20240809PAC to Staff 69 Attachment.pdf

_ ROCKY MOUNTAIN 1407 W. North Temple,Suite 330
POWER. Salt Lake City,UT 84116
A DIVISION OF PACIFICORP
May 30, 2024
VIA ELECTRONIC FILING
Utah Public Service Commission
Heber M. Wells Building, 4t'Floor
160 East 300 South
Salt Lake City, UT 84114
Attention: Gary Widerburg
Commission Administrator
RE: Docket No.24-035-28—Rocky Mountain Power's 2024 Wildland Fire Cost and
Compliance Report
Pursuant to Utah Code § 54-24-201(4) and 54-24-202(2) and Administrative Code R746-315-3,
PacifiCorp, d.b.a. Rocky Mountain Power, ("the Company") hereby submits its 2024 Wildland
Fire Cost and Compliance Report("Report").
The Company respectfully requests that all formal correspondence and requests for additional
information regarding this filing be addressed to the following:
By E-mail (preferred): datarequestkpacificorp.com
utandockets(&,pacificorp.com
j ana.s abakpacificorp.com
daniel.teimouri(d),pacificorp.com
By regular mail: Data Request Response Center
PacifiCorp
825 NE Multnomah, Suite 2000
Portland, OR 97232
Informal inquiries may be directed to Jana Saba at [phone].
Sincerely,
A qLa..-LD
Joelle Steward
Senior Vice President, Regulation

ROCKY MOUNTAIN
POWER
A DIVISION OF-FICOR1
Utah Wildfire Mitigation
Plan
Cost and Compliance Report
June 1, 2024
Page /1

1 INTRODUCTION
Consistent with Utah Code § 54-24-201(4), § 54-24-202(2), and R746-315-3, Rocky
Mountain Power ("the Company") submits this Annual Cost and Compliance Report
("Report"), which provides the following:
1. Details of the Company's wildfire mitigation efforts undertaken in 2023 in
compliance with the Plan as filed in Docket No. 23-035-44;
2. The actual capital investments and expenses incurred in calendar year 2023 to
implement the Wildfire Mitigation Plan ("WMP" or "the Plan")' filed in Docket No.
23-035-44, and an updated forecast of the capital investments and OMAG
(operations, maintenance administrative and general expenses (also referred to as
Expense in this document)) for 2024; and
3. Changes, if any, incorporated into the WMP during the previous year and the
reason for the changes in accordance with the Public Service Commission of Utah's
October 13, 2020, order in Docket No. 20-035-28. Rocky Mountain Power's
Revised 2023 Utah WWMP in Docket No. 23-035-44.
In 2023, Rocky Mountain Power worked diligently to implement the measures set forth in
the 2023-2025 WMP2. The core principles of the WMP include system-wide situational
awareness and operational readiness systems, which are central to identifying and mitigating
fire risk. The impact of a fault event can be minimized by using equipment and personnel to
isolate the fault and ensure power is safely restored. The frequency of ignition events related
to electric facilities can be reduced by engineering a more resilient system, targeted in fire
high consequence areas.
2 COMPLIANCE WITH THE PLAN
2.1 RISK MODELING AND DRIVERS
1 The terms"wildland fire protection plan"and"wildfire mitigation plan"are synonymous.
2 Wildfire mitigation plan is in reference to the Rocky Mountain Power's Revised 2023 Utah Wildland Fire Protection Plan as
filed on February 28,2024,in Docket 23-035-44. Docket No:23-035-44 1 Public Service Commission(utah.gov)
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Risk Modeling Tools
Complete development of combined composite risk score - In 2023, Rocky Mountain Power
began implementing FireSight, which is part of a broader suite of software from Technosylva
referred to as Wildfire Analyst (WFA-E). The FireSight modeling associates wildfire hazards
with the location of existing electric assets. The modeling is used to estimate the probability
and consequence or impact of a wildfire from a given ignition point along Rocky Mountain
Power electric infrastructure. There are two primary parts to the FireSight model: Risk
Associated with the Asset Location (RAIL) and Risk Associated with Value Exposure (RAVE).
In 2023, attributes from RAIL and RAVE were used to calculate risk scores for wind-driven
fires and fuel/terrain-driven fires which were combined to create a composite risk score for
circuits in the service territory.
Fire High Consequence Area (FHCA)
Complete FHCA map update - Throughout 2023, the new modeling tools along with new
data and processes were used to evaluate areas throughout Utah for inclusion in the FHCA.
The FireSight model was used to model risk scores for wind-driven and fuel/terrain-driven
fires on each circuit. Areas that were modeled to be within the 85-100 percentile of the
composite risk score were classified as FHCA. The updated modeling and criteria resulted in
an FHCA map update with the addition of approximately 1,400 miles of distribution and
transmission lines. Implementation of the updated FHCA will begin in 2024,and the Company
clarifies that references to FHCA work performed in 2023 throughout this report refer to the
FHCA map prior to the update in late-2023/early-2024. The 2023 FHCA map included 220
miles of transmission lines and 429 miles of distribution lines to total 649 combined line miles
within the FHCA.
