Details for: 4032-E (Part 1 of 1).pdf

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Gary A. Stern, Ph.D.
Managing Director, State Regulatory Operations

July 5, 2019
(U 338-E)
Covered Conductor Installation Outside of the Commission’s
High Fire Threat District Maps as part of Southern California
Edison Company’s Wildfire Covered Conductor Program in
Compliance with Decision 19-05-038


In compliance with Decision (D.)19-05-038, Southern California Edison Company (SCE)
hereby outlines and justifies installation of covered conductor as part of its Wildfire
Covered Conductor Program (WCCP) in areas outside the California Public Utilities
Commission (CPUC or Commission) High Fire Threat District (HFTD) map through the
end of 2019. As explained below, since inception of the WCCP in 2018 and through
2019, SCE anticipates that approximately three circuit miles of covered conductor will
be installed in areas outside the HFTD.
This advice letter provides SCE’s plans and justification for installing covered conductor
outside of the Commission’s HFTD maps as required by Ordering Paragraph (OP) 2 of
In D.17-12-024, the Commission adopted new fire-safety regulations requiring investorowned utilities (IOUs) to integrate into their operations a new HFTD map, indicating
areas in California that are affected by Tree Mortality High Hazard Zones (Zone 1) or
represent an elevated (Tier 2) or extreme (Tier 3) wildfire risk due to utility
infrastructure-associated ignitions.1 These tier designations drive certain maintenance,
inspection, and vegetation management criteria/inspection intervals of overhead assets

The Final CPUC HFTD Map was published on January 5, 2018 in the Pacific Gas and
Electric Company, San Diego Gas & Electric Company, and REAX Engineering joint Advice
Letter 5211-E / 3172-E and adopted by the Commission on January 19, 2018 via Safety
and Enforcement Division’s (SED) disposition of the aforementioned joint Tier 1 Advice

