By California statute, electrical utilities must provide a complete Wildfire Mitigation Plan every three years, with yearly updates. The WMPs are submitted to the Office of Energy Infrastructure Safety (OEIS) and then to the California Public Utilities Commission (CPUC) for ratification.  The public is allowed to comment on these plans, which have come to comprise thousands of pages of the plans and supporting data and documents.

M-bar Technologies and Consulting has been reviewing these plans on behalf of MGRA since their inception in 2019.  While each iteration of the WMPs becomes more complete and sophisticated, there remain a number of key issues with the WMPs of the major California utilities that MGRA has identified. In the 2023 WMPs, the following issues were of particular concern:

• Utility risk models generally do not adequately incorporate the influence of extreme wind events in triggering the outages that lead to wildfires.
• As a consequence, utility models also overweight risk drivers unrelated to wind (such as animals, vehicles, balloons, or 3rd party).
• Utility risk models that use wildfire spread simulations to calculate consequences artificially inflate risk nearer to the ignition point and underrepresent risk in remote high-wind areas.
• Since PG&E proposed a 10,000 mile undergrounding program in 2021, all three utilities have introduced expanded undergrounding programs without adequately justifying the cost efficiency of undergrounding. While highly effective, undergrounding is the most expensive and there are other mitigations that have significantly higher cost efficiency.
• New evidence from Southern California Edison's extensive deployment of covered conductor suggests that covered conductor may be more effective in preventing wildfires than the estimates utilities are using.
• Combinations of covered conductor and new technologies (REFCL, Falling Conductor Protection, High-Impedance Fault detection) will further reduce potential for wildfire igntions.

 MGRA Comments on the 2023-2025 Wildfire Mitigation Plans of SDG&E, SCE, and PG&E

From October 8th to October 12th, 2019, PG&E planned its largest pre-emptive power shutoff event (PSPS) ever attempted by a utility in anticipation of an extreme Diablo wind event. As the event approached, performance of the PG&E website, a primary outlet for PSPS information, degraded and key components ultimately failed. As part of a CPUC proceeding investigating PG&E's October 2019 event, M-bar's expert prepared testimony and briefing for MGRA on the PG&E website failure. Our findings: PG&E's failure was at the root a lack of customer empathy. PG&E did not understand how its customers would use its website during a power shutoff event, and as a result under-estimated required capacity, failed to implement performance testing, and missed a key warning sign that could have helped it avoid the outage.

MGRA Testimony on the October 2019 PG&E Website Failure

MGRA Brief Regarding the October 2019 PG&E Website Failure

• - Continuing opportunity for substantive public and party input into utility fire plans
• - Mandating wind speed as a key metric related to outages, vegetation incidents, and fires
• - State-wide standards for all California electric utilities
• - Training and certification for the new utility wildfire plan Independent Evaluators