2.2 INSPECTION AND CORRECTION PROGRAM
Distribution and Transmission Facility Point Inspection and Correction
Continue planned inspection programs on transmission and distribution lines - In 2023, Rocky
Mountain Power continued inspections in accordance with its general inspection policies and
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procedures for areas within the FHCA. The inspections include visual safety inspections and
detailed inspections. Table 1 below shows a summary of the planned versus completed asset
inspection programs.
Table 1:2023 Asset Inspection Program Summary
Planned Completed Outstanding
Inspection Program (Facility Point (Facility Point (Facility Point
Count) Count) Count)
Distribution Visual Safety 17,407 17,422 0
Transmission Visual Safety 20,888 20,888 0
Distribution Detail 1,433 1,433 0
Transmission Detail 4,149 4,149 0
Table 1 summarizes that all the planned inspections in 2023 were completed with an
additional 15 visual safety inspections performed. Table 2 below summarizes the conditions
that were corrected throughout 2023 as a result of the inspection programs and the condition
priority.
Table 2:2023 Summary of Open and Corrected Conditions Identified
Energy Open Corrected
Area Release Condition Correction Timeframe Conditions* Conditions
Risk
FHCA Yes Imminent Dispatch correction immediately 0 46
FHCA Yes A 60 days average 14 42
@FHC Yes B 12 months 111 941
A
FHCA No A 120 days average 7 351
FHCA No B not specified 2,968 966
2023 FHCA 3,087 2,732
*Open conditions as of December 31,2023
Table 2 shows there are 112 total open energy release risk conditions identified in 2023.
Energy Release Conditions, as defined by Asset Management's general policy for condition
priorities and correction time frames, are a type of condition that, under certain
3 Planned values are based on the 2023 FHCA map.The map update that happened at the end of 2023 did not result in any
planned changes for the 2023 calendar year.
4 At the time of filing the cost and compliance report this priority A condition has been cleared.
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circumstances, can correlate to an increased risk of a fault event and potential release of
energy at the location of the condition. These conditions are a priority and scheduled to be
corrected when locations can be safely accessed by line operations. Open conditions indicate
that the defect still exists, but this does not necessarily mean that the corrections are overdue
or outside of the specified correction timeframe.
Transmission Infrared Inspection
Continue enhanced infrared inspections - The infrared inspection is performed to detect
potential conditions or"Hot Spots" that could be un-identifiable through the other inspection
programs. The lines are scheduled for inspection during peak loading to increase the
probability of identifying a thermal rise through the inspection, indicating a potential
condition. Table 3 shows the summary of planned and completed line miles for the
transmission infrared inspections in 2023.
Table 3:2023 Transmission Infrared Inspection Summary
Inspection Program Planned5 Completed Outstanding
(Line Miles) (Line Miles) (Line Miles)
Transmission Infrared Inspection 1,638 1,077 561
Table 3-indicates that Rocky Mountain Power completed inspections for 1,077 miles, leaving
561 miles outstanding. The outstanding lines have not been inspected because, due to the
nature of infrared, hotspots are more visible during peak loading, or when the lines have
increased power draw. Therefore, inspections are scheduled during peak loading. Towards
the end of the peak loading season in August, when 1,067 line miles were scheduled to be
inspected,the vendor had a helicopter crash which prevented the 1,067 line miles from being
inspected at that time. The lines missed had the peak loading intervals re-evaluated for
alternate inspection times, and 506 of the 1,067 line miles were able to be inspected in
October and December. The 561 line miles that were not re-scheduled, due to peak loading
5 Planned values are based on the 2023 FHCA map.The map update that happened in 2023 did not result in any planned
changes for the 2023 calendar year.
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constraints, are set for inspection in the 2024 IR inspection program.
2.3 VEGETATION INSPECTION AND MANAGEMENT
Continue planned vegetation management programs - In 2023 the vegetation management
activities continued, which included an annual inspection of circuits within the FHCA,
extended clearances for vegetation in the FHCA, and pole clearing at the base of identified
poles.The annual inspection is performed to identify any vegetation that might pose a contact
risk with the energized lines so that it can be identified for corrective actions. The extended
clearances are performed to reduce the risk that vegetation growth will exceed the minimum
distance to the energized lines prior to the next cycle. Pole clearing on equipment poles
located in the FHCA involves removing all vegetation within a 10-foot radius, extending up
to eight feet vertically, around each pole. Herbicides and/or soil sterilants are then applied to
prevent vegetation regrowth.This ensures that if the equipment on the targeted pole releases
a spark, there will be no vegetation below to ignite a fire. Table 4 summarizes the planned
line miles for inspections and pruning.
Table 4:2023 Vegetation Inspection and Pruning Summary
Planneds Outstanding
Inspection Program Miles Completed Miles Miles
FHCA Distribution Inspection 1,198 1,198 0
FHCA Transmission Inspection 218 218 0
FHCA Distribution Pruning 1,198 1,198 0
FHCA Transmission Pruning 218 218 0
As shown in Table 4 above, Rocky Mountain Power completed all inspections within the
FHCA. There were 1,198 miles of distribution lines inspected and pruned, and 218 miles of
transmission lines inspected and pruned.
