UPDATE – MAY 2019

The tragic wildfires of the past two years have highlighted decades of infrastructure neglect by PG&E clearly demonstrating that its electric transmission & distribution business model is, indeed, “Run to Failure,” as it was with its gas lines in San Bruno, rather than safety and fire prevention. New York Times: How PG&E Ignored Fire Risks in Favor of Profits. “Run to Failure,” or the policy of waiting for equipment to fail before improving it (purportedly saving money), explains PG&E’s long-standing, unconscionable focus on ever-expanding “vegetation management” as its chosen power line safety program.

Wildfires’ frequency and severity has been exacerbated by years of drought and increased population growth into wild areas. The failure to consider the significant environmental impacts of removing healthy, mature (previously protected) trees, especially Climate Change repercussions, compounds the damage, while PG&E’s priorities result in guaranteed failure to protect us all from “utility-associated wildfire” as mandated under the law.

This pattern of neglect has created unsafe conditions year-round, especially in Tier 3, high utility-associated wildfire risk — rural and forested areas — causing and exacerbating disastrous wildfires, while adding to the number of winter-weather downed power lines and power outages. (see Office of the Safety Advocate pdf)

The California Public Utilities Commission (CPUC) shares responsibility for this increasingly critical situation, having failed to set standards for fundamental, necessary infrastructure protection like circuit breakers and stronger insulated wire, while basically depending on PG&E, a for-profit corporation, to set its own standards and response – for decades.

It is a critical emergency, but it is not being treated as such. Under its Wildfire Management Plan, PG&E proposes limited infrastructure improvements, scheduled for five and ten years of testing and inspections, with minimal critical insulated wire installation, resulting in thirty years and more before adequate safety and reliability advances are in place.

While the primary infrastructure improvement focus is on hardening wires over years, there is only minimal testing of small numbers of circuit breakers, with little focus on the remarkable computerized circuit breakers, high impedance arc fault interrupters, that recognize immediately when a line breaks, and within a second or two shut it off and thus prevent any fire or any electrocutions – savings lives and preventing fires. They should be installed immediately. The technology is off-the-shelf ready, and remarkably affordable – and protects bare wire lines.

Because of this egregious failure to put safety first, or to recognize the detrimental environmental effects of taking down thousands of trees, protests are growing. Over the past few months, hundreds of environmental groups and individuals around the State have taken an in-depth look at the situation, to provide well-researched information and data to affected cities and counties, State legislators and the Governor, Judge Alsup’s Federal Court and the CPUC, seeking to motivate them to focus on infrastructure improvements while maintaining a responsible level of vegetation management. A related goal is to require comprehensive environmental impact evaluation before mandating massive projects like Enhanced Vegetation Management in the future, and to highlight the prohibitively high, duplicative financial costs.

This, coupled with media reports on PG&E’s failures, may help reform the status quo.

Note: the volunteers of The Valley Women’s Club’s Environmental Committee for the SLV have put in thousands of hours and accumulated volumes of documents and analyses, proving PG&E’s irresponsible, if not criminal, neglect. Networking with individuals from other organizations, especially the Sierra Club, who have also done intensive research, has enabled shared concerns from every county having already suffered from or being threatened by utility-caused wildfires to reach further and have greater impact. YOUR interest and involvement is important since the problem is not going away until and unless fundamental changes are made.     

The Basics

The critical situation is not just with PG&E; it is statewide. The three huge IOU’s (Investor Owned Utilities – for-profit) include Pacific Gas & Electric (PG&E – the largest), Southern California Edison (SCE), and San Diego Gas & Electric (SDGE). Each has been held responsible for disastrous, deadly wildfires impacting thousands of lives, destroying homes, businesses and wildlands, with alarming on-going human, financial and environmental impacts.

The focus of this update is primarily on PG&E, but includes similarities and contrasts of the other two major IOU’s that are acting, in good measure, in more scientific and effective ways.

