Details for: 4327-E (Part 1 of 1).pdf

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

October 30, 2020
(U 338-E)

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

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
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.
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

CPUC WMP approval statement available at:
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 (U 338-E) -2- October 30, 2020 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:
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ADVICE 4327-E (U 338-E) -3- 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 (U 338-E) -4- 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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ADVICE 4327-E (U 338-E) -5- October 30, 2020 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 (U 338-E) -6- October 30, 2020 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 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: 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: 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 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 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
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ADVICE 4327-E (U 338-E) -7- October 30, 2020 For questions, please contact Kavita Srinivasan at (626) 302-3709 or by electronic mail at 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: 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) #: 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: 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: 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: 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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