P.O. Box 800

8631 Rush Street

Rosemead, California 91770

(626) 302-9645

Fax (626) 302-6396


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ADVICE 4032-E (U 338-E) -2- July 5, 2019 in high fire-threat areas. Prior to the creation of the CPUC HFTD, SCE utilized multiple sources to specify which areas in its service area historically represented high fire risk. Since D.17-12-024, SCE maintained a High Fire Risk Area (HFRA) that was a combination of historical map boundaries (based on past fire management and response experiences), CAL FIRE’s Fire Hazard Severity Zone (FHSZ) maps, and most recently the CPUC HFTD map. SCE has considered all four categories (i.e., Zone 1, Tier 2, Tier 3, and non-CPUC historical high fire risk areas) to be “HFRA.” As shown in Table 3-5 of SCE’s 2019 WMP, approximately 4,200 square miles of SCE’s service territory (or approximately 8 percent) consisted of non-CPUC HFRA.2 In fall 2018, a team consisting of SCE employees with subject matter expertise in fire management/response, fire behavior/fuels, meteorology, maintenance/inspection, grid operations, vegetation management, and geospatial analysis embarked on a project to evaluate these non-CPUC HFRA (divided geospatially into over approximately 1,000 space areas or “polygons”). SCE is nearing completion of this review. Once the final review has been completed, SCE plans to operationalize and treat the retained nonCPUC HFRA as Tier 2 (elevated) fire threat until the CPUC formally adopts these areas into the HFTD as Tier 2 or Tier 3 designations.3 In D.19-05-038, the Commission approved SCE’s 2019 WMP and directed SCE to comply with the reporting, metrics, advice letter, and other follow-up requirements set forth therein. One of the requirements was for SCE to outline and justify its plans if it plans to install covered conductor outside the Commission’s HFTD during the 2019 WMP cycle. COVERED CONDUCTOR INSTALLATION OUTSIDE OF THE CPUC’S HFTD MAPS When the CPUC released its HFTD map in 2018, SCE compared it to its historical high fire risk area maps and found that while a large portion of these data sets overlapped, there was approximately 8,800 sq. miles of SCE’s historical HFRA outside of the CPUC’s HFTD. SCE felt it was prudent to maintain its historical HFRA in addition to the CPUC’s newly-defined HFTD until it could re-evaluate those historical HFRA and determine whether or not to exclude or retain them as a HFRA. As described above, SCE is in process of completing its final review and anticipates removing a large portion of its non-CPUC HFRA. In the interim, SCE will continue to treat its non-CPUC HFRA in the same manner as the CPUC’s HFTD Tier 2 until this process has been completed. SCE began scoping and installing covered conductor in 2018 based on a circuit-level prioritization methodology described in SCE’s Grid Safety and Resiliency Program (GSRP) Application (A.)18-09-002).4 As described in that prioritization method, 40 2 3 4 SCE also operates and maintains electrical infrastructure outside its service area that included approximately 4,500 square miles previously designated as non-CPUC HFRA. At this time, SCE anticipates filing a petition to modify D.17-12-024 to request formal inclusion of SCE’s retained non-CPUC HFRA into the HFTD. See WPSCE-01 Grid Safety and Resiliency Program Workpaper Vol. 1 “Circuit Deployment Prioritization.” This document was also included in SCE’s Comments in the SB 901 OIR.
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ADVICE 4032-E (U 338-E) -3- July 5, 2019 percent of the weighting was based on the length of circuitry within the HFTD Tier 2 and Tier 3 areas. This methodology resulted in the vast majority of covered conductor planned to be installed within the HFTD over the GSRP Application period (2018-2020). This initial methodology to determine deployment prioritization of covered conductor was also based on methodology utilized in SCE’s Overhead Conductor Program (OCP) that focused on replacing small bare wire, typically less than 1/0 ACSR or 2/0 CU, with covered conductor on radial line sections and adding current limiting fuses. This approach addressed the concern of fault-induced downed conductor due to fault current levels in excess of the conductor ratings as well as Contact From Object (CFO) faults on radial line sections; however, it did not address main line circuitry. Recognizing that SCE’s initial covered conductor scope did not address the risk associated with CFO faults on mainline sections, SCE further analyzed two years of fault history and identified circuits with recent history of CFO faults. This information was used to improve the overall GSRP deployment prioritization methodology to include more frequent CFO identified circuits and replace bare wire with covered conductor for line sections within the HFTD and non-CPUC HFRA. SCE has and will continue to improve its prioritization methodology to deploy covered conductor to the highest fire risk areas. Since developing its GSRP circuit prioritzation