILDFIRE MITIGATION PLAN
Pacific Gas and Electric Company (PG&E) hereby provides notice that pursuant to Rule
1.12 of the Rules of Practice and Procedure of the California Public Utilities Commission
(Commission or CPUC), PG&E is modifying its Wildfire Safety Plan (Plan), filed February 6,
2019, corrected February 12, and amended February 14, 2019.
The amendments to the Plan reflect clarifications, improvements, and limited revisions to
targets to address specific external conditions that PG&E has encountered in its implementation
of the Plan. While PG&E has made significant progress towards achieving the targets set forth
in the Plan, it nonetheless needs to revise certain targets due to external factors such as the
extended federal government shutdown, weather, access challenges, and permitting/
environmental restrictions that will likely prevent PG&E from meeting some targets on the
projected timeline. PG&E is also enhancing several procedures based on early learnings, which
will result in some modifications to Plan targets. In addition, PG&E is clarifying a few targets to
avoid the potential for misinterpretation, notifying the Commission and parties of expected cost
increases for two programs, and correcting minor errors in Attachment E to its Plan. PG&E is
submitting its Second Amendment at this time so that the Commission has the most up-to-date
information to review and consider before issuing its final decision on the Plan. Should other
factors or conditions change, PG&E will update the Commission in a timely and appropriate
manner.
1

 Case 3:14-cr-00175-WHA Document 1057-2 Filed 04/25/19 Page 4 of 25
 

I.

STATUS UPDATE
PG&E developed its Plan to implement aggressive and innovative measures to reduce

the risk of wildfires in its service territory. The Plan provides considerable detail about what
PG&E proposes to do in 2019 in advance of the wildfire season, during the wildfire season, and
in subsequent years to reduce the risk of wildfires. The Plan reflects a mobilization and
organization of extensive workforces in multiple areas of PG&E’s electric business, including
operations; system hardening; overhead distribution, transmission, and substation inspections
and corrective actions; vegetation management; situational awareness; and proactive deenergization. The objective of PG&E’s Plan is straightforward – to act with urgency to prevent
electrical lines and equipment from causing wildfires that have the potential to become
catastrophic wildfires. To accomplish this objective, PG&E proposed in Tables 1 and 9 of the
Plan specific targets that were tangible, quantifiable, and auditable; reflecting substantial
increases of work over prior years on an ambitious timeline.
PG&E started working on many of these programs in 2018 and has made considerable
progress since that time. As of mid-April, PG&E has automated over 80% of the targeted line
reclosers and is approximately 40% and 70% complete on its mid-year (i.e., June 30th) targets for
weather stations and cameras, respectively.1 PG&E’s Wildfire Safety Inspection Program
(WSIP) teams have completed visual and climbing inspections by qualified electrical workers of
more than 95% of the total transmission structures included in the scope of the Plan (over 45,000
transmission structures); inspections of approximately 70% of the substations (152 substations);
and inspections of 45% of the distribution poles (over 300,000 poles). The teams have also
identified and resolved over 900 high priority corrective actions2 identified during the
inspections. The system hardening team has completed or has in progress approximately 95% of
the 2019 design and estimating work and has completed or is in the process of completing
1

With regard to its 2019 end of year targets for weather stations and cameras, PG&E has installed over
15% of the weather stations and 20% of the cameras.

2

PG&E defines high priority corrective actions as A and B tags.

2

 Case 3:14-cr-00175-WHA Document 1057-2 Filed 04/25/19 Page 5 of 25
 

approximately 25% of the 2019 system hardening work. The Enhanced Vegetation Management
(EVM) team has completed inspections and necessary tree work (subject to quality review) on
over 25% of 2019 targeted miles to date, with another approximately 25% of the 2019 miles
inspected and ready to be worked. The Public Safety Power Shutoff (PSPS) team is working to
finalize the 2019 PSPS training while collaborating with external parties to prepare for the 2019
wildfire season. PG&E has evaluated the outstanding 2019 work in light of this progress and
lessons learned to date to make modifications, so the Plan that is ultimately approved reflects the
most current information available, as well as what is feasible and achievable.
Other than the targets revised in this amendment, PG&E currently expects and is
planning to achieve the remaining targets. However, while PG&E has prepared contingency
plans and mitigations to address potential challenges, the Plan proposes the completion of work
at an unprecedented scale and speed. In developing the Plan, PG&E recognized that there were
significant execution risks, arising from sources both external and internal to PG&E, to
accomplishing the expanded and accelerated scope of planned work. These challenges, outlined
in Table 9 of the Plan, include inclement weather, the availability of equipment, materials, and
qualified personnel, and legal/regulatory issues (e.g., objections from property owners or
governmental agencies, and environmental permitting requirements), which could impact the
timing and scope of the programs proposed in the Plan.3
As PG&E implements these ambitious goals, these challenges persist. For example, both
the WSIP inspections and EVM program apply heightened criteria compared to historical routine
work. As a result, PG&E is identifying greater numbers of necessary actions, which require
additional resources. PG&E has hired and will continue to hire the qualified resources necessary
to complete this work safely and with a high standard of quality, and PG&E will continue to
assess and fine-tune the needs of these new programs as PG&E learns through executing the
Plan. Likewise, PG&E’s land and environmental management, external affairs, and customer

3

PG&E Plan at p. 2, see also Table 9 at pp. 39-46 (identifying the major risks for each target).

