Gary A. Stern, Ph.D.
Managing Director, State Regulatory Operations
October 30, 2020
ADVICE 4327-E
(U 338-E)
PUBLIC UTILITIES COMMISSION OF THE STATE OF CALIFORNIA
ENERGY DIVISION
SUBJECT:
Southern California Edison Company’s Quarterly Advice Letter
Pursuant to Assembly Bill 1054 Regarding the Implementation
of Its Approved Wildfire Mitigation Plan and Its Safety
Recommendations
Southern California Edison Company (SCE) hereby submits this Tier 1 Advice Letter
(AL) detailing the implementation of its approved 2020-2022 Wildfire Mitigation Plan
(WMP),1 recommendations of the most recent safety culture assessment, a statement of
the recommendations of its board of directors’ safety committee2 (Committee) meetings
that occurred during the third quarter of 2020, and a summary of the implementation of
Committee recommendations during the second quarter of 2020.3
PURPOSE
The purpose of this advice letter is to comply with the provisions of Public Utilities Code
(PUC) Section 8389(e)(7), established by California Assembly Bill (AB) 1054.
BACKGROUND
AB 1054 was signed into law by Governor Newsom on July 12, 2019. Section
8389(e)(7), which was added to the PUC by AB 1054, reads:
The executive director of the commission shall issue a safety certification to
an electrical corporation if the electrical corporation provides documentation
of the following . . . The electrical corporation is implementing its approved
wildfire mitigation plan. The electrical corporation shall file a tier 1 advice
letter on a quarterly basis that details the implementation of both its
1
2
3
CPUC WMP approval statement available at:
https://docs.cpuc.ca.gov/PublishedDocs/Published/G000/M340/K129/340129782.PDF.
SCE’s board of directors’ safety committee is known as the Safety and Operations
Committee of the Board of Directors and referred to herein as the “Committee.”
Advice 4266-E.
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ADVICE 4327-E
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approved wildfire mitigation plan and recommendations of the most recent
safety culture assessment, and a statement of the recommendations of the
board of directors safety committee meetings that occurred during the
quarter. The advice letter shall also summarize the implementation of the
safety committee recommendations from the electrical corporation’s
previous advice letter filing. If the division has reason to doubt the veracity
of the statements contained in the advice letter filing, it shall perform an
audit of the issue of concern.
SCE provides the required information as indicated below:
(1) Implementation of Wildfire Mitigation Plan
On February 7, 2020, SCE submitted its second comprehensive WMP covering
the years 2020 through 2022 and building on its 2019 WMP, including successes
and lessons learned. After an extensive review process that included discovery,
workshops, and comments, the CPUC approved SCE’s 2020-2022 WMP on
June 11, 2020.4
In 2020, SCE is tracking 69 specific wildfire-related programs and activities
included in its 2020-2022 WMP. As in SCE’s 2019 WMP, the 2020-2022 plan
includes wildfire mitigation activities such as infrastructure hardening, vegetation
management, detailed inspections and remediations, and situational awareness.
SCE’s WMP also emphasizes Public Safety Power Shutoff (PSPS) resilience and
community engagement, particularly for under-represented groups and access
and functional needs customers. SCE’s 2020-2022 plan increases the use of
data, advanced risk analytics and innovative technologies to help the company
prioritize the activities with the greatest potential to mitigate wildfire risks and
improve public safety.
In Attachment A, SCE presents detailed information about the implementation
status of meeting WMP 2020 Program Targets for each of these wildfire-related
mitigation activities and programs. As referenced in Attachment A, SCE is
currently substantially on track or has met the majority of 2020 goals listed in its
2020-2022 WMP.
SCE remains cautiously optimistic that it will be able to meet the year-end
program targets in most behind-plan activities but notes that the targets for three
activities, SH-10 (Tree Attachment Remediations) and SH 12.1 and 12.2
(Distribution Inspection-driven Remediations and Transmission Inspection-driven
Remediations) are at risk. COVID-19-related restrictions have had an impact on
the implementation plans for a few WMP activities and, in recent months, fires
and the associated diversion of crews, poor air quality, and US Forest Service
4
CPUC WMP approval statement available at:
https://docs.cpuc.ca.gov/PublishedDocs/Published/G000/M340/K129/340129782.PDF.
