20210902PAC to PIIC Attach 33 RMP Utah Wildland Fire Protection Plan 6-1-21.pdf

1407 W North Temple, Suite 310
Salt Lake City, Utah 84114

June 1, 2021

VIA ELECTRONIC FILING

Utah Public Service Commission
Heber M. Wells Building, 4th Floor
160 East 300 South
Salt Lake City, UT 84114

Attention: Gary Widerburg
Commission Administrator

RE: Docket No. 21-035-35 – Rocky Mountain Power’s 2021 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 2021 Wildland
Fire Cost and Compliance 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): [e-mail]
[e-mail]
[e-mail]
[e-mail]
[e-mail]

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,

Joelle Steward
Vice President, Regulation

Utah Wildland Fire Protection Plan

Cost and Compliance Report

June 1, 2021
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Utah Wildland Fire Protection Plan
2021 Cost and Compliance Report

Introduction
Consistent with UTAH CODE § 54-24-201(4), § 54-24-202(2), and R746-315-3, Rocky Mountain
Power (“the Company”) submits its first Annual Cost and Compliance Report (“Report”), which
provides the following:
1. The actual capital investments and expenses incurred in calendar year 2020 to
implement the Wildland Fire Protection Plan (“the Plan”) approved in Docket No. 20-
035-28, and an updated forecast of the capital investments and expenses for the current
year 2021.
2. Details of the wildfire mitigation efforts undertaken in 2020 in compliance with the Plan
as approved in Docket No. 20-035-28.
3. Changes incorporated into the Plan 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.
Overall, Rocky Mountain Power made progress to reduce wildfire risk, and the Company
continues to evaluate and measure the effectiveness of its wildfire mitigation programs.
1. Capital and O&M Expenditures, Forecasts and Plan Updates
1.1 Capital Spend Summary
Table 1. Wildland Fire Protection Implementation Summary – Capital Actuals & Forecast
Capital Mitigation Programs ($ Millions) 2020 2021
Actuals Plan Variance Forecast Plan Variance
System Hardening $15.8 $29.6 ($13.8) $24.9 $44.7 ($19.8)
Advanced Protection and Control $4.1 $3.3 $0.8 $3.8 $3.0 $0.8
Operational Practices $2.4 $2.9 ($0.5) $0.5 $1.0 ($0.5)
Inspections and Corrections $2.2 $1.0 $1.2 $3.8 $1.5 $2.3
Situational Awareness $1.4 $0.4 $1.0 $0.8 $0.2 $0.6
Environmental $0.0 $0.2 ($0.2) $0.0 $0.2 ($0.2)
Totals $25.9 $37.4 ($11.5) $33.8 $50.6 ($16.8)

Capital spend in 2020 was $11.5 million less than originally planned. The 2020 variance was due
to the actual spend in the System Hardening category ($15.8 million) being significantly lower
than the forecasted $29.6 million. The largest contributing factors for underspend was
associated with the line rebuild projects, which include lengthy permitting processes, limited
access timeframes for construction, material delays caused by high-demand markets and
limited supplies due in part to the COVID-19 related impacts.
The Inspections and Corrections costs were $1.2 million greater than what was initially
estimated in the Plan. This variance was driven by the increased inspection program and
identification of a greater number of corrections than initially forecasted.
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Capital spend forecasted for 2021 is anticipated to be behind the original plan of $50.6 million
for the year, which is also driven by delays in the line rebuild projects. The Company expects
capital spend to increase in the years 2022-2026 as impacts and delays experienced from
COVID-19 and related wildfire resources and material competition begins to subside and drives
improved timelines for the installations progress to construction phase. Table 2 provides an
updated forecast for capital spend for 2022-2026.
Table 2. Wildland Fire Protection Implementation Summary – Capital Plan for 2022-2026
Capital Mitigation Programs ($ Millions) 2022 2023 2024 2025 2026 Totals
System Hardening $ 66.2 $ 43.9 $ 39.6 $ 20.1 $ 10.1 $ 179.9
Advanced Protection and Control $ 1.1 $ 1.3 $ 0.3 $ 0.3 $ 0.3 $ 3.3
Inspections and Corrections $ 1.5 $ 1.5 $ 1.5 $ 1.5 $ 1.5 $ 7.5
Situational Awareness $ 0.2 $ - $ 0.1 $ - $ - $ 0.3
Environmental $ 0.2 $ 0.2 $ 0.2 $ 0.2 $ 0.2 $ 1.0
Totals $ 69.2 $ 46.9 $ 41.7 $ 22.1 $ 12.1 $ 192.0
Original 2020 Plan Estimate $ 50.1 $ 40.5 $ 27.7 $ 22.0 $ 12.1 $ 152.4
Variance $ 19.1 $ 6.4 $ 14.0 $ 0.1 $ - $ 39.6