3

 Case 3:14-cr-00175-WHA Document 1057-2 Filed 04/25/19 Page 6 of 25
 

care teams are working closely with PG&E’s work execution teams to reduce potential delays
caused by property owners, governmental agencies, and environmental permitting requirements.
Nonetheless these challenges still present a risk of delay.
Other unexpected and unavoidable challenges will likely also arise as PG&E continues to
execute the Plan. For example, weather stations and high definition cameras cannot be installed
and properly calibrated during inclement weather. While PG&E currently has a plan to achieve
the 2019 targets, inclement weather in the first quarter of the year has resulted in initial delays
from which PG&E is currently working diligently to recover, and future unforeseen weather
conditions could further impact the schedule.
PG&E’s WSIP program similarly faces risks that certain repairs cannot be completed on
the identified timeline. PG&E has completed just under half of the required distribution pole
inspections, which have had a relatively low percentage of high priority corrective actions.
While PG&E currently expects to complete the repairs on schedule, it is possible that there will
be a significantly higher percentage of high priority corrective actions resulting from the
remaining inspections. This could jeopardize the schedule. Corrective actions from transmission
drone inspections face similar uncertainties as inspections for nearly half of the transmission
structures are currently in progress (described below). As discussed above, PG&E continues to
evaluate risks and develop contingency plans related to the resources necessary to complete all of
the work safely and to high quality standards.
As noted in the Plan, programs (including system hardening and vegetation management
work) may also face delays from environmental permitting requirements, the need to obtain
additional land rights, or community protests. Local governmental permits can also cause
delays. For example, many municipalities have adopted heritage tree ordinances that prohibit the
removal of specified tree species or require a permit. Although local land use restrictions do not

4

 Case 3:14-cr-00175-WHA Document 1057-2 Filed 04/25/19 Page 7 of 25
 
apply to CPUC-regulated work by investor-owned utilities,4 private citizens nonetheless
frequently protest the work. PG&E works closely with local governments to explain existing
law regarding the Commission’s jurisdiction and attempts to address local concerns about its
proposed work authorized or required by the Commission. However, disputes over the
applicability of local ordinances have resulted in litigation and delays in other safety-related
work.
While PG&E cannot predict whether these additional risks will arise, we are committed
to keeping the Commission informed of our progress and any delays we encounter. PG&E will
seek assistance from the Federal Monitor to address these challenges, where necessary. The
amendments outlined in this filing address only the specific factors and learnings that have
already arisen and are impacting the original targets.
II.

OVERVIEW OF FACTORS PRECIPITATING SECOND AMENDMENT
PG&E is amending its Plan in three respects: To address external conditions that will

likely prevent full completion of the targets by the original target dates; to modify targets to
allow for improvements to the original Plan from lessons learned; and to clarify ambiguous
language that may be subject to misinterpretation.
External execution risks identified in the Plan have resulted in delays. Although PG&E
initiated the process to obtain the Federal Aviation Administration (FAA) certification required
by CAL FIRE to use PG&E’s helicopters in July 2018, the abnormally long government

4

See, e.g., Cal. Const., art. XII, §§ 5, 8 (granting the Legislature “plenary power” to confer on the
Commission jurisdiction to regulate public utilities and prohibiting a city, county or other public body
from regulating matters within the regulatory authority of public utilities); Cal. Pub. Util. Code, § 701
(Commission may “do all things . . . necessary and convenient” to supervise and regulate public utilities);
CPUC General Order 131-D, § XIV (local jurisdictions are preempted from regulating public utility
projects subject to the Commission’s authority); San Diego Gas & Electric Co. v. City of Carlsbad, 64
Cal. App. 4th 785, 796, 801-802 (1998) (preemption over local authority occurs regardless of whether the
Commission has expressly exercised this power); Sarale v. Pacific Gas & Electric Co., 189 Cal. App. 4th
225, 232 (2010) (utility vegetation management programs fall within the exclusive jurisdiction of the
Commission, safeguarding “the commission's ability to implement statewide safety protocols from being
undermined by an unworkable patchwork of conflicting determinations regarding what constitutes
necessary or proper management of power lines.").

5

 Case 3:14-cr-00175-WHA Document 1057-2 Filed 04/25/19 Page 8 of 25
 

shutdown in late 2018 and early 2019 delayed issuance of the certification. In addition,
unusually heavy snowfall and storms have prevented PG&E crews from accessing, inspecting,
and repairing a small percentage of distribution and transmission poles and towers under the
WSIP program. Likewise, despite PG&E’s proactive outreach, land owner refusals and
environmental permitting challenges threaten PG&E’s ability to complete a small percentage of
WSIP corrective actions. While PG&E continues to find creative solutions to these challenges,
these external execution risks will likely prevent PG&E from completing some components of
the Plan on the projected timeline. As a result, PG&E is amending the Plan to allow for
necessary extensions of time.
In addition, PG&E is amending the Plan to incorporate enhancements identified as a
result of improved strategies. As explained in the Plan, PG&E will continuously evolve the Plan
to incorporate new information, experience, and input from communities, first responders,
regulators, and others on how best to prevent wildfires and improve the overall safety of its
system.5 As previously noted by several parties, this flexibility is critical to allow continuous
improvements to the Plan, especially in this early stage of the process. For example, after
beginning construction of the first pilot Resilience Zone, PG&E made improvements to the
design to improve risk reduction. This design change requires PG&E to obtain additional land
rights, which may delay the completion of construction of the Resilience Zone. In addition,
PG&E has further enhanced the EVM program with more objective criteria to enable more
consistent Quality Assurance (QA) audits. As described in more detail below, in recognition of
these enhancements, PG&E proposes to amend targets in the Plan to incorporate these
enhancements.
Finally, this amendment clarifies targets to avoid any ambiguity about what is required to
comply with the target. First, PG&E clarifies the Vegetation Management inspection program
target to indicate that, while over 100 million trees will be assessed as explained in the Plan, only