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ADVICE 4327-E
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October 30, 2020
work stoppages as well as heat waves have impeded work in affected areas.
Attachment A (Appendix) provides more details on Behind Plan activities
including plans to identify and prioritize pending activities during the remainder of
the year.
(2) Implementation of Most Recent Safety Culture Assessment
SCE has not yet undergone a CPUC-led safety culture assessment pursuant to
PUC Section 8389(d)(4). Notwithstanding this, safety is the first of SCE’s core
values and this is demonstrated through the company’s commitment to creating
and maintaining a safe environment for employees, contractors, and the public.
SCE continues to improve its safety culture via meetings, trainings, corporate
messaging and the incorporation of feedback from all levels of the organization.
The Wildfire Safety Division (“WSD”) is currently in the process of developing an
annual Safety Culture Assessment Process Proposal with plans to conduct its
first assessment for individual electrical corporations in the summer of 2021.
SCE looks forward to working with WSD and other interested stakeholders in
2021 to review its safety culture and build upon existing efforts to strengthen it.
(3) Recommendations of Safety and Operations Committee
The Committee had a single meeting during the third quarter of 2020 (on August
26, 2020). During this meeting, the Committee focused on wildfire and safety
issues in the following categories: Wildfire Safety and Employee, Contractor and
Public Safety. Each of these areas is separately addressed below.
Wildfire Safety
Discussions at the third quarter meeting covered an overview of the current fire
season and ignition data, the status of the WMP progress to date, asset data
management, and the plan to address identified WMP deficiencies as identified
by WSD.
Regarding the status of the current fire season and the WMP, topics included the
impact of sectionalization in reducing customer impacts of the Public Safety
Power Shutoff events, ignition trends year-to-date as compared to 2019 ignitions,
and the analysis of mitigations in the WMP that may have prevented ignitions.
The progress on the WMP and areas where plans are being implemented to
meet targets, including on transmission inspections, was also covered. The
Committee was also made aware of the stand down of a helicopter contractor
due to a fatality outside of SCE’s service area.
Management also reported on ongoing asset data management process
enhancements. The Committee and management discussed various factors
regarding asset data management, including the structure of corporate and
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ADVICE 4327-E
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October 30, 2020
business unit data governance and identification of risks related to asset data
management.
A summary of SCE’s responses to Class A deficiencies as identified by WSD and
the plan for SCE’s response to Class B deficiencies was provided to the
Committee. Management discussed the scope and timing of SCE’s long-term
plan for wildfire mitigation in detail, including its alignment with WSD’s maturity
model.
Employee, Contractor and Public Safety
The Committee concentrated on worker and contractor safety at its third quarter
meeting, discussing leading indicators for safety performance, worker safety and
the contractor safety program.
Management reported on SCE’s safety performance including the serious injuries
and fatalities and Days Away, Restricted or Transferred (“DART”) rates and
performance year-to-date of those factors as compared to 2019.
Management and the Committee discussed serious injury leading indicators and
potential correlation of serious and/or fatal injuries to the districts targeted for
reduction in DARTs. Management also reported on employee safety
performance including impacts of teleworking on the DART rate. Management
noted that while the DART rate of field workers had declined year-to-date in
comparison to 2019, the serious injuries have not decreased.
The Committee and management also discussed key drivers of contractor safety
performance. Management provided an overview of the contractor safety
program, the gating process for prequalification and the role of the business unit,
supply management and the safety organization in contractor management.
Management also noted the potential impact of independent ratings of contractor
safety combined with SCE’s own assessment of performance on the allowed
scope of work for such contractors. The Committee and management discussed
aspects of the contractor safety program, including various factors that contribute
to contractor management and oversight.