Table 5 shows the work completed as a result of performing the vegetation management
programs.
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Table 5:2023 Vegetation Corrections
Vegetation Corrections Total Count
Trees Removed 805
Trees Pruned 7,154
Poles Cleared 4,603
2.4 ENVIRONMENTAL PROGRAM
Avian Protection Plan and Wildlife Protection Plan
Continued avian protection plan work - Rocky Mountain Power continued implementation of
its Utah Avian Protection plan. The avian protection plan is intended to address avian
electrocution risks by reducing the likelihood of bird or animal contact.The plan includes pro-
active actions including nest management, substation protections, and line element
protections or pole retrofits. Nest management activities include relocating the nest or
installing avian guards. The activities are performed to reduce the risk of animal contact with
energized lines. Pole retrofits are performed to reduce nesting or animal contact in areas
where previous incidents have occurred. The Company also partnered with HawkWatch
International to install or maintain nest boxes for cavity nesting birds that could be impacted
by removal of nest sites through vegetation management of dead or dying trees. Table 6
summarizes the completed activity for the avian protection plan in 2023 for nests managed,
poles retrofitted, and nest boxes installed or maintained.
Table 6:2023 Avian Protection Plan Summary
Environmental Project Planned6 Completed Outstanding
Nests Managed 52 105 0
Poles Retrofitted 3,095 3,429 0
Nest Boxes for Cavity Nesting 500 0
Birds
Table 6 shows that there were 53 additional nests managed and 334 additional poles
6 Planned values are based on the 2023 FHCA map.The map update that happened in 2023 did not result in any planned
changes for the 2023 calendar year.
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retrofitted. The nest managed planned number is based on an average amount of nests in a
typical year but in 2023 there was an increase in emerging nests that required management.
The additional pole retrofits were completed due to efficiency in work and favorable
contracts. As shown in Table 20 the work performed was still within the planned budget.
Habitat and Fire Resiliency
Complete habitat project scoping - The Company worked with Pheasants Forever in 2023 on
the Intermountain West Joint Venture's Forest Habitat program. The program identifies
habitat improvement projects that can be implemented to support healthy, fire resilient
forests across large landscapes involving multiple public and private partners. The projects
mitigate the wildfire risk both within Rocky Mountain Power's service territory and adjacent
to the Company's infrastructure by removing dead and dying trees, restoring vegetation to
encourage fire resiliency, improving the water quality, and increasing the water volume to
reduce the possibility and impact of a wildfire in the project areas. In 2023 the project scopes
were completed and funded, with work set to begin in 2024.
2.5 SYSTEM HARDENING
Line Rebuild Program
Complete 2023 line rebuild projects - The company's line rebuild program involves overhead
lines within the FHCA that were constructed with bare overhead conductor. As part of the
program the lines may either be moved, removed, converted to underground, rebuilt, or
retrofitted with more resilient materials such as covered conductor or non-wooden poles.
Table 7 shows the 2023 planned line rebuild miles and the miles that were completed.
Table 7:2023 Line Rebuild Summary
Line Rebuild Project Planned? Completed Outstanding
Transmission Miles 12 12 0
Distribution Miles 37 37 0
Total Miles 49 49 0
Planned values are based on the 2023 FHCA map.The map update that happened in 2023 did not result in any planned
changes for the 2023 calendar year.
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As a result of the line rebuild program the planned scopes for 2023 were completed on the
distribution and transmission miles identified in the line rebuild project. The completion of
the projects are line miles that were hardened with covered conductor or more resilient
materials.
Advanced System Protection
Complete 2023 planned equipment upgrade projects - The replacement and upgrading of
electro-mechanical relays and microprocessors throughout circuits within and interconnected
to the FHCA continued in 2023. The replacement of relays provides multiple wildfire
mitigation benefits including increased programmed function speed compared to an electro-
mechanical relay. Most importantly, the faster relay limits the length and magnitude of fault
events. The equipment upgrades also enable customized settings to address environmental
conditions. As part of replacing an electro-mechanical relay, the associated circuit breaker or
other line equipment may also be replaced, as appropriate, to facilitate the functionality of a
microprocessor relay. Table 8 shows the completed status compared to what was planned
for the different equipment replaced or upgraded in 2023.
Table 8:2023 Advanced System Protection Summary
Equipment Planned Completed Outstanding
Distribution Relay Replacement 25 25 0
Transmission Relay Replacement 9 9 0
Recloser Replacement 20 20 0
Total 54 54 0
As shown in Table 8, the completed replacement of 54 devices allows for greater
customization and will allow for the settings to be updated based on environmental
conditions.
Expulsion Fuse Replacements
Complete 2023 planned expulsion fuse replacements - In an effort to reduce the arcing
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experienced from an expulsion fuse operation, expulsion fuses are being replaced proactively
within the FHCA. The total scope of expulsion fuse replacements span multiple years over
many circuits across the company's service territory. Table 9 shows the expulsion fuses
planned for replacement and what was completed in 2023.