Five areas are covered after this Introduction:

1. Opening Salvo, including the original articles covering our early response to the situation: evaluating the “new” Wildfire Safety Plan, as presented to the Santa Cruz County Board of Supervisors in late June, 2018; the important FORMAL SAFETY COMPLAINT to the CPUC, filed by Kevin Collins, elucidating PG&E’s failure to address the real safety issue – “to address wildfire ignition from its own equipment and instead places the burden for misguided wildfire mitigations onto its customers in the form of damage to easements on private and public land;” working to empower residents to protect their trees in the face of poorly trained, ill-informed and ignorant contracted employees determining what trees to cut, while frightened and dealing with confusing information and intimidation; distributing hundreds of “how-to” information sheets and attending public meetings to make sure the cogent questions were asked and comments made; commencing extensive research about the CPUC and PG&E, leading to disturbing revelations about the lack of change or improvement over decades of tragedy and wildfire; and, working with our County and State elected officials to gain some measure of control over the massive onslaught to remove thousands of trees;
2. Expanding on the current situation impacting Tier 3, high-utility associated wildfire threat areas;
3. Overview of the hasty, confusing SB 901-mandated CPUC Proceedings to establish new Wildfire Management Plans for the three huge IOU’s that so far, for PG&E, still focuses on Enhanced Vegetation Management;
4. Discussing Current Impacts on the Situation: the current, in one case ill-considered, Legislative response, and providing observations on the Federal Court’s continued concerns after PG&E’s criminal conviction after the San Bruno tragedy; and,
5. Ideas about what you can do to help improve the situation, to propel a State-wide focus on infrastructure improvements as the primary safety response, and on saving the mature, healthy trees that protect our watershed, reduce the impacts of Climate Change, enhance property values and provide vital habitat to myriad wildlife. Included are RESOURCES such as informational flyers, research documents, photos and more. (Return to this section since it will be expanded and improved in the coming weeks.)

For on-going revelations, updates and discussion, there are on two relevant Facebook pages, including PG&E and the SLV, and Citizens for Responsible PG&E Fire Prevention.

*Please note: The Valley Women’s Club’s Environmental Committee for the San Lorenzo Valley is dedicated to the protection and restoration of our steep and fragile watershed. Our members have spent thousands of hours over ten months, researching and analyzing information and documentation. This update is a summary of some of the most relevant, including important additions from the amazing people contacted through networking efforts. We have joined with remarkable individuals joining together under the Sierra Club’s Utility-Wildfire Taskforce; each Taskforce member is involved in a similar mission where they live, throughout PG&E’s sphere of influence. The Taskforce includes members from Santa Cruz County, and other rural and forested areas including San Mateo, Santa Clara, Butte (the location of the horrific Camp Fire), Calaveras, Solano, and others We are honored to be a part of this team, under the leadership of Karen Maki (Chair of the Sierra Club Peninsula Group’s Forestry Committee).

Disclaimer: The information presented here is provided as a public service, and every effort has been made to present accurate information, analyses, and suggestions for action, in the honest hope to improve safety and to guard the environment. However, it is up to each reader to consider what action to take, and whether to take a particular action, as an individual or a member of any group. We are not lawyers and suggest consulting an attorney if there is any concern over the consequences of any action.     

Opening Salvo: June 2018 and After – Articles and Resources

What You Need to Know About PG&E’s Wildfire Safety Program

The clear and powerful Formal Safety Complaint to the CPUC, filed by Lompico resident, Kevin Collins, regarding the failure of PG&E to improve the safety its power distribution system’s infrastructure, with link to the complaint – July 2018 

What has PG&E FAILED to do to Prevent Wildfire?

Know more about PG&E’s Wildfire Safety Program

Protect Your Trees Guidelines – How to defend your rights, your property, your trees

Letter from Supervisor Bruce McPherson and State Assemblymember Mark Stone to PG&E regarding major problems with both the tree removal itself and the untenable way it was initiated in Santa Cruz County

Supervisor McPherson’s statement describing PG&E’s wildfire safety program in San Lorenzo Valley

Original Petition to get PG&E to insulate its power lines for safety – still active! Sign and share.