5

PG&E Plan at pp. 6-7.

6

 Case 3:14-cr-00175-WHA Document 1057-2 Filed 04/25/19 Page 9 of 25
 

those trees needing work will be documented in PG&E’s vegetation management database.
Second, PG&E clarifies that PG&E will patrol all lines that were identified as meeting PSPS deenergization criteria before re-energizing following a PSPS event and will exercise operational
judgment to determine whether to patrol lines that were only interrupted as a secondary effect of
the de-energization of other lines.
As explained below, the amendments to the Plan reflect clarifications, improvements, or
limited modifications to targets that are consistent with the execution risks PG&E previously
identified in its Plan.6 More specifically the amendments:


Revise the timeline the helicopters will be available for CAL FIRE’s use to
accommodate the delay due to the government shutdown;



Extend the WSIP inspection and repair schedule for impacted locations to
accommodate restrictions presented by external factors such as weather, access
challenges, and permitting/environmental requirements;



Modify the completion timeline to have the pilot resilience zone operational to
allow for a design change for additional risk reduction;



Modify a vegetation management QA target to adapt to more objective vegetation
management inspection procedures developed through implementation of the
Plan;



Clarify potentially ambiguous language in the description of vegetation
management and PSPS targets; and



6

Correct inadvertent errors in Attachment E to the Plan.7

See, e.g., PG&E Plan at p. 132-33.

7

As described in the Plan, PG&E may need to make additional adjustments in the future to address
evolving conditions and incorporate learnings from these innovative and new programs.

7

 Case 3:14-cr-00175-WHA Document 1057-2 Filed 04/25/19 Page 10 of 25
 

III.

DESCRIPTION OF AMENDMENTS
A. Changes Required by External Execution Risks
1. Aviation Resources

In its Plan, PG&E proposed to have four heavy-lift helicopters operational and available
for use by CAL FIRE to aid in fire suppression by May 2019. The helicopters will be
operational by May 1, 2019, but CAL FIRE also requires a certification from the FAA to use
contract helicopters. PG&E initiated its certification request to the FAA in July 2018, well in
advance of the May 1, 2019 deadline. However, the unusually long federal government
shutdown delayed review of PG&E’s request for the certification. When PG&E filed the Plan in
February, it believed that the government shutdown would cause only a minimal delay in receipt
of the certification.8 Unfortunately, the FAA has indicated that the governmental shutdown will
delay issuance of the certification until mid-June 2019, at the earliest. PG&E has reached out
through multiple paths to seek to expedite the FAA’s review, but to date has been unable to
secure a commitment to an earlier date. As a result, PG&E is adjusting this goal to reflect that
the helicopters will be available for CAL FIRE use as soon as feasible after receipt of the needed
FAA certification and modifying the Aviation Resources target set forth in Table 9 of the Plan as
follows:

Section 

Title 

2019 Target 

Execution Risk 

Operate four heavy-lift
helicopters to aid in fire
suppression and restoration
efforts by May 2019, available
at CALFIRE’s discretion as
soon as feasible after receipt
of the necessary FAA
certification.

Delays securing
CALFIRE carding by
May 2019.9

Included in 
FPP 

Operational Practices 
4.1.4

8

Aviation Resources

No

PG&E Plan at p. 39 n. 35.

9

Carding is the process of reviewing aircraft, support equipment and pilots each year to ensure they all
meet the Cal Fire contract requirements. The Federal Government shut down delayed PG&E’s request
for a 133 Certificate that is required for the Cal Fire carding and contract.