Table 9:2023 Expulsion Fuse Replacement Summary
Equipment Planned Completed Outstanding
Expulsion Fuses Replaced 1,790 1,790 0
The replacement of 1,790 expulsion fuses as shown in Table 9 are locations where the arcing
potential during operation will be reduced through the new fuse.
Fault Indicators
Complete 2023 planned fault indicator replacements - Fault indicators are being installed to
reduce outage duration, such as those experienced due to enhanced recloser or relay settings.
Fault indicators assist in response times as the location of the fault can be determined quicker
when a patrol inspection is required. Table 10 shows that 200 communicating fault circuit
indicators (CFCI) were installed as replacements in 2023. The 200 replacements were to
replace broken or malfunctioning CFCI devices previously installed.
Table 10:2023 CFCI Summary
Equipment Planned Completed Outstanding
CFCI Replacements 200 200 0
Total 200 200 0
2.6 SITUATIONAL AWARENESS PROGRAM
Meteorology Department
Continued weather modeling - PacifiCorp's experienced meteorology department is an
essential group that gathers data and interprets and translates the data into an assessment of
risk specific for the utility.The assessment is a key component in decision making as described
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in the Assessing the District Fire Risk section of the WMP (at page 84). The department uses
an operational Weather and Research Forecast (WRF) model and a complimentary 30-year
WRF reanalysis across the Company's entire service territory. The model created a
comprehensive forecast of atmospheric, fire weather, and National Fire Danger Rating
System parameters out to 96 hours (4-days). The forecast is overlayed on the electrical
distribution and transmission network for further analysis. In 2023 the meteorology
department continued to analyze the daily risk as described in Assessing the District Fire Risk
section of the WMP.
Weather Station Network
Expand weather station network - The Company found that publicly available weather data
can have limitations. The utility does not have visibility into the maintenance and calibration
of public weather stations, and the frequency of data collection may not match the needed
intervals for performing real-time risk assessments and dynamic modeling. As a result, the
Company installed additional weather stations throughout the state. The weather station
network is regularly evaluated as the network expands for continual improvement.
Complete annual weather station maintenance - An important component of the weather
station network is the annual maintenance performed on existing weather stations. All
weather stations installed by December 31st, 2022, required annual calibrations in 2023.
Table 11 below shows the planned and actuals for weather stations installed and weather
stations maintained in 2023.
Table 11:2023 Weather Station Installation and Maintenance Summary
Initiative Planned Completed Outstanding
Weather Station New Installs 25 25 0
Annual Weather Station Maintenance 105 105 0
Seasonal Wildfire Risk
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Continued use of weather modeling tools - In 2023 the Company continued to use the
Wildfire Analyst Enterprise (WFA-E) modeling tools from Technosylva. The main modules
used by meteorology for WFA-E are FireRisk and FireSim. FireRisk is a product that models
8-hour wildfires simulated at 100 meter intervals every three hours across the entire system.
The data produced provides wildfire risk metrics such as a fire's potential size, which is used
to understand the fire risk across the service territory. In 2023 the output of these models
were used to inform the District Fire Risk.
Assessing the District Fire Risk
Continued daily district fire risk assessments - In 2023 the meteorology group developed an
index called the Modified Hot-Dry-Windy Index or mHDWI. The index uses fuels and
weather conditions to assess wildfire potential, and when used in combination with wind gust
percentiles, the data provides wildfire risk levels in the daily forecast. The daily forecasts are
used to identify the weather conditions and which areas might have an elevated, significant,
or extreme risk of wildfire. Alongside the mHDWI the fuels and fire conditions are part of the
analysis performed to identify the wildfire risk. An accomplishment in 2023 was the
development of the mHDWI to aid in the district fire risk assessment, but it is acknowledged
that this assessment is completed daily and is ongoing in nature.
2.7 SYSTEM OPERATIONS
Continue deployment of enhanced safety settings - The Company developed enhanced
safety settings formerly referred to as elevated fire risk settings that are enabled to reduce
the potential energy released in a fault event. The settings can be enabled based on the daily
risk assessment performed by the meteorology group. Relays and line reclosers are an
example of devices that can have the enhanced settings enabled.
2.8 FIELD OPERATIONS AND WORK PRACTICES
Modified Work Practices
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Continue field implementation of wildfire programs - The field crews incur incremental labor,
as additional resources are required, to support system operations in assessing localized risk
and administering enhanced safety settings. District Fire Risk is used to inform additional
patrols and coordination. As discussed within the system operation section there can be
different re-energization practices that require patrols or assessments. In 2023, Table 12
below shows the quantity of circuits patrolled that were completed on distribution and
transmission circuits based on risk assessments.
Table 12:2023 Additional Patrols Completed
Patrol Type Circuit Count
Transmission 27
Distribution 150
Total 177
Mobile Communication Devices
Procure additional communication equipment to aid in response - In order to respond
effectively in locations throughout the service territory where there may not be cellular
connectivity, Rocky Mountain Power procured alternate satellite communication devices.