The table reflects an increase in spending in 2022 – 2026 over the original forecast since several
projects that were originally planned to be installed and placed in service in 2020 and 2021 have
been shifted. The net impact of both Tables 1 and 2 is an overall $11.3 million increase to the
plan that is a result of refined estimates from the originally planned projects, project scoping
and engineering.
1.2 O&M Spend Summary
Table 3. Utah Wildland Fire Protection Implementation Summary – O&M Actuals & Forecast
Mitigation Program ($ Thousands) 2020 2021
Actuals Plan Variance Forecast Plan Variance
Inspections and Corrections $2,539 $3,200 $ (661) $ 3,156 $3,050 $ 106
Situational Awareness $ 191 $ 300 $ (109) $ 227 $ 500 $ (273)
Environmental $ 3 $ 100 $ (97) $ 510 $ 400 $ 110
Advanced Protection and Control $ - $ - $ - $ 110 $ 100 $ 10
Total Distribution O&M $2,733 $3,600 $ (867) $ 4,003 $4,050 $ (47)
Inspections and Corrections $ 737 $ 800 $ (63) $ 1,005 $ 850 $ 155
System Hardening $ 321 $ - $ 321 $ 200 $ 100 $ 100
Environmental $ - $ - $ - $ - $ 100 $ (100)
Total Transmission O&M $1,058 $ 800 $ 258 $ 1,205 $1,050 $ 155
Total O&M $3,791 $4,400 $ (609) $ 5,208 $5,100 $ 108

Distribution inspections and corrections made up the largest variance in 2020 with a decrease
of $661 thousand. This can be correlated to the types of conditions that are found which differ
in whether the correction is funded under the capital or operations and maintenance expenses
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(“O&M”) accounting treatments.et. (See discussion above regarding increased spending on
corrections involving capital spend.) If the correction of a condition involves the replacement of
an accounting asset (pole, crossarm, cutout, etc.) the correction is accounted for in the capital
program; otherwise the correction is accounted for as O&M. Since the type of correction is
unknown before the actual inspection takes place the planned costs can vary from the actual
costs based on the type of correction required.
Table 4. Utah Wildland Fire Protection Implementation Summary – O&M Plan for 2022-2026
Mitigation Program ($ Thousands) 2022 2023 2024 2025 2026 Total
Inspections and Corrections $3,050 $3,050 $3,100 $3,050 $3,050 $15,300
Situational Awareness $ 500 $ 400 $ 500 $ 500 $ 400 $ 2,300
Environmental $ 400 $ 400 $ 400 $ 400 $ 400 $ 2,000
Advanced Protection and Control $ 100 $ 100 $ 100 $ 100 $ 100 $ 500
Total Distribution O&M $4,050 $3,950 $4,100 $4,050 $3,950 $20,100
Inspections and Corrections $ 850 $ 850 $ 900 $ 850 $ 850 $ 4,300
Environmental $ 100 $ 100 $ 100 $ 100 $ 100 $ 500
Total Transmission O&M $ 950 $ 950 $1,000 $ 950 $ 950 $ 4,800
Total O&M $5,000 $4,900 $5,100 $5,000 $4,900 $24,900

