data request set t u r n - s c e - 0 0 2 to: turn ......southern california edison a.19-08-013 –...

Southern California Edison

A.19-08-013 – SCE 2021 General Rate Case

DATA REQUEST SET T U R N - S C E - 0 0 2

To: TURN Prepared by: Jesse Rorabaugh

Job Title: Senior Engineer Received Date: 10/17/2019

Response Date: 10/30/2019

Question 03.a-d: SCE-04, Vol. 5, p. 18, lines 9-10, state that the “implementation of such multiple mitigations has resulted in marked improvement in bushfire risk performance [in Australia].” a. Please provide all documents and other sources (including any emails or notes of conversations) on which this statement is based. b. Please provide the number and percentage of overhead circuit miles that relevant Australian utilities have deployed covered conductor on. Please provide all supporting documentation. Please provide as a percentage of total miles and equivalent “high threat fire district” miles if available. c. Please provide a list of risk of reduction measures deployed by Australian utilities and indicate which are the same as SCE’s proposals. d. Please provide all reports known to SCE regarding evaluation of the performance of various risk mitigation measures in Australia. Response to Question 03.a-d: SCE objects to use of the phrase “all documents” in this Data Request as vague, ambiguous and overly broad and potentially burdensome. SCE also objects to the extent that the request calls for the production of documents protected by the attorney-client privilege, attorney work product doctrine, or other relevant protections and privileges. SCE additionally objects to the extent the request calls for the production of documents considered confidential pursuant to the Commission’s confidentiality rules or are proprietary to SCE or its third-party contractors and vendors, in the absence of an executed Non-Disclosure Agreement. Subject to and without waiver to the foregoing objections, SCE responds as follows:

a. The documentation used in this analysis are listed below; additional information for some of these topics can be seen in the answer to section d. Documents are only mentioned in a or d depending on where they best fit; documents were not duplicated between the lists.

Progress Report Victorian Bushfire Royal Commission Implementation of Recommendations and Actions, August 1, 2015

Progress Report Victorian Bushfire Royal Commission Implementation of Recommendations and Actions, August 1, 2016

Fact Sheet Powerline Replacement Fund

Summer Preparedness Plan, 2017-18, October 9, 2017

Bushfires Royal Commission Implementation Monitor Annual Report July, 2013

TURN‐SCE‐002: 03.a‐d of 5

Bushfires Royal Commission Implementation Monitor Final Report July, 2012

Bushfires Royal Commission Implementation Monitor Progress Report July, 2011

SCE visit Dec 2018 – BFM

Progress Report Victorian Bushfires Royal Commission, Implementation of Recommendations and Actions, August 1, 2016

Powerline Replacement Fund Making Victoria’s Powerlines Safer, December 2016

Research & Development Project February 2018

January 2019 AusNet emails

Victoria’s journey to fire-safe electricity networks January 18, 2019

Powerline Bushfire Safety Pre-Course Workshop, June 24, 2019

Powerline Bushfire Safety Day 1 Network Fire Risk, June 24, 2019

Powerline Bushfire Safety Day 3: Limiting earth Fault Current (NERs, ASCs, REFCLs, SSFCLs), June 26, 2019.

Early Fault Detection (EFD) Technical Briefing, June 25, 2019

Bushfire Ignition from Electric Arcs, June 25, 2019

Powerline Bushfire Safety Management A Holistic Approach, June 25, 2019

2014 REFCL Trial REFCLs can cut fire-risk, June 26, 2019

Powerline Bushfire Safety Short-Course - Harmonics, June 26, 2019

REFCLs in Practice the Program Experience, June 27, 2019

2015 Vegetation Conduction Ignition Research, June 27, 2019

2015 REFCL Technologies Test program at Kilmore South, June 28, 2019

b. SCE does not have the requested data. However, SCE is aware of related information as described below.