The satellite devices expand the rapid response capability from the cellular on wheels device
that was procured in 2022. The devices are strategically placed throughout the service
territory and used during a major event to improve communication capabilities to the control
center, base camp, and/or management. The devices support emergency restoration
activities through increased communication ability which can help mitigate impacts to
customers.
Table 13:2023 Mobile Communication Devices Ordered
Device Ordered
Alternate Satellite Communication Device 6
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Equipment and Tool Purchases
Procure vehicles and equipment to aid in wildfire mitigation - Rocky Mountain Power
procured additional equipment and vehicles to mitigate wildfire risk. Some of the equipment
procured includes basic fire suppression equipment which allows field personnel to extinguish
small fires that ignite while they are working in the field. Fire trucks were procured for work
required to be completed in the FHCA, the equipment could be on hand to water down
vegetation in the work area to minimize the chance of an ignition. Other equipment includes
vehicles to aid in patrols in remote locations as well as equipment to help restoration efforts.
Table 14 below shows the equipment that was procured in 2023 for wildfire mitigation.
Table 14:2023 Equipment and Tools Purchased
Equipment Quantity Use Description
Backhoes 1 Restoration efforts
Backhoe trailers 1 Restoration efforts
Forklift 3 Material management
Forklift trailer 3 Material management
UTV(side by side) 9 Field Patrols
UTV trailer 9 Field Patrols
Fire trucks 5 Field work in fire season
Wildfire Training Material
Develop wildfire eBooks and training applications - Beginning in 2023, with completion
expected in 2024, Rocky Mountain Power is developing training materials which includes
eBooks and mobile applications to be available for internal employees. The goal with the
training materials is to prepare and train crews before an event happens in order to reduce
response time and aid in the effectiveness of the response. The topics include wildfire
protection, roles and responsibilities, and Public Safety Power Shutoff. The applications will
include interactive scenarios for the crews to walk through to inform and guide actions should
an incident occur.
2.9 PUBLIC SAFETY POWER SHUTOFF (PSPS)
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2023 PSPS Experience
Continue PSPS readiness - In 2023 the Company did not experience conditions that would
require a PSPS Watch or a PSPS event in Utah.
2.10 EMERGENCY MANAGEMENT WILDFIRE RESPONSE
Continue wildfire response readiness - The Company's emergency response is guided by the
National Incident Management System (NIMS). The approach is applicable to any type of
wildfire event, ranging from a relatively small wildfire that can be controlled by a local fire
suppression agency,to larger wildfire events that require a coordinated interagency response.
2.11 PUBLIC SAFETY PARTNER COORDINATION STRATEGY
Complete events with public safety partners for emergency response - As part of emergency
preparedness efforts, Rocky Mountain Power takes a multi-step approach in coordination
with public safety partners on wildfire mitigation and PSPS preparedness. The strategy
includes outreach, workshops, and tabletop exercises. The outreach efforts include meetings
and workshops throughout the year across the service territory with public safety partners.
The design of the informal discussions in meetings or workshops is intended to orient
participants to a new concept or procedure. Workshops that are performed are more local,
with targeted discussions that build upon the general outreach. The workshops are aimed to
refine plans, streamline processes, and confirm capabilities. Finally, tabletop exercises
develop awareness of PSPS planning and procedures. Table 15 below shows how many
events were conducted in 2023.
Table 15:2023 Public Safety Partner Events
Activity Quantity
Public Safety Partner Events 16
Public Safety Partner Portal
Implement improvements to Public Safety Partner Portal - In 2023 Rocky Mountain Power
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continued development of the Public Safety Partner Portal with an official launch in 2024.
The portal is a secure web-based portal where critical information can be shared with public
safety partners during a PSPS event. The portal is a map-centric application that hosts critical
GIS files along with information regarding critical facilities and infrastructure. The
development of the portal is on track for deployment in 2024.
2.12 WILDFIRE SAFETY AND PREPAREDNESS ENGAGEMENT STRATEGY
Continue community outreach about wildfire safety - The Company employs a multifaceted
approach to support community engagement and outreach with the goal of providing clear,
actionable, and timely information to customers, community stakeholders, and regulators.
Over the past several years, the Company has engaged customers and the general public on
wildfire safety and preparedness through a variety of strategies including webinars, targeted
paid advertising campaigns, informational videos featuring company subject matter experts,
press engagement, distributed print materials, infographics, social media updates, and
communication through bill messages, emails and website content, and other communication
channels. Table 16 below shows work completed in 2023 to increase community awareness.
Table 16:Community Outreach to Raise Awareness
Activity Date Completed
Translate website into Spanish June 2023
Conduct community webinar July 2023
2.13 INDUSTRY COLLABORATION
Continue industry collaboration involvement - Industry collaboration is performed to
maintain an understanding of best practices and allows for collaboration with experts
regarding new technologies and research. The Company is a member of the International
Wildfire Risk Mitigation Consortium (IWRMC) which is an industry-sponsored collaborative
designed to facilitate the sharing of wildfire risk mitigation insights. The Company also plays
leadership and support roles through other organizations such as the Edison Electric Institute,
the Electric Sector Coordinating Council, and the Institute of Electrical and Electronics
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Engineering.