Committee Recommendations/Management Responses
The Committee made the following recommendation(s) and request(s) during its
third quarter meeting:
1. The Committee recommended that management benchmark the use of
leading indicators and management practices for contractor safety
performance and provide a report in a future meeting regarding any
variances with current practices.
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2. The Committee asked management to follow up with a deep dive on the
Safety Culture Assessment survey results of the districts targeted for
further work on reducing DARTs; specifically looking at areas of
opportunity for this group, and include similar analysis for locations where
safety performance is high.
In response to the Committee’s recommendations in prior meetings,
management provided the following responses at the third quarter meeting:
1. In addition to the detailed plan on location-specific DART safety action
plans provided at the June 26th meeting, management discussed potential
correlation of serious and/or fatal injuries to the seven target districts for
DART improvement during the report on Safety and Operations Metrics.
2. Management provided an update on the development of the long term
plan for wildfire mitigation, during the update on the WMP. An overview of
the contractor safety program was provided during the Worker Safety
Update Report. In addition, a report on Contractor Management Practices
is scheduled to be provided at the October 21st meeting.
The Committee has two regular fourth quarter meetings on October 21, 2020 and
December 9, 2020 and additional meetings will be scheduled as appropriate.
No cost information is required for this AL.
This AL will not increase any rate or charge, cause the withdrawal of service, or conflict
with any other schedule or rule.
TIER DESIGNATION
Pursuant to General Order (GO) 96-B, Energy Industry Rule 5.1, this AL is submitted
with a Tier 1 designation.
EFFECTIVE DATE
SCE respectfully requests that this AL become effective October 30, 2020, which is the
same date as submitted.
NOTICE
Anyone wishing to protest this AL 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:
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ADVICE 4327-E
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October 30, 2020
CPUC, Energy Division
Attention: Tariff Unit
505 Van Ness Avenue
San Francisco, California 94102
E-mail: EDTariffUnit@cpuc.ca.gov
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 AL 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: AdviceTariffManager@sce.com
Diana S. Gallegos
Senior Advisor, 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: Karyn.Gansecki@sce.com
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 AL to the
interested parties shown on the attached GO 96-B, R.18-10-007, R.18-12-005, and
A.18-09-002 service lists. Address change requests to the GO 96-B service list should
be directed by electronic mail to AdviceTariffManager@sce.com or at (626) 302-3719.
For changes to all other service lists, please contact the Commission’s Process Office
at (415) 703-2021 or by electronic mail at Process_Office@cpuc.ca.gov.
Further, in accordance with PUC Section 491, notice to the public is hereby given by
submitting and keeping this AL at SCE’s corporate headquarters. To view other SCE
advice letters submitted with the Commission, log on to SCE’s web site at
https://www.sce.com/wps/portal/home/regulatory/advice-letters.
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ADVICE 4327-E
(U 338-E)
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October 30, 2020
For questions, please contact Kavita Srinivasan at (626) 302-3709 or by electronic mail
at kavita.srinivasan@sce.com.
Southern California Edison Company
/s/ Gary A. Stern
Gary A. Stern, Ph.D.