In 2016, regulations in Victoria, Australia changed to require covered conductor for new and replacement installations of overhead electrical lines in their codified areas.1 Thirty-three codified areas have been identified by the Government as having the highest fire loss consequence. It is estimated that, on average, electrical lines in codified areas will be replaced within 25 years. Maps of all thirty-three codified areas are available at:

https://www.energy.vic.gov.au/safety-and-emergencies/powerline-bushfire-safety-program/electrical-safety-bushfire-mitigation-further-amendment-regulations-2016/electric-line-declared-energy-maps

In addition to the regulatory change, a $200 million Powerline Replacement Fund was commenced by the Government in 2013 with the goal of replacing electrical lines in highest priority Local Government Areas due to wildfire risk. By December 2019, 555 kilometers of electrical lines will be replaced with covered conductor or underground lines through the Powerline Replacement Fund.

1 Electricity Safety (Bushfire Mitigation) Amendment Regulations 2016 S.R. No. 32/2016


c. As Australia has many utilities working on a great many different proposals, it is infeasible to produce an exhaustive list. A list of the most prominent programs in the Australian state of Victoria can be found on the third slide of the file “Victorias journey CEC-CSIRO 18 Jan 2019.pptm.” Those which are similar to SCE programs have been marked below:

• Dampers and armour rods

• More frequent line inspections and pole tests – In 2021 GRC

• Thermal scanning of assets – In 2021 GRC

• LIDAR assessment of vegetation clearances – In 2021 GRC

• Conductor spacing survey and remediation (spacers) – In 2021 GRC

• Upgrading of HV fuses or replacement with ACRs – In 2021 GRC

• Upgrade of old hydraulic ACRs to modern “smart’ types – Not applicable to SCE

• Enhanced ACR settings – In 2021 GRC

• Fuse-savers as ACRs – In evaluation

• Insulated conductors on pole tops

• Selective covered conductors – In 2021 GRC

• Selective undergrounding – In 2021 GRC

• Enhanced enforcement of vegetation clearances – In 2021 GRC

• Processes to manage hazard trees – In 2021 GRC

• Fire loss consequence maps for plans and priorities – In 2021 GRC

• Hi-res aerial surveys with centralised image evaluation – In 2021 GRC

• Earth fault ignition R&D

• Vegetation fault ignition research

• Vegetation fault signature research

• Installation of REFCLs – Feasibility being evaluated as part of SB901

• Development of fire risk models – In 2021 GRC

• Trial of Early Fault Detection (RF) line monitoring –Distribution Fault Anticipation 2021 GRC


d. The following attached reports evaluate various risk mitigation measures from Australia. Please note that in some cases, the entire reports are devoted to the topic whereas in other cases only a small section is devoted to the topic.

Regulatory Impact Statement for the Bushfire Mitigation Regulations Amendment, November 2015

REFCL technologies test program final report, December 4, 2015

REFCL trial ignition tests August 4, 2014

Non-network Options to Comply with Bushfire Mitigation Regulations, August 2017

Final Decision AusNet Services Contingent Project Installation of Rapid Earth Fault Current Limiters (REFCLs) – tranche 1, August 2017

Powercor Contingent project application REFCL program: tranche two, April 2018

Powerline Bushfire Steering Committee REFCL Program Update, December 5, 2016

Interim Report Probability of Bushfire Ignition from Electric Arc Faults September 2011

New Technology to cut Victoria’s Powerline Fire Risk, September 2016

Powerline Bushfire Safety Program Ignition Tests – Lo-Sag Conductor, December 4, 2015

Review and Audit of SECV Bushfire Mitigation Program, October 1991

Bushfire Mitigation Program – Audit Action Plan Analysis of Fault Energy/Fire Starts Relationship, June 18 1992

National workshop on rural electricity network options to reduce bushfire risk, June 2010

Victorian Government Response to the Victorian Bushfires Royal Commission Recommendations 27 and 32, December 2011

Powerline Bushfire Safety Taskforce Final Report, September 30, 2011

Effect of Auto-Reclose Delay on Ignition Probability from Electric Arcs in Powerline Faults, April 2013

Analysis of resonant Earthed Networks, February 2015

Vegetation Conduction Ignition Tests, July 16, 2015

The definite health risks from cutting power outweigh possible bushfire prevention benefits, October 15, 2012