Participate in climate risk initiative - Beginning in 2023, the Company began participating in
a three-year Electric Power Research Institute Climate Resilience and Adaption Initiative
(READi). The goal is to work with industry stakeholders and other utilities to develop a
common framework to assess climate risk, address resilience, and evaluate investments.
Plan Monitoring and Implementation
Complete 2023 WMP and ensure adherence to Plan - In 2023 the Wildfire safety program
Delivery group developed the 2023 Utah WMP. The group ensures that each initiative is
progressing toward the established plan. Initiative owners are responsible for developing
individual project plans to ensure the plan objectives are met, while the Wildfire Safety
Program delivery group ensures the project plans are aligned with the WMP's objectives. The
group performs regular status checks with the initiative owners to ensure that risk and issues
are being monitored and that prompt action is taken to resolve issues for successful project
execution.
Table 17:Summary of 2023 Compliance with Plan
Section Section Plan Compliance Details
Number
2.1 Risk Modeling Develop Composite Risk Score Completed development for combined composite risk
and Drivers score.
Complete FHCA Map Update Completed FHCA MAP update.
2.2 Inspection and Continue standard inspection Completed standard inspection programs:
Correction programs: Distribution Visual Safety: 17,407
Program Distribution Visual Safety: Transmission Visual Safety:20,888
17,407 Distribution Detail: 1,433
Transmission Visual Safety: Transmission Detail:4,149
20,888
Distribution Detail: 1,433
Transmission Detail:4,149
Perform infrared inspection on Completed 1,077 miles of transmission IR inspections.
1,638 miles of transmission lines.
2.3 Vegetation Perform FHCA vegetation Perform FHCA vegetation inspections and corrections:
Management inspections and corrections: Distribution Miles: 1,198
Distribution Miles: 1,198 Transmission Miles:218
Transmission Miles:218 Program resulted in 805 trees removed,7,154 trees
pruned,and 4,603 poles cleared.
2.4 Environmental Manage 52 nests and retrofit Completed environmental work that resulted in 105
3,095 poles nests managed,3,429 poles retrofitted,and 500 nest
boxes maintained for cavity nesting birds.
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Section Section Plan Compliance Details
Number
Complete project scoping for Completed project scoping with pheasants forever for
habitat improvements habitat improvements to be completed in 2024.
2.5 System Complete line rebuild projects: Completion of 49 miles of Line rebuild(12
Hardening 12 miles of transmission lines transmission line miles,37 distribution line miles)
37 miles of distribution lines
Complete Device Upgrades: Completion of 54 device upgrades(25 distribution
25 distribution relays relays,9 transmission relays,20 recloser
9 transmission relays replacements).
20 recloser replacement
Complete 1,790 expulsion fuse Completion of 1,790 expulsion fuses replaced.
replacements
Complete 200 CFCI 200 CFCI installed as replacements.
replacements
2.6 Situational Continued weather modeling by Completed-Meteorology's department as essential
Awareness meteorology department for gathering data,interpreting data,and translates
Program data into an assessment of risk.
Expand weather station network Completed installations of 25 additional weather
with 25 additional weather stations.
stations
Complete annual weather station Completed maintenance on 105 weather stations.
maintenance on 105 weather
stations
Continue use of weather Completed-The use of WFA-E modeling with
modeling tools. FireRisk and FireSim to understand the fire risk across
the service territory.
Continue daily district fire risk Completed the development of the Modified Hot-Dry-
assessments Windy Index mHDWI to aid in district fire risk
assessments.
2.7 System Continue deployment of Completed-The use of enhanced safety settings were
Operations enhanced safety settings utilized in 2023.
2.8 Field Operations Procure additional Purchased 6 Starlink Satellite communication devices.
and Work communication equipment to aid
Practices in field response.
Procure vehicles to aid in wildfire Completed purchases of fire trucks,backhoes,
mitigation. forklifts,UTV's,and equipment trailers.
Develop wildfire training Development began on wildfire training eBooks and
resource material Applications for delivery in 2024.
2.9 Public Safety Continue PSPS Readiness Completed PSPS readiness and no PSPS events were
Power Shutoff required in 2023.
(PSPS)
2.1 Emergency Continue wildfire response Completed and the Company's emergency response is
Management readiness guided by NIMS.
Wildfire
Response
2.11 Public Safety Complete events with public Completed 16 events with public safety partners.
Partner safety partners for emergency
Coordination response.
Strategy Implement improvements to the In 2023 the development began for Public Safety
Public Safety Partner Portal. Partner Portal and is on track for delivery in 2024.
2.12 Wildfire Safety Continue community outreach Translated the website into Spanish and conducted 1
and about wildfire safety community webinar.