method in 2018, SCE has developed enhanced wildfire risk models at a more granular segment-based level, incorporating improved consequence data as well as ignition risk data. The initial batch of scope resulting from SCE’s latest prioritiztion model went into design in Q2 of 2019. Given that scope at a segment level can be designed and executed more rapidly than circuit-level scope, SCE anticipates a small portion of these segments to be constructed in the latter part of 2019. If an identified segment is near an HFTD boundary, there may be a handful of spans that get covered outside the HFTD boundary in order to safely dead end the covered coductor in a location that can be guyed appropriately. Similarly, there are small portions of the Buckhorn circuit, shown below in Figure 1, that are located outside of both the non-CPUC HFRA and HFTD that will be covered as well. In this case, a portion of Filmore substation is located within a Tier 2 area, near the edge of town where the majority of the area surounding town is within a Tier 3 area. Some segments of the Buckhorn circuit serve load inside town that are outside the HFTD although the vast majority of the Buckhorn circuit is within Tier 2 and 3 areas. Given these conditions, SCE decided to also cover those segments outside HFTD rather than mix and match bare and covered conductor in the same neighborhood.
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ADVICE 4032-E (U 338-E) -4- July 5, 2019 Figure 1 In total, SCE estimates that by the end of 2019 and since it began the program in 2018 it will have installed approximately three circuit miles of covered conductor outside the CPUC’s HFTD as part of the WCCP. SCE anticipates that as part of its WCCP, it will have installed approximately 380 circuit miles of covered conduction since inception and through the end of 2019. Accordingly, the amount of covered conductor installed outside of the HFTD through 2019 and since inception of the program in 2018 is estimated to be less than one percent of the total amount of covered conductor installed as part of the WCCP. Additionally, SCE revised its distribution design standards in mid-2018 calling for all new conductor within SCE’s HFRA, which includes areas outside of the CPUC’s HFTD, to be covered conductor. This is applicable to new business and all existing capital programs in addition to WCCP. Therefore, projects that were designed after the mid 2018standards update and constructed in 2019 will add to the total amount of covered conductor installed and may include an additional small percentage of covered conductor outside of the CPUC’s HFTD. Once SCE completes the removal of the majority of its non-CPUC HFRA, the new distribution design standards will only apply to HFTD and its retained non-CPUC HFRA.
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ADVICE 4032-E (U 338-E) -5- July 5, 2019 No cost information is required for this advice letter. This advice letter will not increase any rate or charge, cause the withdrawal of service, or conflict with any other schedule or rule. TIER DESIGNATION Pursuant to OP 2 of D.19-05-038, this advice letter is submitted with a Tier 1 designation. EFFECTIVE DATE This advice letter will become effective on July 5, 2019, the same day as submitted. NOTICE Anyone wishing to protest this advice letter may do so by letter via U.S. Mail, facsimile, or electronically, any of which must be received no later than 20 days after the date of this advice letter. Protests should be submitted to: CPUC, Energy Division Attention: Tariff Unit 505 Van Ness Avenue San Francisco, California 94102 E-mail: Copies should also be mailed to the attention of the Director, Energy Division, Room 4004 (same address above). In addition, protests and all other correspondence regarding this advice letter should also be sent by letter and transmitted via facsimile or electronically to the attention of: Gary A. Stern, Ph.D. Managing Director, State Regulatory Operations Southern California Edison Company 8631 Rush Street Rosemead, California 91770 Telephone: (626) 302-9645 Facsimile: (626) 302-6396 E-mail:
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ADVICE 4032-E (U 338-E) -6- July 5, 2019 Laura Genao Managing Director, State Regulatory Affairs c/o Karyn Gansecki Southern California Edison Company 601 Van Ness Avenue, Suite 2030 San Francisco, California 94102 Facsimile: (415) 929-5544 E-mail: There are no restrictions on who may submit a protest, but the protest shall set forth specifically the grounds upon which it is based and must be received by the deadline shown above. In accordance with General Rule 4 of GO 96-B, SCE is serving copies of this advice letter to the interested parties shown on the attached GO 96-B and Rulemaking (R.)18-10-007 service lists. Address change requests to the GO 96-B service list should be directed by electronic mail to or at (626) 302-4039. For changes to all other service lists, please contact the Commission’s Process Office at (415) 703-2021 or by electronic mail at Further, in accordance with Public Utilities Code Section 491, notice to the public is hereby given by submitting and keeping the advice letter at SCE’s corporate headquarters. To view other SCE advice letters submitted with the Commission, log on to SCE’s web site at For questions, please contact Ryan Stevenson at (626) 302-3613 or by electronic mail at Southern California Edison Company /s/ Gary A. Stern, Ph.D. Gary A. Stern, Ph.D. GAS:rs/kc:jm