GAS:ks:cm
Enclosures
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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: AdviceTariffManager@sce.com
E-mail Disposition Notice to: AdviceTariffManager@sce.com
EXPLANATION OF UTILITY TYPE
GAS = Gas
WATER = Water
HEAT = Heat
(Date Submitted / Received Stamp by CPUC)
Tier Designation: 1
Advice Letter (AL) #: 4327-E
Subject of AL: Southern California Edison Company’s Quarterly Advice Letter Pursuant to Assembly Bill 1054 Regarding
the Implementation of Its Approved Wildfire Mitigation Plan and Its Safety Recommendations
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 #:
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: 10/30/20
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: EDTariffUnit@cpuc.ca.gov
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: advicetariffmanager@sce.com
Name: Diana S. Gallegos c/o Karyn Gansecki
Title: Senior Advisor, 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:
Facsimile (xxx) xxx-xxxx: (415) 929-5544
Email: karyn.gansecki@sce.com
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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Attachment A
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WMP Activities Summary
Inactive
Complete
Ahead of Plan
Behind Plan, Likely to
Meet Year-end Goal
On Track
Behind Plan, At-Risk of Not
Meeting Year-end Goal
PSPS
PSPS-1: De-Energization Notifications
PSPS-1.1: Notifications to public safety
agencies and local gov’t
PSPS-1.2: Notifications to CalOES via
State warning system
PSPS-1.3: Notifications to the CPUC
PSPS-1.4: Enhance Emergency
Outage Notification System
Risk Analysis
PSPS-2: Have 23 available
Community Resource Centers
PSPS-5: Support
MICOP partnership
PSPS-3: Develop a customer resiliency
equipment incentive pilot program
PSPS-6: Support Independent
Living Centers Partnership
PSPS-4: Income Qualified Critical Care (IQCC)
Customer Battery Backup Incentive Program
PSPS-7: Have 5 available
Community Crew Vehicles
PSPS-8: Assess microgrid
resiliency projects
Emergency Preparedness
DEP-1: Customer Education and Engagement
DEP-1.1: Send
~915K /~3.2M letters
to customers in HFRA
/ non-HFRA
DEP-1.3: Conduct
marketing
campaign (reach
5M cust.)
DEP-1.2: Host 8-12
community
meetings
Vegetation Management
DEP-2: Hold internal
training on deenergization protocols,
determine staffing
needs, and fill positions
DEP-3: Participate in a
multi-channel, multilingual campaign to
provide information on
wildfire mitigations*
DEP-4: Develop a
measure to track
customer awareness of,
preparedness for, and
satisfaction with outage
experiences
System Hardening
SH-1: Install 700 miles of
covered conductor in
HFRA
SH-6: Circuit Breaker
Relay Hardware for Fast
Curve
SH-2: Refine
undergrounding
overhead conductor
methodology
SH-3: Replace 5,200 poles
with fire resistant poles
SH-7: PSPS-Driven Grid
Hardening Work
SH-8: Deploy
Transmission Open Phase
Detection on 6 additional
circuits
SH-4: Install/replace
fusing at 3,025 locations
SH-9: Transmission
Overhead Standards
(TOH) Review
VM-1: Hazard Tree
Management Program.
Assess 75,000 trees
SH-12.1: Distribution
SH-12.2: Transmission
Situational Awareness
SA-1: Install 375
Weather Stations
SA-2: Fire Potential
Index (FPI) Phase II. Refine
current FPI
SA-3: Complete
installation of two HighPerformance Computer
Clusters
SA-4: Implement
FireCast and FireSim
modules of Technosylva
SA-5: Perform fuel
sampling in HFRA
SA-6: Map surface and
canopy fuels across HFRA
SA-7: Initiate
procurement of remote
sensing technology
SA-8: Implement fire
science enhancement
initiatives
SH-12.3: Generation
Inspections
IN-1: Ground Inspections*
IN-1.1: Inspect 105,000
distribution structures in HFRA
IN-1.2: Inspect 22,500
transmission structures in HFRA
IN-6: Aerial Inspections
IN-6.1: Inspect 165,000
distribution structures in HFRA
IN-6.2: Inspect 33,500
transmission structures in HFRA
IN-2: Perform quality review on 15,000
transmission, distribution, and generation
structures in HFRA
IN-3: Infrared Inspection of 50% of
distribution circuits in HFRA
IN-4: Infrared Inspection, Corona Scanning,
and High Definition imagery of 1,000
transmission circuit miles in HFRA
IN-5: Inspect 200 generation assets
IN-7: Failure Modes and Effects Analysis
(FMEA)
VM-3: Expand clearances
for legacy facilities
VM-5: Perform 3,000 risk-based
quality control vegetation
management inspections
Operational Practices
SH-5: Install 45
RARs/RCSs
SH-10: Remediate 325
tree attachments
VM-2:. Perform
brush clearance of
200,000 poles
VM-4: Perform annual DRI inspection
scope and compete mitigations
according to guidelines
OP-1: Review and
update Annual
System Operating
Bulletin 322
OP-2: Hire additional
staff for Wildfire
Infrastructure
Protection Team
OP-3: Increase the
number of UAS operators
by an additional 50 crews
Alternative Technologies
SH-12: Remediate all notifications with ignition risk, to be past due compliant by year-end
SH-11: Legacy Facilities
RA-1: Implement
Wildfire Risk Reduction
Model (WRRM) module
of Technosylva
AT-1: Meter
Alarming for
Downed Energized
Conductor
AT-2.1: Evaluate
performance of
Distribution Fault
Anticipation technology
AT-2.2: Conduct
Extended Visual Line
of Sight demonstration
UAS flights
AT-3: Alternative Technology Evaluations
AT-3.1:
Initiate
design and
equipment
order for a
Ground Fault
Neutralizer
AT-3.2:
Initiate
design to
convert a
substation to
resonant
grounding
AT-4: Alternative Technology
Implementation – Vibration Dampers
AT-6: Assessment of
Partial Discharge for
Transmission Facilities
* The Change Report filed in September 2020 describes that SCE has ended its statewide campaign (DEP-3) and that SCE plans to inspect (IN-1) ~165,000
distribution and ~33,500 transmission structures in HFRA in 2020.