On a longer-term perspective, the Company is not currently projecting significant changes to
O&M spending forecast in the Plan.
2. Compliance with the Plan
2.1 System Hardening
The Plan identified five primary categories for system hardening activities. The line rebuild
projects are particularly central to Rocky Mountain Power’s mitigation efforts, as reflected in
the cost of those projects.
Fire High Consequence Area (FHCA) Line Rebuild Program
The increased risk of wildland fires in western states prompted Rocky Mountain Power to focus
standards development on tools and materials better suited for mitigating wildfire risk. In 2020,
the Company developed standards for covered conductor, which is being used to replace
portions of the distribution network inside of the FHCA.
For decades, the dominant distribution overhead conductor used by U.S. utilities, including
Rocky Mountain Power, has been bare wire. Covered conductors are useful in preventing arcing
on a distribution line that can be caused by trees, animals, balloons, or any other kind of foreign
objects that can contact powerlines. This results in both a prevention of ignition sources for fires
and an improved reliability of the distribution line.
In 2020, Rocky Mountain Power completed a re-build project of an 8-mile section of the 138kV
transmission line from Snyderville Junction to Silver Creek. An additional eight transmission line
rebuild projects are currently underway. Various projects are at different stages in permitting,
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design or construction, with 2021, 2022 and 2023 installation dates currently projected. In
addition, rebuild projects for 12 distribution line circuits are also currently underway.
Due to the complexity of most of the line rebuild projects, the environmental permitting
process, limited construction season and current demand of materials, most line rebuilds will
span two or more years. 2020 served as a major planning and project origination year that will
bring greater results in 2021 and beyond.
Pole Replacement Program
In 2020, 69 distribution poles in the FHCA over 45 years of age were selected to be replaced.
These poles were designed and submitted for construction during the last quarter of 2020.
Construction itself will take place in 2021. These pole replacements are separate from and in
addition to the pole replacements that take place in conjunction with other wildfire mitigation
initiatives. Specifically, poles may be replaced as part of the distribution line rebuilds discussed
above; in addition, pole replacement can occur as the result of conditions found during
inspections.
Fire Mesh Wrap Installation
During 2020, Rocky Mountain Power created a new policy to provide crews guidance on the
installation of fire mesh wrap. This wrap can be installed on wood poles (either transmission or
distribution) to protect the poles from fire damage in the event of a wildfire. The Company
installed wrap on 104 wood poles on the Snyderville – Silver Creek 138kV rebuild. All condition
pole replacements inside of the FHCA are reviewed to determine whether installation of fire
mesh wrap is warranted in conjunction with the replacement. Fire wrap may also be installed in
certain conditions when an advancing fire is threatening facilities and crews can safely complete
installations. In 2020, the Company installed fire wrap on nine wood poles on the Hale –
Wallsburg 138kV transmission line during the Range Fire in Provo Canyon under such conditions.
Relays for Advanced System Protection Program
Rocky Mountain Power replaced 11 substation electromechanical relay packages on
transmission lines inside of the FHCA with new microprocessor relay packages prior to the 2020
wildfire season. These relays result in faster clearing times in the case of a fault, which decreases
the amount of released energy. They also provide fault location to dispatch, which speeds up
the ability to complete a patrol and decreases restoration time. All electromechanical relay
packages on transmission lines inside of the FHCA will be replaced with new microprocessor
relays by the end of the 2026 plan.
The Company also replaced 19 DPU (distribution line relays) and three TPU (distribution
transformer relays) in substations inside the FHCA to replace devices with identified
performance issues. All distribution relaying devices with known performance issues inside of
the FHCA will be replaced by the end of the 2026 plan.
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Non-Expulsion Fuse Installation Program
Rocky Mountain Power replaced 417 protection overcurrent devices, expulsion fuses, inside of
the FHCA with new non-expulsion fuses. Rocky Mountain Power plans to replace all expulsion
fuses installed in the FHCA by the end of the 2026 plan. Because most fuse replacements are
included as part of the distribution line rebuild projects, much of this work will be completed on
the timeframe of the underlying re-build project. (Note that pole-clearing, discussed in the
vegetation management section, will continue equipment poles with expulsion fuses while such
fuses remain in service.)
2.2 Operational Practices
Wildfire Training Facility
Rocky Mountain Power constructed a comprehensive wildfire transmission and distribution
training center in 2020. The training center provides spaces to perform training and equipment
testing analysis, including an enclosed pole yard where crews can train on network operations
of new materials and impacts on electrical facilities. Especially with the new technologies being
deployed as part of Rocky Mountain Power’s wildfire mitigation efforts, this training center will
play a key role in ensuring personnel are properly trained for project installations, maintenance,
and restoration efforts.
Public Safety Power Shutoff (PSPS)
In 2020, Rocky Mountain Power did not de-energize any power lines as part of any Public Safety
Power Shutoff (“PSPS”). During the 2020 wildfire season, Rocky Mountain Power Emergency
Operations Center was activated for two separate PSPS watch events. During the watch events,
field employees were dispatched to take real-time wind measurements, actively patrol lines,
and monitor local conditions, which field personnel communicated back to Emergency
Operation Center (“EOC”) personnel. Conditions were not elevated as to warrant a PSPS in
either case.
The watch events were useful real-world experiences that has helped the Company prepare for
the 2021 wildfire season. In each watch event in 2020, the Company notified affected customers
48 hours in advance, informing them of potential de-energization. Targeted media notices and
follow-up releases were sent out, and customers were notified via outbound calls, texts and/or
emails based on their preference. Related posts were also made on Rocky Mountain Power’s
social media channels. Notification information included updates on weather forecast
conditions, criteria being monitored as part of the PSPS evaluation, actions taking place by
operations personnel on the ground and restoration information. Rocky Mountain Power will
employ the lessons learned in 2020 to effectively use this tool of last resort.