8

 Case 3:14-cr-00175-WHA Document 1057-2 Filed 04/25/19 Page 11 of 25
 

2. WSIP Inspections

For PG&E’s WSIP, the Plan target for all distribution and transmission overhead
structures inspections within the high fire threat district (HFTD) areas (and adjacent areas) is
May 31, 2019 and May 1, 2019, respectively. Given the urgent need to address wildfire risk,
these were aggressive goals representing a substantial increase over routine annual inspections
and presenting a major organizational and planning challenge to mobilize the crews, equipment,
and sites, and coordinate with third parties. Nonetheless, PG&E is working to complete more
than 95% of the visual ground and climbing inspections by the original deadlines.
As mentioned in the Plan, in addition to work-force and other challenges that PG&E
currently believes have been addressed, “implementation of the WSIP can be further delayed by
weather conditions, delays caused by property owners and governmental agencies, and
environmental permitting issues.”10 While PG&E’s land management, external affairs, and
customer care teams have actively worked to overcome these challenges, there are some external
execution risks that persist and may prevent PG&E from conducting enhanced inspections of all
overhead facilities within the HFTD by the original completion dates.
A primary external obstacle is the wet winter that Northern California has experienced.
The 2018-2019 winter has been unusually wet with heavy snow load, including at lower
elevations. According to the California Department of Water Resources, snowpack was 165% of
the statewide average as of April 18, 2019.11 Affected areas within PG&E’s HFTD areas range
from 172% of normal in the north, 165% of normal for the central Sierra, and 153% of normal
for the southern Sierra. Data tracked by PG&E’s Meteorology Department indicates that through
March 31, 2019, the 2018-2019 winter season is among the wettest since 1995, with the second
highest amount of snow at low elevations, third highest amount of winter storm days, fourth
highest amount of weather impacted days, and sixth highest heavy rain days.

10

PG&E Plan at p. 55.

11

See http://cdec.water.ca.gov/reportapp/javareports?name=DLYSWEQ

9

 Case 3:14-cr-00175-WHA Document 1057-2 Filed 04/25/19 Page 12 of 25
 

As a result of these weather patterns, a population of less than 5% of distribution and
transmission structures have been and continue to be inaccessible to visual ground and climbing
inspections, either because the footings of the structures are covered in snow or the heavy
moisture has made access infeasible. In some cases, storms have washed away access roads,
making them unsafe or impassable. Fortunately, structures that are inaccessible due to these
weather conditions do not pose a fire risk at this time because of the wet conditions (e.g., snow
on the ground). Notwithstanding these access limitations, PG&E will strive to inspect these
structures through visual ground, visual climbing, drone imagery, or helicopter imagery by May
31 (for distribution) or May 1 (for transmission), as conditions permit. This will allow for
identification of conditions requiring corrective actions and will reduce the potential wildfire
ignition risk until a full enhanced inspection can be performed, once access is possible.
Unfortunately, it is impossible to predict when the snowpack will melt or when access roads will
become passable; the WSIP team will complete these inspections as soon as practicable once the
restrictions pass.
The unusually stormy weather thus far in 2019 has also hindered drone inspections,
which PG&E planned to conduct on every transmission structure in the WSIP scope (subject to
any FAA restrictions that cannot be resolved) to complement visual ground and visual climbing
inspections.12 This is an innovative use of drones, and PG&E is learning from its experiences
with these inspections. PG&E has nearly every available qualified drone and drone operator in
the western United States working on the Plan, but FAA regulations prohibit flying drones in
inclement weather (e.g., winds above 25 knots). Northern California’s stormy weather (snow,
rain, heavy winds, etc.) has restricted PG&E’s ability to perform drone inspections on the same
timeline as the ground and climbing inspections. As a result, about 50% of the transmission
structures drone inspections will be completed after May 1, 2019.

12

PG&E Plan at p. 57.

10

 Case 3:14-cr-00175-WHA Document 1057-2 Filed 04/25/19 Page 13 of 25
 

In addition to weather-related restrictions, the WSIP distribution and transmission
inspections may be delayed due to property owner objections and governmental permit or
environmental requirements, any of which could impede the ability of PG&E’s crews to enter
onto certain properties.
PG&E believes it will complete at least one form of inspection (ground, climbing, drone,
or helicopter) on each distribution pole by May 31 and each transmission structure by May 1,
subject to delays caused by the external risk factors impacting a limited population of facilities,
discussed above. To adjust the Plan in recognition of these external challenges, PG&E modifies
the May 31, 2019 and May 1, 2019 targets for the WSIP inspections of overhead distribution and
transmission structures to allow for delays resulting from weather and other external factors.
The specific changes to the targets set forth in Table 9 are:13
///
///
///
///

13

This chart includes proposed modifications to the WSIP corrective action targets explained in the next
section.

11

 Case 3:14-cr-00175-WHA Document 1057-2 Filed 04/25/19 Page 14 of 25
 

Section 

Title 

2019 Target 

Execution Risk 

There are 685,000 poles
located in the HFTD areas
and adjacent areas with
structures in close proximity
and high risk of fire spread
into the adjacent HFTD.

1) qualified workforce
availability; and

1) Complete a WSIP
enhanced inspection of all
685,000 poles in the HFTD
areas by May 31, 2019, or, for
impacted locations, as soon
thereafter as is feasible in light
of weather conditions and
other external factors.

1) inclement weather
(snow, rain, wind, washed
out roads, etc.);

Included in 
FPP 

Wildfire Safety Inspections Programs
4.2.1

Wildfire Safety Inspection
Program (WSIP),
Distribution

2) Complete high priority
corrective actions created
from deficiencies identified
resulting from these enhanced
inspections by June 30, 2019,
or, for impacted locations, as
soon thereafter as is feasible
in light of weather conditions
and other external factors.
4.2.2

WSIP, Transmission

There are approximately
50,000 poles and towers
(structures) in the HFTD areas
and adjacent areas with
structures in close proximity
and high risk of fire spread
into the adjacent HFTD.
1) Complete a WSIP
enhanced inspection of all
50,000 structures by May 1,
2019, or, for impacted
locations, as soon thereafter
as is feasible in light of
weather conditions and other
external factors. (Approx.
9,377 inspections were
completed in December
2018.)
2) Complete all high priority
corrective actions identified
during these inspections by
May 31, 2019, or, for
impacted locations, as soon
thereafter as is feasible in light
of weather conditions and
other external factors.

