Details for: 4031-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)
Description of Southern California Edison Company’s
Enhanced Overhead Inspections Program that Clarifies
Differences from SCE’s Existing Inspections, what the
Enhanced Inspections Involve, Specific Activities that will be
Performed, and Data that will be Collected as well as
Databases Related to These Inspections


In compliance with Decision (D.)19-05-038, Southern California Edison (SCE) hereby
further describes its Enhanced Overhead Inspections (EOI) initiative by clarifying the
differences from SCE’s existing inspections, explaining what the EOI involve, the
specific activities that will be performed, the data that will be collected as well as
databases related to EOI.
This advice letter provides the Commission with further description of SCE’s EOI
program as required by Ordering Paragraph (OP) 2 of D.19-05-038.
As described in its 2019 Wildfire Mitigation Plan (WMP), SCE commenced its EOI
initiative in late 2018 to help address evolving wildfire risks. The primary focus of SCE’s
EOI is to inspect, assess and remediate SCE’s infrastructure in its high fire risk areas
(HFRA) to reduce ignition risk. Historically, SCE’s inspection and maintenance
programs have been focused on regulatory compliance. SCE’s EOI initiative continues
to evolve, as further described below, centered on a risk-based approach that
addresses the evolving wildfire threat. In D.19-05-038, the Commission ordered SCE to
file a Tier 1 Advice Letter further describing its EOI to clarify (in more detail than
provided in the WMP) how it differs from SCE’s existing inspections, what the enhanced
inspections involve, including a description of the specific activities that will be
performed, data that will be collected, and any databases that will be created or
supplemented as part of these inspections. SCE addresses these requirements below.