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Expanding on the Current Situation – May 2019 – growing in complexity

The lack of appropriate and responsible Utility responses to wildfire threat has compounded a growing safety emergency. Far too much of PG&E’s current equipment has not been upgraded in decades to meet safety concerns – only being repaired when something fails. Most of the aboveground distribution lines are bare wire and much of the other equipment is antiquated, especially in the Santa Cruz Mountains and other rural and forested counties. Money that could go to making the infrastructure safe is going to tree removal with no guarantee that it will be effective, we feel the system of testing effectiveness is inadequate, and there is still disregard of destructive environmental effects.

PG&E currently has only 300 miles of “tree wire” (insulated wire), and plans to install only 150 miles of covered conductor this year, and then 7100 miles of covered conductor by 2029. This is glacier-slow. In stark contrast, Southern California Edison’s risk-informed decision-making has made insulated wire a high priority. It will be spending over $500 million to install almost 600 miles of insulated lines this year alone.

Throughout the San Lorenzo Valley, there are almost comic examples of virtually antique distribution lines. For example, in the riparian corridor of Pilger Creek, long outdated wires are right above the stumps of formerly majestic redwood trees (well-known for fire resistance) cut down to create the 24 to 30-foot wide corridor centered along the wires up the narrow road. (See photos under Resources.) During the hot summer, now-exposed undergrowth will dry out and become a real fire danger having lost the protection the trees’ shade had provided.

Pressured by lawsuits, criminal Court proceedings, public outcry and threatened with legislation, PG&E commenced its Enhanced Vegetation Management process without adequate prior public warning in September, 2018. Starting with private property, while negotiating encroachment permits with the County, thousands of trees were irresponsibly removed – with frightened, misinformed residents who did not know their rights in this regard, feeling compelled to allow this. Since then heavy rains have caused increased erosion, slope instability and wind-throw downed power lines when exposed trees fell.

After a brief hiatus over the winter, PG&E has revamped its PR machine – including TV ads, several new mailers, modified graphics and continuing obtuseness of language. PG&E is already returning with an even further expanded Enhanced Vegetation Management plan going back to private roads and private property. Santa Cruz County roads are not yet impacted, until and unless County Public Works provides the required encroachment permit. When that occurs, they will work on County roads as well. The County is requesting adherence to County ordinances, for environmental protection, and PG&E is resisting.

Thankfully, Kristine Conley, Engineering Associate in Santa Cruz County’s Public Works, oversees the current “regular” Encroachment Permit. She initiated a new procedure when the regular teams seemed to begin following the Enhanced Vegetation Management guidelines. PG&E has no permit for the enhanced work, but the regular teams were beginning to remove trees and to go beyond the permitted trimming. Due to complaints to Supervisor McPherson’s office, his Analyst, JM Brown informed Ms. Conley and she immediately went to check the team on Graham Hill Rd. That team was cutting down healthy, mature trees — far beyond the required 4-foot radial trimming and dead tree removal. Since then, she is closely tracking PG&E’s “regular” tree work to be sure it does not overstep its permit. Now, the local PG&E office is required to check in with her daily, to delineate where teams will be working and what the focus of the work will be. Kristine occasionally visits job sites unannounced and has responded quickly to complaints since members of the public now notice when mature trees are being cut down. This oversight procedure is in good measure the work of Supervisor McPherson’s Analyst, JM Brown, in coordination with Ms Conley.

In the meantime, the tree survey crews for the Enhanced Plan are out on both private and public roads, inspecting and confirming whether the trees marked with the yellow-X-of-eradication should be cut down. It is clear, Enhanced Vegetation Management goes far beyond the responsible, CPUC-required (GO 90) regulations of a 4-foot radial clearance (trimming) of the wires to last a year. This is despite that fact that PG&E has no metrics – no data –  to demonstrate its effectiveness. This lack of proof was specifically criticized by the CPUC’s own Office of the Safety Advocate when it evaluated PG&E’s reported response to “wires down” events. ([Investigation 17-11-003] Filed November 9, 2017) It was barely a month later that the CPUC announced the plan, ignoring this crucial deficiency, allowing PG&E to do what it wanted without proper regulation or oversight.