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ADVICE LETTER SUMMARY ENERGY UTILITY MUST BE COMPLETED BY UTILITY (Attach additional pages as needed) Company name/CPUC Utility No.: Southern California Edison Company (U 338-E) Utility type: ELC GAS PLC HEAT ELC = Electric PLC = Pipeline WATER Contact Person: Darrah Morgan Phone #: (626) 302-2086 E-mail: E-mail Disposition Notice to: EXPLANATION OF UTILITY TYPE GAS = Gas WATER = Water HEAT = Heat (Date Submitted / Received Stamp by CPUC) Tier Designation: 1 Advice Letter (AL) #: 4032-E Subject of AL: Covered Conductor Installation Outside of the Commission’s High Fire Threat District Maps as part of Southern California Edison Company’s Wildfire Covered Conductor Program in Compliance with Decision 19-05-038 Keywords (choose from CPUC listing): Compliance AL Type: Monthly Quarterly Annual One-Time Other: If AL submitted in compliance with a Commission order, indicate relevant Decision/Resolution #: Decision 19-05-038 Does AL replace a withdrawn or rejected AL? If so, identify the prior AL: Summarize differences between the AL and the prior withdrawn or rejected AL: Confidential treatment requested? Yes No If yes, specification of confidential information: Confidential information will be made available to appropriate parties who execute a nondisclosure agreement. Name and contact information to request nondisclosure agreement/ access to confidential information: Resolution required? Yes No Requested effective date: 7/5/19 No. of tariff sheets: -0- Estimated system annual revenue effect (%): Estimated system average rate effect (%): When rates are affected by AL, include attachment in AL showing average rate effects on customer classes (residential, small commercial, large C/I, agricultural, lighting). Tariff schedules affected: None Service affected and changes proposed1: Pending advice letters that revise the same tariff sheets: None 1 Discuss in AL if more space is needed. Clear Form
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Protests and all other correspondence regarding this AL are due no later than 20 days after the date of this submittal, unless otherwise authorized by the Commission, and shall be sent to: CPUC, Energy Division Attention: Tariff Unit 505 Van Ness Avenue San Francisco, CA 94102 Email: Name: Gary A. Stern, Ph.D. Title: Managing Director, State Regulatory Operations Utility Name: Southern California Edison Company Address: 8631 Rush Street City: Rosemead Zip: 91770 State: California Telephone (xxx) xxx-xxxx: (626) 302-9645 Facsimile (xxx) xxx-xxxx: (626) 302-6396 Email: Name: Laura Genao c/o Karyn Gansecki Title: Managing Director, State Regulatory Affairs Utility Name: Southern California Edison Company Address: 601 Van Ness Avenue, Suite 2030 City: San Francisco State: California Zip: 94102 Telephone (xxx) xxx-xxxx: (415) 929-5515 Facsimile (xxx) xxx-xxxx: (415) 929-5544 Email: Clear Form
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ENERGY Advice Letter Keywords Affiliate Direct Access Preliminary Statement Agreements Disconnect Service Procurement Agriculture ECAC / Energy Cost Adjustment Qualifying Facility Avoided Cost EOR / Enhanced Oil Recovery Rebates Balancing Account Energy Charge Refunds Baseline Energy Efficiency Reliability Bilingual Establish Service Re-MAT/Bio-MAT Billings Expand Service Area Revenue Allocation Bioenergy Forms Rule 21 Brokerage Fees Franchise Fee / User Tax Rules CARE G.O. 131-D Section 851 CPUC Reimbursement Fee GRC / General Rate Case Self Generation Capacity Hazardous Waste Service Area Map Cogeneration Increase Rates Service Outage Compliance Interruptible Service Solar Conditions of Service Interutility Transportation Standby Service Connection LIEE / Low-Income Energy Efficiency Storage Conservation LIRA / Low-Income Ratepayer Assistance Street Lights Consolidate Tariffs Late Payment Charge Surcharges Contracts Line Extensions Tariffs Core Memorandum Account Taxes Credit Metered Energy Efficiency Text Changes Curtailable Service Metering Transformer Customer Charge Customer Owned Generation Mobile Home Parks Name Change Transition Cost Transmission Lines Decrease Rates Non-Core Transportation Electrification Demand Charge Non-firm Service Contracts Transportation Rates Demand Side Fund Nuclear Undergrounding Demand Side Management Oil Pipelines Voltage Discount Demand Side Response PBR / Performance Based Ratemaking Wind Power Deposits Portfolio Withdrawal of Service Depreciation Power Lines Clear Form
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