P.O. Box 800

8631 Rush Street

Rosemead, California 91770

(626) 302-9645

Fax (626) 302-6396


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ADVICE 4031-E (U 338-E) -2- July 5, 2019 ENHANCED OVERHEAD INSPECTIONS INITIATIVE OVERVIEW SCE’s ongoing commitment to safety and supporting California’s fight against wildfire risk remains a top priority.   Inspections of SCE’s infrastructure, particularly in its HFRA, have been an ongoing part of regular operations for SCE for many years. In light of what has been called “the new abnormal” wildfire climate in California, SCE is conducting additional, enhanced inspections of its infrastructure in HFRA. SCE has long taken substantial steps to reduce the risk of wildfires, and SCE continues to proactively enhance its operational practices and infrastructure through its comprehensive wildfire mitigation strategy. SCE has developed and improved its various maintenance and inspection programs to further protect the safety of the general public, its customers, and its workers, as well as to continue to provide reliable service to customers. In SCE’s efforts to consistently and continually improve the safety in HFRA, additional criteria inform the enhanced inspections. The EOI initiative is being implemented in addition to SCE’s regular compliance and safety inspections as an added measure to further strengthen the safety and reliability of SCE assets. SCE dedicated enormous amounts of resources and effort to the EOI initiative to expeditiously finish a vast scope of work in advance of the 2019 wildfire season. DISTRIBUTION ENHANCED OVERHEAD INSPECTIONS How EOI Differs From Existing Programs The distribution EOI initiative was designed to identify and rectify immediate and/or probable wildfire risk on the distribution system - including an emphasis on SCE historical ignition data to ensure the EOI criteria identified a wide range of potential ignition risk. However, for the 2019 WMP cycle, the EOI initiative was not designed to identify or replace SCE’s legacy compliance inspection programs; EOI was primarily designed for a risk-based approach and not designed to identify the full spectrum of distribution compliance infractions. What the Enhanced Inspections Involve The distribution EOI scope consists of approximately 300,000 overhead primary distribution structures within all SCE HFRA (Zone 1, Tier 2, Tier 3, and non-CPUC HFRA). The aggregate EOI scope was implemented through a phased approach based on probability risk using historical data. Each phase was assigned a completion date to ensure an effective operational strategy, maximize risk buy-down, and complete inspections of all HFRA overhead structures prior to the traditional start of the California fire season in 2019. As of the filing of this advice letter, SCE has completed the vast majority of distribution EOI with few remaining exceptions due to limited access issues. Some aspects of EOI (including certain remediations and aerial inspections) are expected to continue into 2020.
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ADVICE 4031-E (U 338-E) -3- July 5, 2019 The primary activities involved in SCE’s distribution EOI initiative include inspecting all approximately 300,000 distribution primary-level structures1 based on specificallydesigned ignition risk reduction criteria. Additionally, all items that need to be remediated identified during EOI are scheduled and remediated based on existing maintenance priority timelines. During an EOI, there is a physical visit to the structure being inspected followed by a thorough visual inspection from the ground at the actual location. EOI are not conducted in vehicles. SCE designed a Distribution Inspection Reference Guide to optimize inspection results and provide additional instructions to field crews. The reference guide consists of a description of each question on the inspection form, details on the intent of the question and expected outcome of the inspection, and instructions on mitigation of findings for each question. In addition to the Distribution Inspection Reference Guide, a specialized project team with various areas of expertise throughout SCE designed a specific distribution EOI criteria form for qualified electrical workers to conduct the enhanced field inspections of SCE’s distribution infrastructure in HFRA. The inspection form was designed to ensure effective ignition-focused mitigation, consistent EOI throughout SCE’s HFRA, and implement construction standard changes and hardware projects to prevent and mitigate future ignition sources. The specially-designed inspection form is comprised of several ignition-focused questions not covered in General Order 95 compliance requirements, and posed as “yes” or “no” and “true” or “false” to ensure accuracy.2 Based on field inspection responses to each individual question, the type of response results in an additional action to rectify all potential ignition risk issues discovered during the inspections. For example, based on the inspection discovery in the field, a response may result in an immediate notification creation on the digital form with the notification classification determined based on the severity of the discovered issue. To ensure optimal inspection effectiveness during EOI, SCE utilizes specialized resources to perform field inspections. In contrast to traditional compliance inspections, all EOI is conducted by SCE Journey Lineman to further provide distribution expertise and improve ignition risk reduction effectiveness. To further improve these enhanced inspections and minimize the probability of missing a potential ignition risk, SCE has recently launched a comprehensive aerial inspection function as part of its EOI program. Whereas the ground-based enhanced inspections described above have detected issues with SCE’s infrastructure that are seen in-person from qualified electrical workers, the aerial inspections provide improved visuals for infrastructure that is located above the ground such as pole tops that may not be easily visible from the ground. This function is performed by helicopters and/or drones 1 2 The EOI inspectors are not precluded from inspecting secondary-level structures, but the EOI initiative does not specifically mandate such inspections. For example, the specialized form asks the following question: “Are jumper wires adequately separated and supported to avoid contact or fatigue during high wind events (N/A if no jumpers)?”