Significantly, despite the exponential increase in vegetation to be cleared, including previously protected mature, healthy trees, the CPUC still self-declared the Enhanced Vegetation Management as EXEMPT from CEQA environmental review, saying it was not a “program.” The CPUC also failed to inform the hundreds of cities, counties, water districts, environmental agencies and other entities affected by this exemption – and got away with it because no one noticed in time. This is exactly what happened in 2008, after a spate of severe wildfires required new safety plans. Nothing has improved in over ten years. (see pdfs in Resources)

The results throughout the rural and forested areas of the enhanced tree removal that began last Fall, are significant negative long-term environmental, social and financial impacts.

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FAILURE TO IMPROVE FROM BEFORE 2008 THRU CURRENT PROPOSED WMP’S – No CEQA

In 2008, after several severe wildfires, the CPUC set standards to increase safety yet still failed to require the infrastructure improvements. The emphasis was on inspection but the result was vegetation management. The CPUC self-declared the plans CEQA Exempt as they did with the Enhanced Vegetation Management approved in 2017 and initiated in 2018.  

Note the irony in this quote from the document that did not require upgrading the wires nor mention circuit breakers: “The Commission has long recognized that poorly maintained overhead utility facilities are a public-safety hazard. To mitigate this risk, Rule 31.2 of
GO 95 requires overhead electric supply lines and communications lines to be inspected “frequently and thoroughly to ensure that they are in good condition.” This requirement applies to all entities that own or operate overhead electric supply lines or communications lines in California, including investor-owned electric utilities.” While this requires inspecting the wires themselves, the focus was keeping vegetation away from the wires. In 2008, this wildfire plan mandated inspection, but not actual infrastructure repair.

ORIGINAL ORDER ADOPTING FIRE-THREAT MAPS & FIRE-SAFETY REGULATION, resulting in Enhanced Vegetation Management on December 17, 2017.

COMMENTS & SUGGESTIONS FROM THE OFFICE OF THE SAFETY ADVOCATE IN RESPONSE TO ENSURING GRID RESILIENCE AND PUBLIC SAFETY

The OSA reviews the statistics about the “October 2017 Fire Siege,” on p. 2. In this document, the focus by the CA Energy Commission is on critical research needs of the State to drive the development of effective mitigation programs to limit and reduce the enormous public safety impacts from wildfires. Christopher Parkes of the Office of the Safety Advocate provides cogent input on the topic. It starts with an excellent graph delineating the various equipment failures causing fires 2014-2016 and follows with its recommendations.

EARLIER EVIDENCE OF DELAYS IN PG&E MAINTENANCE – SF Public Press 2012

MOTION FOR PARTY STATUS – Santa Cruz County CAO’s well-research and effectively-expressed arguments provide a valuable analysis of the situation.

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Overview of the SB 901 Mandated CPUC Proceedings Implementing “New” Wildfire Management Plans from IOU’s

Results due end of May

The situation is rapidly growing in complexity, especially with PG&E declaring bankruptcy. Many affected by the situation are not aware that the so-called utility “bail-out” bill, SB 901 https://www.sfchronicle.com/california-wildfires/article/Legislature-to-vote-Friday-night-on-bill-13198305.php) was passed in response to the 2017 fires but did not include those of 2018, increasing liability lawsuits and resulting in PG&E declaring bankruptcy. Wisely, SB 901 also mandated that the CPUC have all three of the huge for-profit, investor-owned utilities (IOU’s) update and improve current Wildfire Management Plans. Utility Wildfire Mitigation Plans (SB 901)

Sadly, the resulting CPUC Proceeding to do this is a hasty, confusing process, with the utilities apparently steering the focus of the discussions rather than the CPUC setting standards. There have been few if any Commissioners visible at the workshops or meetings, and the procedures for having input are challenging at best. Thankfully, at our urging, the County of Santa Cruz became a Party to the Proceedings, and therefore has an official voice in the process. Its Motion for Party status has extremely well-researched and effectively-expressed statements regarding the failures of PG&E’s Plan, especially the safety failures of its Enhanced Vegetation Management. (See Resources below) It is a valuable analysis!

The Santa Cruz County CAO, Carlos J. Palacios and his staff are to be commended for their Motion, especially including Jason Hoppin who is the designated person to follow and respond to the Proceeding. However, time is running out for further input (due before March 27) and we are discouraged that there has been no further input, in spite of requests to do so with suggested topics of discussion.