12

2) materials availability
for repairs.

Current
program
scope not
included

Access limitations:

2) property owner
objections; and
3) Access rights
(environmental permits,
government owned land
access permits).

1) qualified workforce
availability; and
2) materials availability
for repairs.
Access limitations:
1) inclement weather
(snow, rain, wind, washed
out roads, etc.);
2) property owner
objections; and
3) Access rights
(environmental permits,
government owned land
access permits).
Scheduling Transmission
segments out of service
(customer impact and
clearance process) may
limit timeliness of repairs.

Current
program
scope not
included

 Case 3:14-cr-00175-WHA Document 1057-2 Filed 04/25/19 Page 15 of 25
 

3. WSIP Corrective Actions

The Plan also includes aggressive WSIP targets to complete all high priority corrective
actions on the distribution, transmission, and substation structures resulting from the WSIP
inspections by June 30, 2019 for distribution and May 31, 2019 for transmission and substation.
PG&E is working to achieve these goals and overcome internal challenges, including by hiring
additional qualified crews and inspectors and evaluating each program to maximize efficiency.
As explained in the Plan, corrective actions resulting from inspections are prioritized
based on the risk posed by the condition and the urgency of repairs.14 Subject to unanticipated
and unavoidable risks discussed above, PG&E expects to complete all A tags (the highest
priority) and nearly all of the B tags on the timeline outlined in the Plan. However, external
factors will likely prevent PG&E from completing all B tags on schedule. These external factors
include the same access issues that delay WSIP Inspections, described above. Further, in some
cases, the timeline of the visual and drone inspections due to weather will result in delayed
identification of the B tags, which in turn will delay the completion of the needed repairs beyond
the target date. In addition, governmental permitting and environmental restrictions and the need
to schedule clearances with external parties may further impede completing corrective actions on
transmission and substation assets.
As a result of these external challenges, PG&E is modifying the June 30, 2019 and May
31, 2019 targets for completion of high priority corrective actions for WSIP distribution,
transmission, and substation to allow for delays resulting from weather and other external
factors, including inspections delayed due to external factors. The extension of the target dates is
consistent with the basis for extensions allowed by CPUC General Order 95, Rule 18, for these
corrective actions. The specific changes to the targets set forth in Table 9 are:15

14

PG&E Plan at p. 54.

15

This chart includes modifications for WSIP inspections discussed above.

13

 Case 3:14-cr-00175-WHA Document 1057-2 Filed 04/25/19 Page 16 of 25
 

Section 

Title 

2019 Target 

Execution Risk 

There are 685,000 poles
located in the HFTD areas
and adjacent areas with
structures in close proximity
and high risk of fire spread
into the adjacent HFTD.

1) qualified workforce
availability; and

1) Complete a WSIP
enhanced inspection of all
685,000 poles in the HFTD
areas by May 31, 2019, or, for
impacted locations, as soon
thereafter as is feasible in light
of weather conditions and
other external factors.

1) inclement weather
(snow, rain, wind, washed
out roads, etc.);

Included in 
FPP 

Wildfire Safety Inspections Programs
4.2.1

Wildfire Safety Inspection
Program (WSIP),
Distribution

2) Complete high priority
corrective actions created
from deficiencies identified
resulting from these enhanced
inspections by June 30, 2019,
or, for impacted locations, as
soon thereafter as is feasible
in light of weather conditions
and other external factors.
4.2.2

WSIP, Transmission

There are approximately
50,000 poles and towers
(structures) in the HFTD areas
and adjacent areas with
structures in close proximity
and high risk of fire spread
into the adjacent HFTD.
1) Complete a WSIP
enhanced inspection of all
50,000 structures by May 1,
2019, or, for impacted
locations, as soon thereafter
as is feasible in light of
weather conditions and other
external factors. (Approx.
9,377 inspections were
completed in December
2018.)
2) Complete all high priority
corrective actions identified
during these inspections by
May 31, 2019, or, for
impacted locations, as soon
thereafter as is feasible in light
of weather conditions and
other external factors.

14

2) materials availability
for repairs.

Current
program
scope not
included

Access limitations:

2) property owner
objections; and
3) Access rights
(environmental permits,
government owned land
access permits).

1) qualified workforce
availability; and
2) materials availability
for repairs.
Access limitations:
1) inclement weather
(snow, rain, wind, washed
out roads, etc.);
2) property owner
objections; and
3) Access rights
(environmental permits,
government owned land
access permits).
Scheduling Transmission
segments out of service
(customer impact and
clearance process) may
limit timeliness of repairs.

Current
program
scope not
included

 Case 3:14-cr-00175-WHA Document 1057-2 Filed 04/25/19 Page 17 of 25
 
4.2.3

WSIP, Substation

There are approximately
200 sites located in HFTD
areas. These sites include
substations, switching stations,
and hydro power houses.
1) Complete WSIP enhanced
inspections for all sites located
in HFTD areas by May 1,
2019.
2) Complete all high priority
corrective actions created from
deficiencies identified resulting
from these enhanced
inspections by May 31, 2019,
or, for impacted locations, as
soon thereafter as is feasible
in light of weather conditions
and other external factors.