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ADVICE 4031-E (U 338-E) -4- July 5, 2019 hovering and taking high-quality digital photos of each HFRA distribution overhead structure. Subsequently, each photo is then examined by a team of qualified resources (e.g., Journeymen Lineman and Distribution Engineers) and a specialized aerial inspection form is completed for each HFRA structure captured by the aerial inspections. Upon discovery of issues identified during the aerial inspections, the team submits repair notifications based on the severity of the findings. The aerial inspections are generally in addition to – not in lieu of – the ground-based inspections.3 Several EOI (both ground-based and aerial) have resulted in a remediation notification to repair or replace the identified distribution infrastructure issue. The remediation plan has been designed to rectify notifications based on compliance requirements, ignition and consequence risk, and for specific findings as a result of these enhanced inspections. The plan emphasizes a risk-based approach focused on ignition (type of notification) and consequence (potential effects of an ignition) to ensure the risk of an identified issue is prioritized to rectify the issue based on its severity. Existing and New Databases Generally, SCE has leveraged existing information systems for its EOI initiative. In addition, SCE used the “Survey123” application, which is an application that the EOI inspectors now use on newly deployed iPads in the field with full utilization of SCE’s ArcGIS database to collect and store the inspection data during an EOI. Additionally, SCE designed several internal automated features within existing technologies to transition data and automate processes. SCE also deployed new technology during these enhanced inspections. For distribution EOI, about 500 iPads were provided to the inspectors to document and track inspections. TRANSMISSION ENHANCED OVERHEAD INSPECTIONS How EOI Differs From Existing Programs In general, SCE’s EOI for transmission-level infrastructure is similar in scope and work activities to the distribution initiative described above. Similar to the distribution EOI, transmission EOI take into consideration a more conservative risk-based approach than historical inspection practices, which are compliance-based. Although transmission inspections in the past required detailed assessments, transmission personnel, as part of the transmission EOI, were directed to focus specifically on potential ignition sources. All transmission overhead structures (approximately 50,000) in SCE’s HFRA have been inspected through the EOI initiative as of the filing of this advice letter. Although these structures would have been inspected over the course of the year through traditional inspection programs, these enhanced inspections were accomplished in a shorter span 3 Except in areas where access issues made it infeasible, SCE inspected all primary distribution and transmission infrastructure in HFRA via ground-based inspections. For those limited exceptions, SCE used aerial inspections instead of ground-based inspections. In general, however, SCE’s aerial inspections are being conducted on assets that have already been inspected from the ground.
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ADVICE 4031-E (U 338-E) -5- July 5, 2019 of 5 months with greater focus on ignition risk. The purpose of transmission EOI was to remediate high priority notifications as soon as possible and before the traditional fire season started. The volume of work and inspections completed was unlike anything the Transmission organization had done historically. What the Enhanced Inspections Involve A new interim group was formed within SCE’s Transmission organization for this new initiative. Members from all parts of the Transmission organization formed a strike team to mobilize and execute the transmission EOI. The team planned, designed, and executed these enhanced inspections. The approach to these inspections was also new. As opposed to having these structures inspected by only patrolman, teams were formed under patrolman supervision to inspect all the structures in HFRA. A new inspection checklist was created with the help of Transmission Engineering, Transmission Patrolman and Transmission Management to specifically assess fire threats. The typical inspection checklist that Patrolman used was incorporated, but many more ignition-specific questions above and beyond what they would normally inspect for were added. Work that was remediated was also prioritized in a different way. Compliance timeframes in HFRA are much shorter than other non-HFRA and remediation in highestrisk areas take priority. The approach on using risk to determine priority was also new. Transmission leveraged a risk-based approach to determine prioritization of remediation work. SCE’s risk-based approach will continue to evolve in order for SCE to continually improve its efforts to focus its mitigation efforts on the highest-risk items. Additionally, and similar to distribution EOI, the Transmission organization has started to conduct aerial enhanced inspections via helicopters. These aerial inspections are an enhanced version of Transmission's traditional line patrols. Under SCE’s traditional, compliance-based programs, SCE does not aerially inspect every transmission area. Historically, detailed aerial patrols have been conducted only when a ground-based inspection could not be safely conducted, or when a ground-based inspection finding indicated that an aerial inspection was warranted. Aerial patrols would be continuous and visual-only until a potential notification was identified, at which point the patrol resources would stop to further assess the condition and write an associated notification. While conducting enhanced ground inspections, SCE found that an aerial view of SCE's overhead assets would provide a more comprehensive inspection of the pole top, the wooden crossarms, the steel structures, and all conductor/hardware. Closer inspection has revealed additional ignition risks in Transmission's infrastructure. In an aerial EOI, every pole/tower that was assessed from the ground will be assessed in the air. Each structure will now have an HD video accompanied by individual still frames (photos) of each connection point on the pole or tower. These visuals allow the Transmission Patrolman, engineers, etc. to perform a deeper dive inspection of the asset.