PG&E’s proposed plan will result in the “treatment” – either trimming or removal — of over 300,000 trees in 2019 alone, with minimal hardening (insulated wire) of the system. PG&E has been exposed for putting profits over safety because their business model that has always been based on “RUN TO FAILURE,” i.e.running equipment until it fails rather than upgrading vulnerable areas to assure safety. We have seen that PG&E’s policy assumes that most of those failures would occur in the winter; thus, they completely underestimate the possibility of line failure during the summer causing wildfires, and ignore the electrocution hazards year-round – as well as the delays in making repairs in the rainy season. They didn’t pay attention! No one shut off the Reclosers (ineffective circuit breakers) that shut off power in Napa and Sonoma, and then, because they have no ability to recognize where a broken wire may be, Reclosers automatically turned power back on to “test” the wire. This resulted in the downed broken wire sparking again and again — igniting grasses and spreading the fire further. Outmoded equipment, allowed to fail rather than being upgraded with high impedance arc fault interrupters to be resistant to breaking and preventing ignition when broken wires fell to the ground.

This happened again in Paradise, where a large tower (over a decade past its replacement date) broke down and sent sparks, igniting the deadly Campfire.

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Discussing Current Impacts on the Situation

Legislative Response so far – March 2019

Adding to the complexity, members of the State Legislature have been legitimately looking for ways to control the problem. Senator Jerry Hill (who represents the District where San Bruno’s tragic explosions and fire occurred, resulting in criminal convictions of PG&E) has introduced three important bills worth supporting, but they do not address the safety issues of distribution lines https://sd13.senate.ca.gov/news/2019-02-22-senator-hill-introduces-legislation-protect-pge-ratepayers. 

Sadly, the one bill so far that focuses on vegetation, SB 247, introduced by State Senator Bill Dodd of Senate District 3, will add to the confusion and may well exacerbate the problem. Senator Dodd has profound interest in this issue; he represents a broad area, including parts of Contra Costa, Napa, Sonoma, Yolo, Sacramento and Solano counties – much of which was heavily burned in 2017. SB 247 assigns the Department of Forestry (CalFire) the responsibility of inspecting and identifying the trees that should be removed or trimmed along PG&E’s distribution lines. It is questionable that this is the logical and reasonable way to improve PG&E’s response. It is obviously an enormous amount of work and expense for CalFire, if they do it right, and it adds another agency to the already crazy situation, since it doesn’t remove the CPUC from its regulatory powers.

In addition, with Forestry identifying trees there is the potential of increasing the number of trees removed since they don’t hesitate to cut down trees. In addition, the bill emphasizes the removal and trimming of trees in the vicinity of the power lines. This phrase could be interpreted to include hundreds of feet from the wires, leaving too much leeway for CalFire to determine what needs to be removed/trimmed in relationship to the wires. Most significantly, it both neglects environmental impact evaluation and totally removes the rights of private property owners and local governments to question the validity of the choice and number of trees; it further undermines property values and scenic values, and has the potential to further undermine other significant environmental issues. We urge that Senator Dodd be asked to reconsider this bill.

Courts involved

Various Courts are involved with civil lawsuits and, significantly, the Federal Court under Judge Alsup is involved because of his previous judgements in the criminal prosecution of PG&E resulting from the San Bruno disaster. Judge Alsup is actively establishing mandates for action by PG&E that recognize the need for infrastructure improvements, but, so far, fail to elevate any such improvements to primary importance, and are more focused on trees and vegetation. https://www.sfchronicle.com/business/article/Cal-Fire-says-PG-E-doesn-t-have-to-remove-all-13599233.php. We have reached out to Judge Alsup and encourage you to do so as well, by emailing his staff member, Lynn Fuller <Lynn_Fuller@cand.uscourts.gov> to encourage him to require strong, insulated wire and installation of high impedance arc fault interrupters, and to limit vegetation management (but enforce its completion) to the required 4-foot radial clearance for a year.

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Ideas about what you can do to help improve the situation

Personal involvement with emails, phone calls, attending meetings… contacts:

(coming soon)

Resources

(coming soon)

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