Preparedness
Engagement
Strategy
2.13 Industry Continue industry collaboration Continued membership with the IWRMC.
Collaboration involvement
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Section Section Plan Compliance Details
Number
Participate in climate risk Rocky Mountain Power began participating in a three-
initiative year study referenced as Climate READL
2.14 Plan Monitoring Complete 2023 WMP and The team responsible developed the WMP and is
and ensure adherence to the plan actively tracking initiatives.
Implementation
3 CAPITAL AND O&M EXPENDITURES,
FORECASTS AND PLAN UPDATES
3.1 CAPITAL SPEND SUMMARY
In 2023, Rocky Mountain Power invested $103.7 million of capital expenditures into the
Wildfire Mitigation programs described in this Report, which are accounted for in Table 18
below.
Table 18:Wildfire Mitigation Plan Implementation Summary- Capital Actuals
Mitigation Program 2023
($Millions) Actuals Plan8 Variance Variance Description
Distribution
*Risk Modeling and $2.3 $2.5 ($0.2)
Costs are within 10%of plan
Drivers
Inspection and Corrections $13.8 $16.4 ($2.6) Expulsion fuse replacements were originally classified
under inspection and correction and are better
classified as system hardening work.
Environmental $1.4 $1.3 ($0.1) Costs are within 10%of plan
System Hardening $53.7 $51.6 $2.1 Expulsion fuse replacements were originally classified
under inspection and correction and are better
classified as system hardening work.
Situational Awareness $1.4 $1.4 $0.0 N/A
Field Operations and Work $5.8 $6.2 ($0.4) Costs are within 10%of plan
Practices
*Public Safety Partner $1.9 ($0.1)
Coordination $2.0 Costs are within 10%of plan
Total Distribution $80. $81.4 ($1.0) Costs are within 10%of plan
Transmission
**System Hardening $23.3 $22.3 $1.0 Costs are within 10%of plan
Environmental $0.0 $0.1 ($0.1) Costs are within 10%of plan
Total Transmission $23.3 1 $22.4 $0.9 Costs are within 10%of plan
Total Costs $103.7 1 $103.8 ($0.1) Costs are within 10%of plan
$Plan values are from the Rocky Mountain Power's Revised 2023 Utah Wildland Fire Protection Plan as filed on February 28,
2024,in Docket 23-035-44. Docket No:23-035-441 Public Service Commission(utah.gov).
Page 119

Table 19 below shows actual 2023 capital expenditures as well as expenditures planned for
2024-2025, as documented within the 2023 Utah WMP. At this time, there are no projected
changes to 2024 or 2025 planned expenditures.
Table 19:Wildfire Mitigation Plan Implementation Summary-Capital Plan 2023-2025
Mitigation Program 2023 2024 2025 Totals
($Millions) Actuals PIan9 PIan9
Distribution
*Risk Modeling and Drivers $2.3 $3.0 $0.6 $5.9
Inspection and Corrections $13.8 $20.0 $20.0 $53.8
Environmental $1.4 $0.9 $0.5 $2.8
System Hardening $53.7 $50.0 $85.0 $188.7
Situational Awareness $1.4 $1.7 $0.3 $3.4
Field Operations and Work Practices $5.8 $0.4 $0.5 $6.7
*Public Safety Partner Coordination $1.9 $0.0 $0.0 $1.9
Total Distribution $80.4 $76.0 1 $106.9 $263.3
Transmission
**System Hardening $23.3 $35.0 $50.0 $108.3
Environmental $0.0 $0.0 $0.0 $0.0
Total Transmission $23.3 $35.0 $50.0 $108.3
Total Costs $103.7 $111.0 $156.9 $371.6
*Costs shown as Utah's portion of the system allocated costs.
**Cost shown represents total expenditure in Utah.A portion of the expenditures will be system
allocated to other states when the asset is placed in-service.
3.2 O&M SPEND SUMMARY
In 2023, Rocky Mountain Power spent approximately $18.0 million in operation and
maintenance (O&M) activities for Wildfire Mitigation as shown in Table 20 below.
Table 20: Utah Wildfire Mitigation Plan Implementation Summary-O&M Actuals
Mitigation Program 2023
($Millions) Actuals Plan Variance Variance Description
Distribution
Risk Modeling and Drivers $1.5 $1.5 $ N/A
Inspection and Corrections $7.5 $7.5 $ N/A
Vegetation Management $2.0 $2.0 $ N/A
9 Plan values are from the Rocky Mountain Power's Revised 2023 Utah Wildland Fire Protection Plan as filed on February 28,
2024,in Docket 23-035-44. Docket No:23-035-44 1 Public Service Commission(utah.gov).
Page 120

Mitigation Program 2023
($Millions) Actuals Plan Variance Variance Description
Environmental $0.3 $0.3 $- N/A
System Hardening $0.2 $0.2 $- N/A
Situational Awareness $2.6 $2.6 $- N/A
Field Operations and Work $2.3 $1.0 $1.3 Risk assessments identified additional circuits
Practices that required field patrols.
PSPS Program $0.0 $1.1 ($1.1) There were no PSPS events which resulted in
$0 actuals.