1) qualified workforce
availability; and
2) materials availability
for repairs.

Current
program
scope not
included

Access limitations due to
inclement weather
(snow, rain, wind,
washed out roads, etc.)
Scheduling equipment
out of service (customer
impact and clearance
process) may limit
timeliness of repairs.

4. SCADA Enabling

The Plan includes a target to SCADA-enable line reclosers within Tier 2 and Tier 3
HFTD areas by June 1, 2019. To SCADA-enable line reclosers, crews generally must modify or
install new equipment on the structures in the field. The same weather-related conditions and
government permit requirements impeding WSIP inspections are hindering PG&E crews from
accessing approximately five line reclosers. To adjust the Plan in recognition of these external
challenges, PG&E is modifying the target to SCADA-enable line reclosers to allow exemptions
to the June 1, 2019 deadline for delays resulting from weather and other external factors only.
The specific changes to the target set forth in Table 9 are:
///
///
///

15

 Case 3:14-cr-00175-WHA Document 1057-2 Filed 04/25/19 Page 18 of 25
 
Section 

Title 

2019 Target 

Execution Risk 

Included in FPP 

Operational Practices 
4.1.1

Recloser Operations

SCADA enable all remaining
line reclosers (approximately
285) in Tier 2 and Tier 3
HFTD areas by June 1, 2019,
or, for impacted locations, as
soon thereafter as is feasible
in light of weather conditions
and other external factors.

Qualified personnel or
material limitations.

No

Design, estimating or
construction delays.

Disable any remaining manual
reclosing devices in advance
of exposure to elevated
wildfire risk conditions.
Daily operations conformance
with TD-1464B-001 and
monitor program for
effectiveness.

B. Modifications Due to Lessons Learned
1. Resilience Zones

In the Plan, PG&E proposed having its first, pilot resilience zone operational by June 1,
2019, so it would be available to provide power during the 2019 wildfire season in the event of a
PSPS event. The resilience zone is designed to be quickly isolated from the broader electric grid
when a PSPS is initiated and to receive power from temporary mobile generation connected to a
new pre-installed interconnection hub (PIH). PG&E initially designed the resilience zone to
include segments of new, hardened overhead equipment including more resilient poles (e.g.,
composite, steel) and covered wire, as well as underground distribution lines.
As resilience zones are an innovative concept and this is PG&E’s first resilience zone, a
primary objective of this pilot is to assess and implement the most operationally effective design
to maximize risk reduction. After evaluating the specific circumstances of the location, extent of
facilities, and planned use of the resilience zone, PG&E recently modified the resilience zone
design strategy to underground the majority of the resilience zone distribution conductors, and
use new, hardened overhead systems only over hardscapes or where there is minimal to no
vegetation-related risk. A new scope was added to the project to convert the majority of the
existing wire on wood poles to underground distribution lines.

16

 Case 3:14-cr-00175-WHA Document 1057-2 Filed 04/25/19 Page 19 of 25
 

As a result of the design change, PG&E needs to obtain additional land rights from third
parties and to satisfy environmental and other requirements.16 PG&E is actively seeking to
obtain the additional necessary land rights on an expedited timeline to complete the resilience
zone by June 1. However, because the change in strategy could delay the operational readiness
of the resilience zone, out of an abundance of caution PG&E modifies the target to operationalize
the first pilot resilience zone from June 1, 2019, to “as soon as feasible after June 1, 2019.” The
specific changes to the targets set forth in Table 9 are:
Section 

Title 

2019 Target 

4.6

Public Safety Power Shutoff Program

4.6.2.2

Resilience Zones

Operationalize one resilience
zone as soon as feasible after
by June 1, 2019. Evaluate
performance and
effectiveness through
post-event review.
Incorporate learnings into
future Resilience Zone
establishment.

Execution Risk 

Included in FPP 

Reliability of back-up
generation equipment.

No

Delays or trained
personnel limitations
associated with
construction crew
availability.

Continue efforts to develop
Resilience Zones in other
towns in alignment with
system hardening and
targeted sectionalizing efforts.

2. Vegetation Management – Inspection QC/QA

In Section 6.2.4 of the Plan, PG&E proposed several targets for the EVM program. To
ensure that the EVM work is performed accurately, one of the EVM program targets (Target #4)
measuring the results of the QA audits of the EVM work, stated that the target would be met
where QA inspectors find that at least 92% of the trees audited were correctly worked. All work
that failed the audit would be re-inspected and addressed. Because this is the first full year of the
EVM program, PG&E is performing QA audits on 100% of EVM work.17

16

The PIH, the novel equipment that will enable PG&E to energize this grid segment during a broader
PSPS event, remains on schedule for completion.

17

In future years as the program matures and the crews become more experienced, the program may rely
on a QA sampling methodology, as is common with other programs.