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ADVICE 4031-E (U 338-E) -6- July 5, 2019 A specialized inspection form was created to inspect overhead assets from an aerial perspective. This too was loaded into Survey123 and the software was used in a similar fashion as ground inspections. A team was formed from members outside of the Transmission organization (to supplement Transmission employees that were already spread thin) to support this effort. This team was not only in charge of project managing this enhanced aerial inspection, but were also tasked with creating the inspection groups (or pods) that would be used once the video/photos were available. These inspection pods consist of contract engineers and Transmission Patrolman. SCE plans to expand these pods to include additional analytical support, contract inspectors, and supervision. New and Existing Databases SCE also deployed new technology during these enhanced inspections. For transmission EOI, almost 100 iPads were released to the inspectors to document and track inspections. Automation of inspections in the iPads allowed the inspection checklist to be filled out real time (versus using paper inspections), the ability to capture longitude/latitude with the GPS monitor, the ability to take pictures of every structure and issue (regardless of whether it had an issue), and the ability to track metrics associated to inspections in the Survey 123 software application. Dashboards were created and introduced for the first time to track inspection progress in real-time. The employment of this new technology also required user and other employee training. For transmission EOI, SCE also had to implement a partially new “gatekeeping” process (i.e., the process from reviewing, classifying, and approving/modify/rejecting the notifications that were created in Survey123 to be stored in SCE’s existing SAP databases). Although SCE used the same existing employee gatekeepers (approximately 20), the forum to gatekeep was different. Survey123 was used for gatekeeping to reduce the amount of time that would usually be needed in SCE’s maintenance software (SAP) to navigate through multiple screens to gather the necessary information and validate a notification. Gatekeepers can now visually see the notifications identified on each structure in a map and assign themselves a group to validate and confirm in the new software. The software, the visuals, the maps, and the grouping on the notifications was all new information that required new training. Additionally, SCE set up an internal site to store all photos from the inspection phase. This made it easier for the gatekeeper to reference material needed to validate the priority assigned to the notification. Remediation planning and design was similarly done in Survey123. This is also different than historical Transmission practices. Previously, transmission estimators would search the associated notifications on one structure to determine the remediation that needed to be completed. In the enhanced remediation process, estimators can see all associated notifications on each structure in each circuit. This improved the planning and design process. For example, associated notifications on the structures can now be seen from EOI-related work and other inspection programs that need to be remediated on the same circuit. Bundling of these notifications in one area (using the Survey123
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ADVICE 4031-E (U 338-E) -7- July 5, 2019 tool) proved to be very efficient. GENERATION ENHANCED OVERHEAD INSPECTIONS The generation EOI work stream was initiated after SCE’s distribution and transmission EOI programs and subsequent to SCE’s submittal of its 2019 WMP. The generation EOI was able to take advantage of the processes, training materials and systems described above. Generation facilities are unique in their application, age, variety, and how and where they are situated along with other overlapping regulatory requirements such as FERC licensing requirements; therefore, the tools and processes described above were modified to suit Generation assets and work flow processes. How EOI Differs From Existing Programs Standard inspections for generation assets include a large variety of routine inspections including, for example, NERC clearance requirements, CPUC clearance requirements (GO 95, etc.), substation inspections and testing, dam safety inspections, a variety of facility-based inspections, environmental inspections (hazardous materials storage, inspections of pressurized vessels, etc.) and surveys. However, historically, there have not been specific inspection routines focusing on potential sources of ignition for generation assets. What the Enhanced Inspections Involve Under the generation EOI, SCE scoped enhanced inspections of approximately 450 generation assets in its HFRA. These inspections are ongoing and include ignitionfocused assessments of low-voltage ancillary assets and their associated overhead lines, supporting structures, any exposed wiring and/or threats from vegetation that require additional mitigation, high-voltage facilities to ensure all overhead connections from the last transmission and distribution inspected structures have been evaluated (using the same applicable questions asked on the transmission and distribution enhanced inspection forms), and confirmation of appropriate vegetation-free buffers around high-voltage facilities, especially in heavily forested locations with older facility set-back requirements. Similar to the transmission and distribution EOI described above, photographs are collected and documentation of findings regardless of whether issues are identified. New and Existing Databases Generation is also using the new Survey123 software to classify and remediate issues (with approximately 20 new iPads). 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.
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ADVICE 4031-E (U 338-E) -8- July 5, 2019 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 4031-E (U 338-E) -9- 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) #: 4031-E Subject of AL: Description of Southern California Edison Company’s Enhanced Overhead Inspections Program that Clarifies Differences from SCE’s Existing Inspections, what the Enhanced Inspections Involve, Specific Activities that will be Performed, and Data that will be Collected as well as Databases Related to These... 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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