Public Safety Partner $0.1 $0.1 $- N/A
Coordination
WMP Engagement Strategy ($0.0) $0.1 ($0.5) There was a refunded amount of$0.04M for
previously paid for work.Actuals represented
may differ slightly due to rounding.
Industry Collaboration $0.0 $0.1 ($0.1) There was a credit applied to the account
which balanced out the invoiced cost for the
year.
Plan Monitoring and $0.4 $0.3 $0.1 The actuals for the grant application work
Implementation performed were slightly higher than forecasted.
Total Distribution r$16,9 $16.8 $0.1 Rounding might cause actuals to be slightly off
compared to plan.
Transmission
Inspection and Corrections $0.4 $0.4 $- N/A
Vegetation Management $0.2 $0.2 $- N/A
System Hardening $0.4 $0.4 $- N/A
Field Operations and Work $0.1 $0.1 $- N/A
Practices
Total Transmission $1.1 $1.1 $- N/A
Total Costs $18.0 $17.9 $0.1 Costs are within 10%of plan
Table 21 below shows 2023 actual expenditures and the 2024-2025 planned expenditures
as documented within the 2023 Utah WMP. At this time, there are no projected changes to
2024 or 2025 planned expenditures.
Table 21: Utah Wildfire Mitigation Plan Implementation Summary- O&M Plan 2023-2025
Mitigation Program 2023 2024 2025
($Millions) Actuals Plan10 Plan10 Totals
Distribution
Risk Modeling and Drivers $1.50 $2.2 $2.2 $5.9
Inspection and Corrections $7.50 $13.` $13.5 $34.5
Vegetation Management $2.02 $3.6 $3.6 $9.2
Environmental $0.25 $0.5 $0.5 $1.3
10 Plan values are from the Rocky Mountain Power's Revised 2023 Utah Wildland Fire Protection Plan as filed on February 28,
2024,in Docket 23-035-44. Docket No:23-035-44 1 Public Service Commission(utah.gov).
Page 121

Mitigation Program 2023 2024 2025
($Millions) Actuals Plan10 Plan10 Totals
System Hardening $0.2 $0.2 $0.3 $0.7
Situational Awareness $2.6 $3.2 $3.0 $8.8
Field Operations and Work Practices $2.3 $1.5 $1.6 $5.4
PSPS Program $0.0 $1.1 $1.1 $2.2
Public Safety Partner Coordination $0.1 $0.1 $0.1 $0.3
WMP Engagement Strategy ($0.0) $0.3 $0.3 $0.6
Industry Collaboration $0.0 $0.1 $0.1 $0.2
Plan Monitoring and Implementation $0.4 $0.2 $0.2 $0.8
Total Distribution $16.9 $26.5 $26.5 $69.8
Transmission
Inspection and Corrections $0.4 $1.0 $1.0 $2.4
Vegetation Management $0.2 $0.3 $0.3 $0.8
System Hardening $0.4 $0.4 $0.4 $1.2
Field Operations and Work Practices $0.1 $0.2 $0.2 $0.5
Total Transmission $1.1 $1.9 $1.9 $4.9
Total Costs $18.0 $28.4 $28.4 $74.7
4 CHANGES TO THE PLAN
There are no significant updates since the filing of the Revised 2023 Utah WMP (filed on
February 28, 2024).
5 COST RECOVERY
For purposes of cost recovery, the Utah Public Service Commission established a wildfire
mitigation balancing account in the Company's general rate case, Docket No. 20-035-04, to
track and defer the incremental revenue requirement for the capital investments and
expenses to implement the approved wildland fire protection plan. The general rate case
included a base level of costs in Utah rates as of January 1, 2021, and variances from the
amount included in rates have been calculated and deferred on a monthly basis.The Company
presents the balance of the wildfire mitigation balancing account in the results of operations
reports, most recently filed in Docket No. 24-035-11 on April 18, 2024 (page 8.11). The
Company plans to request recovery of the balance in the next general rate case, Docket No.
24-035-04.
Page 122

CERTIFICATE OF SERVICE
Docket No. 24-035-28
I hereby certify that on May 30, 2024, a true and correct copy of the foregoing was served
by electronic mail to the following:
Utah Office of Consumer Services
Michele Beck mbeck(c�r�,utah.gov
ocsgutah.gov
Division of Public Utilities
dpudatareque stgutah.gov
Assistant Attorney General
Patricia Schmid pschmidgagutah.gov
Robert Moore rmooregagutah.gov
Patrick Grecu pgrecukagutah.gov
Tony Clinger tonyclingergagutah.gov
Rocky Mountain Power
Data Request Response Center datarequest(a�pacificorp.com
Jana Saba jana.saba(a�pacificorp.com
utandocketskpacific orp.com
Utah Department of Forestry, Fire and State Lands
Jamie Barnes jamiebames(&utah.gov
Brett Ostler brettostler(dutah.gov
Taiga Rohrer trohrer(a)utah.gov
Jesse Trembly jessetremblygutah.gov
Mike Melton mikemeltongutah.gov
Katie Ricks katiericksgutah.gov
AA
Santiago Gutierrez
Coordinator, Regulatory Operations
1