17

 Case 3:14-cr-00175-WHA Document 1057-2 Filed 04/25/19 Page 20 of 25
 

As PG&E inspectors began auditing EVM work, PG&E realized there was a fundamental
challenge to performing objective QA audits of the EVM program. In evaluating certain highrisk trees with a potential strike path to power lines, the EVM procedures expected tree
inspectors to exercise professional judgment in deciding whether to remove trees meeting certain
criteria (e.g., species, height, distance, lean). During the audits, however, QA inspectors
exercising their own professional judgment disagreed with the initial assessment made by tree
inspectors approximately 50% of the time. To address this issue, PG&E has eliminated this
subjectivity from the decision-making process for both inspectors and QA auditors: Trees
meeting the objective criteria will be removed.18
PG&E proposes to modify Target #4 to require QA audits on 100% of the EVM work
and to require the reworking of any trees that meet certain objective criteria (species, height,
distance, lean). The specific changes to the Target #4 set forth in Section 6.2.4 of the Plan are:
Section 6.2.4: Vegetation Management Targets and Indicators
Target #4: Quality Assurance Results in HFTD Areas


Measures the completion results of QA review of EVM and Drought Response
Program work performed on electric distribution power line segments within the
HFTD area;



Calculated as a percentage: the number of trees correctly worked to the EVM or
Drought and Tree Mortality scope identified during audits divided by all in-scope trees
reviewed through audits;



The target is met by achieving a 92 percent “meets expectations” performance in the
QA audits. Given that 2019 will be the first full year of the EVM program, performing
QA review performed on 100 percent of EVM work and reworking Aany trees found

18

The subjectivity of the original procedures did not affect wildfire risk, because all work undergoes QA
audits, and all trees identified as requiring additional work through the QA audit were re-inspected and
worked according to the enhanced objective criteria.

18

 Case 3:14-cr-00175-WHA Document 1057-2 Filed 04/25/19 Page 21 of 25
 
to have been through the QA reviews that were missed or incorrectly worked through
the QA reviews will be reworked to meet the relevant program scope.

C. Clarifications to Avoid Misinterpretations
1. Enhanced Vegetation Management - Inspection coverage

In the Plan, PG&E states that all vegetation management patrols will assess all trees that
are tall enough and have a feasible path to strike overhead lines. In Table 9 of the Plan, which
summarized the targets, PG&E stated that this assessment meant that PG&E would “[a]ssess
more than 100 million trees with potential strike path.”19 While PG&E intends to achieve this
target, PG&E inspectors do not document all trees assessed on patrols. Vegetation management
inspectors patrol an overhead line, inspect the appropriate trees and vegetation, and note only
those trees that will require work. The inspectors do not record every tree assessed or examined.
Creating a record of trees not needing work at a particular point in time is time-consuming and
contrary to industry practice. Documenting the significant volume of trees not requiring work,
likely approaching or exceeding 100 million trees, would also substantially delay the inspection
process. To avoid any potential misinterpretation of the target stated in the Plan, PG&E is
clarifying the target to indicate that trees with potential strike paths along patrol routes will be
inspected, and only trees needing work will be recorded in PG&E’s database. The specific
changes to the targets set forth in Table 9 are:
Section 

Title 

4.4

Vegetation Management

4.4.3

Inspecting Trees with a
Potential Strike Path to
Power Lines

19

2019 Target 

Execution Risk 

Assess more than 100 million
trees with potential strike path
on all routine and CEMA
Patrols

PG&E Plan, Table 9, at p. 42.

19

Included in FPP 

Current
program scope
not included

 Case 3:14-cr-00175-WHA Document 1057-2 Filed 04/25/19 Page 22 of 25
 

2. PSPS – Re-energization

In the Plan, PG&E explains that it will only restore power following a PSPS event after
confirming that it is safe to do so. PG&E continues to uphold that standard. However, the Plan
elaborates on that standard by stating it will include patrolling all facilities or “protection zones”
before re-energization.20 This language arose from PG&E’s PSPS program as implemented in
2018 and recognizes that PG&E would only re-energize after patrolling lines in the HFTD areas
subject to the PSPS event to ensure re-energization did not pose a safety threat.
Since then, PG&E has expanded the scope of the PSPS program to include high voltage
transmission lines. If these high voltage transmission lines are de-energized during a PSPS
event, the interconnected nature of the grid could result in a cascading effect that causes other
transmission lines and distribution lines – potentially far from the original fire-risk areas – to be
de-energized. Thus, distribution lines far from HFTD areas that triggered the PSPS event, but
which rely on the de-energized lines for power, such as lines in cities like San Francisco or San
Jose, could be de-energized. San Francisco is not in a HFTD areas and is highly unlikely to
experience the kind of climate and weather conditions that would trigger a PSPS event. Nor
does San Francisco present wildfire risk. But San Francisco could possibly be de-energized if
multiple East Bay transmission lines were to be de-energized due to extreme conditions.
The Plan did not intend to require patrol of lines far from the at-risk areas after a PSPS
event. Rather than include those lines in a blanket mandate to patrol before re-energization,
PG&E will exercise operational judgment to determine if lines de-energized due to the
interconnected nature of the grid, and not due to their wildfire risk potential, need to be patrolled
before re-energization.
PG&E thus clarifies the re-energization requirement to state that PG&E will patrol all
lines in areas identified as meeting the PSPS de-energization criteria, but will exercise
operational judgment consistent with standard utility industry practices to determine whether

20

PG&E Plan, Table 9, at p. 44; and p. 109.