AT-3.3:
Install one
Rapid Earth
Fault Current
Limiter Isolation
Transformer
AT-3.4:
Complete
Distribution Open
Phase Detection
pilot
AT-5: Asset Defect Detection Using
Machine Learning Object Detection
AT-7: Early Fault Detection
(EFD) Evaluation
AT-8: High Impedance
Relay Evaluations
1
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WMP Activities Summary
Inactive
Complete
Ahead of Plan
On Track
Behind Plan, Likely to
Meet Year-end Goal
Behind Plan, At-Risk of Not
Meeting Year-end Goal
PSPS Activities
Enhance Emergency Outage Notification System
(PSPS-1.4)
De-Energization Notifications (PSPS-1.1)
Public Safety
Agencies and
Local Govt
Program Target: Notify applicable public safety agencies and local
governments of possible de-energization
Status Update: Through the end of September the PSPS Incident
Management Team (IMT) was remotely activated for four events.
Notifications were sent out to appropriate stakeholders in a timely
manner during each event.
De-Energization Notifications (PSPS-1.2)
Cal OES
Enhance
EONS
Program Target: Notify Cal OES through the State Warning Center
of possible de-energization
Status Update: Through the end of September the PSPS Incident
Management Team (IMT) was remotely activated for four events.
Notifications were sent out to appropriate stakeholders in a timely
manner during each event.
Status Update: Zip code level and in-language notification
enhancements (in Spanish, Mandarin, Cantonese, Vietnamese,
Korean, Tagalog) have been implemented and have been used
during PSPS events in 2020.
Community
Resource
Centers
213%
confirmed
De-Energization Notifications (PSPS-1.3)
Program Target: Notify the CPUC of possible de-energization
CPUC
Status Update: Through the end of September the PSPS Incident
Management Team (IMT) was remotely activated for four events.
Notifications were sent out to appropriate stakeholders in a timely
manner during each event.
Program Target: Enhance Emergency Outage Notification System
(EONS) to include Zip Code level alerting to include in-language
notifications to align with its existing notification abilities for SCE
customers
Community Resource Centers (PSPS-2)
Program Target: Have 23 sites available across SCE service territory
for customers impacted by a PSPS
Status Update: 49 CRCs have been contracted across 9 counties. Of
these 49, 39 can operate with extended hours (8am to 10pm) per
PSPS Phase 2 D.20-05-051. Through the end of September, 11 CRC
sites have been activated.
Customer Resiliency Equipment Incentives (PSPS-3)
Customer
Resiliency
Equipment
Program Target: Develop a customer resiliency equipment incentive
pilot program that provides financial support to customers willing to
increase resiliency within its HFRA. One customer will be implemented
for this pilot in 2020.
Status Update: The pilot program has been completed and the
chosen location, a local high school, now has the ability to island itself
from the grid and maintain emergency services during a power outage.
2
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