Customer assets directly connected to REFCL networks: a preliminary risk survey

EFD SWER Trial Final report, June 23, 2019

Bushfire Risk Management Plan - Essential Energy, March 27, 2017

Inquiry into the Fire at Springwood NSW 17 October 2013 and the Fire at Mt Victoria NSW 17 October 2013

Bushfire Prevention and Electricity Distribution, April 1985

Powerline Bushfire Safety Taskforce, September 30, 2011

New Research on Bushfire Ignition from Rural Powerlines, February/March 2012

Victoria’s REFCL Rollout, October/November 2018

Prevention of Bushfires from Powerline Vegetation Faults, June/July 2018

Prevention of Bushfires from ‘Wire Down’ Powerline Failures, Febryary/March 2018


2009 Victorian Bushfires Royal Commission Final Report Summary , July 2010

2009 Victorian Bushfires Royal Commission Final Report Chapter 4 Electricity Caused Fire, July 2010




To: TURN Prepared by: Tram Camba Job Title: Senior Advisor Received Date: 6/15/2020


Question 08.a-b: Page 18, lines 23-25, state “there are no effective substitutes to the WCCP that will provide the corresponding amount of risk reduction, in the time it can be provided, without cost-prohibitive customer impacts.” a. Please provide SCE’s definition and an explanation of “cost-prohibitive customer impacts.” b. Please quantify in percentage increase terms what SCE would consider a “cost-prohibitive impact” Response to Question 08.a-b:

a. In Exhibit SCE-15, Vol. 05, pp. 29-30, SCE explains that only three mitigation programs span and mitigate, at least partially and with the same level of effectiveness, each of the Contact from Object and Wire-to-Wire contact risk drivers: covered conductor, repeated and increasing use of PSPS, and widespread undergrounding. SCE estimates the cost per mile of covered conductor as $0.421 million per mile and targeted undergrounding as $3.370 million per mile (constant $2018). Additionally, targeted undergrounding has five times lower risk-spend efficiency (RSE) than that of covered conductor, and it takes longer to be deployed. Due to the lower RSE, longer deployment time, and higher cost per mile of targeted undergrounding, SCE concludes that it would not be financially prudent to suggest deploying a more expensive undergrounding solution, at the scale required to address the wildfire risk in SCE’s HFRA, when there is a more cost efficient and higher RSE solution in WCCP that can more quickly and feasibly address wildfire risk. The repeated and increased use of PSPS is also not a viable option as described on p. 28 of Exhibit SCE-15, Vol. 05.

SCE does not maintain a specific percentage increase term or threshold for what would be considered “cost-prohibitive” in this situation. Please see response to part (a).




To: TURN Prepared by: Tram Camba Job Title: Senior Advisor Received Date: 6/15/2020


Question 10: If SCE does not install covered conductor on a given circuit in the HFRA will there be no other risk mitigation measures in place on that circuit? If no, please identify the other mitigation measures that SCE will deploy on that circuit. Response to Question 10:

To adequately address wildfire risk, it is often necessary to deploy multiple mitigation measures on a given circuit whether or not covered conductor is installed. For example, on circuits that either have covered conductor installed or not, SCE will continue to perform inspections, repair equipment as necessary, follow recommended and required vegetation management practices, etc. SCE’s other applicable wildfire mitigations are discussed in Exhibits SCE-04, Volume 5 and SCE-02, Volume 6 of this GRC, and in SCE’s 2020-2022 Wildfire Mitigation Plan.




To: TURN Prepared by: Gary Cheng Job Title: Senior Advisor Received Date: 6/15/2020


Question 13: Please explain whether covered conductor, absent other mitigations, will reduce 100% of ignitions on SCE’s system. If not 100%, please quantify the percentage of ignitions that SCE predicts that covered conductor, absent other mitigations, will reduce. Response to Question 13:

Covered conductor is not 100% effective in reducing all ignitions.

Please refer to SCE-15 Vol. 5 (“2021 General Rate Case Rebuttal Testimony – Wildfire Management”), pg. A-5 for a summary of covered conductor mitigation estimated effectiveness as it pertains to ignitions within HFRA.