20

 Case 3:14-cr-00175-WHA Document 1057-2 Filed 04/25/19 Page 23 of 25
 

lines in areas that were only interrupted because of the de-energization of other lines should be
patrolled. The specific changes to the targets set forth in Table 9 are:
Section 

Title 

4.6

Public Safety Power Shutoff Program
Re-energize only when
Re-energization Strategy
confirmed safe to do so and
only after lines within areas
triggering the PSPS decision
all protection zones are
patrolled and clear of defects
or damage. PG&E will
exercise operational judgment
to determine whether
distribution lines in areas that
did not experience the PSPS
triggering conditions but were
only interrupted because of
the de-energization of other
lines should be patrolled.
Prioritize as directed to
maximize public safety and
minimize outage impacts and
duration.

4.6.4

2019 Target 

Execution Risk 

Included in FPP 

Large scale events.

No

Extensive facility
damage during PSPS
event.
Trained and qualified
workforce limitations.
Access to difficult
terrain. Aerial patrol
limitations.
Concurrent natural
disasters in deenergized areas
impacting workforce
availability.

D. Corrections to Attachment E
Forecast costs to complete the Plan also continue to evolve. When PG&E submitted the
Plan, PG&E provided initial costs estimates for each program in Attachment E. In Section 7,
PG&E highlighted a number of key drivers of uncertainty for those cost estimates, cautioning
that actual costs may vary substantially depending on actual conditions and requirements.21 As
PG&E has implemented the Plan, these uncertainties around the cost estimates persist. In
particular, PG&E has become aware of likely increases in the cost estimates for two of the Plan
programs: WSIP and PSPS – Sectionalizing. While PG&E is not prepared with updated cost
estimates to amend cost estimates in Attachment E at this time, PG&E wants to notify the
Commission and parties of these expected cost increases. Based on the current status of the
WSIP program, and in light of the corrective actions that need to be taken, unit costs (e.g.,
contractors, drones), and the resource mix (internal vs. contractors), PG&E is currently
estimating forecast WSIP costs to substantially increase. PG&E also predicts the PSPS
21

PG&E Plan at p. 141.

21

 Case 3:14-cr-00175-WHA Document 1057-2 Filed 04/25/19 Page 24 of 25
 

sectionalizing program cost estimate to increase due to a planned expanded scope of work for
2019 and increased unit costs.
This Second Amendment also corrects several minor errors in Attachment E, which
PG&E had previously identified on March 19, 2019, in its response to Question 1 of the Safety
and Enforcement Division’s third set of data requests, as follows:
1.

PG&E inadvertently omitted two categories of system hardening costs from
Attachment E, which costs were included in PG&E’s 2020 General Rate Case (GRC).
a. Approximately $5,200,000 of fuse replacement capital costs: Including these
costs in Attachment E increases the forecast system hardening (pole, pole
loading and replacement (distribution), and conductor) program costs from
approximately $236,900,000 to approximately $242,100,000. The number for
the cell at Row labeled 4.3.1 and Column labeled “Estimated Annual Cost:
2019 Capital (1,000s)” has changed from $236,9003 to $242,1003.
b. Approximately $2,100,000 of automatic protection (line recloser) capital
costs: Including these costs in Attachment E results in an additional line item
to Row Section 4.3.4 System Protection to include these costs for Automation
Protection (Line Reclosers).

2.

Two cells in Row 4.3.2 and Row 4.3.3 for the Column labeled “Estimated Annual
Cost: 2019 Capital (1,000s)” on Attachment A were incorrectly marked with “2”
footnote references instead of “3” footnote references.

3.

Two cells at Row 4.3.2 and Row 4.3.3 for the Column labeled “Costs Currently
Reflected in Revenue Requirement? (Provided Decision Reference) If for Only Part
of Budget, Identify the $ for that Part and Explain Part Not Previously Authorized
(§ 8386(j))” on Attachment A were incorrectly marked with “3” footnote references
instead of “4” footnote references.

22

 Case 3:14-cr-00175-WHA Document 1057-2 Filed 04/25/19 Page 25 of 25
 

IV.

CONCLUSION
PG&E wants to present the Commission with the most current updates to its Plan, so that

the Commission can review these in advance of issuing a final decision on the Plan. PG&E is
updating the Plan to reflect current operating conditions, external challenges, and continuous
improvement opportunities identified through the implementation of the Plan to date. PG&E
also clarifies targets to avoid potential misinterpretation of the scope of the targets. In addition,
PG&E is notifying the Commission regarding expected increases in several cost forecasts, as
well as several minor inadvertent errors in Attachment E to the Plan.
The changes to the targets are summarized above by reference to Table 9 and Section
6.2.4, but also affect other language within the Plan discussing or referencing these targets.
Upon approval of PG&E’s Plan, PG&E will submit a conformed version of the Plan reflecting
these changes to the Plan. PG&E respectfully requests that the Commission approve PG&E’s
Plan as amended.
Respectfully Submitted,
ALYSSA KOO
CHARLES MIDDLEKAUFF

By:

/s/ Alyssa Koo
ALYSSA KOO

Pacific Gas and Electric Company
77 Beale Street, B30A
San Francisco, CA 94105
Telephone: (415) 973-3386
Facsimile:
(415) 973-5520
E-Mail:
Alyssa.Koo@pge.com
Dated: April 25, 2019

Attorneys for
PACIFIC GAS AND ELECTRIC COMPANY

23