To: TURN Prepared by: Eric X Wang

Job Title: Prdctve Anlytcs/Data Science, Sr Advisor Received Date: 6/15/2020


Question 17.a-j: Regarding page 25, Figure II-3, in Excel please provide a list of each fire showing the following information for each fire in a separate row and separate columns: a. Date of ignition; b. Cause of ignition; c. Size of fire; d. Structures burned (number); e. Financial damage; f. Whether SCE had deployed any of its mitigation measures to the area, including, but not limited to, covered conductor; g. SCE Equipment involved; h. Whether a Red Flag Warning had been called; i. Whether the following could have stopped the ignition or resultant spread from occurring (yes/no): i. Vegetation Management (routine); ii. Vegetation Management (enhanced); iii. Sectionalization; iv. Fusing Mitigation; v. Enhanced Overhead Inspections and Remediations; vi. Enhanced Situational Awareness; vii. PSPS; viii. Covered Conductor. j. Please provide an accompanying explanation and all evidence for the answer provided in part (i). Response to Question 17.a-j:

a. Please see column “Date” of file “TURN-SCE-077_Q17.csv” b. Please see column “Suspected Initiating Event” of file “TURN-SCE-077_Q17.csv” c. Please see column “Size” of file “TURN-SCE-077_Q17.csv” d. The information was not captured at the time of the event investigation. e. The information was not captured at the time of the event investigation. f. The information was not captured at the time of the event investigation. g. Please see column “Equipment Involved With Ignition” of file “TURN-SCE-077_Q17.csv” h. Please see column “RFW?” of file “TURN-SCE-077_Q17.csv”

TURN-SCE-077: 17.a-j Page 2 of 2

i. SCE objects to the question as it is an incomplete hypothetical, calls for speculation and is vague and ambiguous as to the word “could.” It is practically infeasible to determine after the fact with certainty if a particular historical ignition “could” have been prevented by a particular mitigation measure. SCE also notes that the mitigation measures are designed to reduce ignitions, not “resultant spread” of the wildfire. The importance of showing these ignitions is the consequence that was captured along these circuit segments (acres burned). No matter the driver of the ignition, the consequence in these locations can be catastrophic as demonstrated by these large fires. Deploying covered conductor on these circuit segments will help mitigate over 60% of those ignition drivers along these circuit miles.

j. See response to question i.

Circuit Date Time Latitude Longitude Material at Origin Land Use at Origin Size Suppressed by Suppressing Agency Facility Identification FLOC HFRA HFTD Other CompaniesVoltage(Volts) Equipment Involved With IgnitionType Was There an OutageSuspected Initiating EventEquipment /Facility FailureContact From ObjectFacility ContactedContributing FactorRFW?

Hi Line 6/23/2014 13:15 0 -118.72947 Vegetation Rural 10 - 99 Acres Fire Agency Cal Fire 00 Old Stage, Glennville, CA 93226 OH-1492845E Extreme/Tier 3 Y Unknown 12kV Conductor Overhead Yes Contact From ObjectConductor Vegetation Electric FacilityUnknown NoBirchim 2/6/2015 13:15 37.45396 -118.584196 Vegetation Rural Greater than 5000 Acres Fire Agency Various Fire Agencies Between Poles 1854107E & 1854106E OH-1854107E Elevated/Tier 2 Y Phone & Cable 12kV Conductor Overhead Yes Unknown Unknown NoSexton 2/22/2015 9:52 34.28487 -119.217293 Vegetation Rural 10 - 99 Acres Fire Agency Ventura Fire Department Pole 1718768E OH-1718768E Extreme/Tier 3 Y Phone & Cable 16kV Other Overhead Yes Unknown None NoAcres 7/3/2015 15:02 33.55365 -117.774982 Vegetation Urban 10 - 99 Acres Fire Agency Orange County Fire Pole 1873216E OH-1873216E Extreme/Tier 3 Y Phone & Cable 12kv Conductor Overhead Yes Contact From Object Vegetation Electric FacilityUnknown NoTICO 4/28/2016 14:00 34.357 -119.314044 Vegetation Rural 10 - 99 Acres Fire Agency Ventura County FD OH-1604151E OH-1604151E Extreme/Tier 3 Y 16 kV Conductor Overhead Yes Equipment/Facility FailureOther Unknown NoSKINKLE 5/29/2016 22:25 36.00912 -118.956283 Vegetation Rural 10 - 99 Acres Fire Agency Cal Fire OH-4566417E OH-4566417E Elevated/Tier 2 Y AT&T CALIFORNIA12 kV Conductor Overhead Yes Contact From Object Other Electric FacilityUnknown NoCACHUMA 8/18/2016 14:52 34.53557 -119.852255 Vegetation Rural Greater than 5000 Acres Fire Agency Santa Barbara County Fire Department OH-1413051E OH-1413051E Extreme/Tier 3 Y FRONTIER COMMUNICATIONS16 kV Conductor Overhead Yes Contact From Object Vegetation Communication FacilityUnknown YesMIST 8/24/2016 16:37 34.46645 -120.070103 Vegetation Rural 10 - 99 Acres Fire Agency Santa Barbara County Fire Department Refiugio Canyon, Santa Barbara OH-4538468E Elevated/Tier 2 Y 16 kV Conductor Overhead Yes Contact From Object Animal Electric FacilityUnknown NoMAYER 4/28/2018 14:23 33.68204 -117.327603 Vegetation Urban 10 - 99 Acres Fire Agency Fire Agency Langstaff & Camino Del Norte in Lake OH-2225121E Elevated/Tier 2 Y 33 kV Conductor Overhead Yes Contact From Object Balloons Electric FacilityUnknown No




To: TURN Prepared by: Nathanael Gonzalez

Job Title: Senior Advisor Received Date: 6/15/2020


Question 18: Page 28, lines 7-8, state “Covered conductor also has additional benefits beyond reducing wildfire risk– if deployed effectively, it can reduce the activation of PSPS events.” Does SCE commit to not calling PSPS for circuits or circuit segments where covered conductor has been deployed? Please explain. Response to Question 18:

SCE cannot commit to not calling PSPS for circuits or circuit segments where covered conductor has been deployed because the decision of whether to conduct a PSPS de-energization is based on many factors. The state of implementation of grid hardening measures on a specific circuit is one such factor. PSPS is an important tool in mitigating wildfire risk and protecting public safety.

However, a circuit being fully deployed with covered conductor will result in lessened wildfire risk, and therefore lessened PSPS risk, all other factors remaining equal. According to SCE’s current PSPS protocols, a circuit or isolatable circuit segment that is constructed fully with covered conductor will be evaluated for PSPS de-energization at higher wind thresholds, however, other circuit and circuit segment specific factors are still considered to determine the ultimate de-energization wind speed threshold.




To: TURN Prepared by: Hunly Chy

Job Title: Manager Received Date: 6/15/2020


Question 21: Page 32, lines 4-8, state “For example, as a result of devastating bushfires in Australia, the 2009 Victorian Bushfires Royal Commission issued a report listing a variety of recommendations, among which were installing covered conductor and removing trees outside of the clearance zone but could come into contact with an electrical power line. The implementation of such multiple mitigations has resulted in marked improvements in bushfire risk performance.” Please provide the percentage (of sum total overhead miles in the utility’s extreme, severe, and high risk areas) and total number of circuit miles, respectively, of the Australian utility’s “high-risk” areas where covered conductor has been deployed. Please provide supporting workpapers and sources. Response to Question 21:

Refer to Data Request TURN-SCE-002, Question 03.b for SCE’s response to this request.




To: TURN Prepared by: Raymond Fugere

Job Title: Manager Received Date: 6/15/2020


Question 25: Page 34, lines 18-19, state “This logic is based on preventing pole-top ignitions from equipment sparks and ensuring pole structure integrity from woodpecker damage.” Please provide the number of historical ignitions in SCE’s territory due to woodpecker damage. Response to Question 25: For CPUC reportable events between 2014 and 2019, SCE did not report that any fire was caused by woodpecker damage. The plaintiffs in the Thomas Fire litigation allege that the Anlauf Canyon fire ignited when a pole, weakened by woodpecker damage, broke during a high-wind event; however, SCE disputes this contention.