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Mobile Generators
Three 500 kW generators were acquired to use in case of public safety power shutoff during the
wildfire season. These units will be ready to be deployed to restore service to certain
commercial, industrial, or residential areas where it is needed if PSPS is implemented. This will
help mitigate impacts to customers if a PSPS event leaves customers without power for an
extended period.
Emergency Management and Response
In 2020, Rocky Mountain Power continued to develop relationships with Cedar City Fire
Department, North Fork Fire District, Summit, Wasatch, Utah, and Iron Counties Emergency
Managers. Those relationships were key in discussions involving the stand-up of the Rocky
Mountain Power Emergency Operations Center and efforts in the field to monitor facilities
during periods of elevated wildfire risk, particularly in those areas where a PSPS watch event
occurred.
2.3 Inspection and Correction Program
Distribution and Transmission Facility Point Inspection and Correction
In 2020, Rocky Mountain Power inspected all 12,933 poles inside of the Fire High Consequence
Area (FHCA). Inspections were performed in accordance with PacifiCorp’s general inspection
policies and procedures. In addition, these facilities were inspected by four infrastructure
specialists that were hired and trained specifically for the purpose of conducting inspections
with a particular focus on potential wildfire risk.
Table 5. Utah Wildland Fire Protection Implementation Summary – Conditions found in 2020
Area Fire Risk Condition Correction
Timeframe
Outstanding
Conditions
Corrected
Conditions
FHCA Yes A – Imminent* immediately 0 178
FHCA Yes A 60 days average 17 391
FHCA Yes B 12 months 59 330
FHCA No A 120 days average 9 997
FHCA No B - 88 392
2020 FHCA 173 2,288

Currently, there are 173 total outstanding conditions identified in 2020, including 17 A and 59 B
conditions categorized as fire risk. The 17 Priority A, Fire Risk outstanding conditions were
identified near the last quarter of 2020. These locations were very difficult to access, if not,
inaccessible for line operations to correct conditions during the winter season. These conditions
are scheduled to be corrected when locations can be safely accessed by line operations.
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Rocky Mountain Power also integrated a new strategy in its inspection program. During the
month of July 2020, a helicopter infrared scan was conducted on all transmission lines that have
poles within the FHCA. Thirty-six transmission localities containing over 1,300 miles of line were
scanned for components experiencing thermal breakdown. No conditions requiring immediate
replacement were found as part of the infrared scan.
Vegetation Inspection and Management
Rocky Mountain Power implemented the new elements of its vegetation management program
described in Section 4.2 of the Plan. In doing so, the Company performed annual vegetation
inspections on all lines inside of the FHCA. While the actual overhead distribution mileage inside
of the FHCA is 489, Rocky Mountain Power completes an inspection on the entire circuit, and
the total mileage of subject circuits is 1,211. The Company also completed inspections on 210
miles of transmission lines in the FHCA. Vegetation contractors completed work identified
through the inspections consistent with the Vegetation Management Standard Operating
Procedures including the extended clearances as described in Table 13 of the Plan. As a result,
a significant amount of clearance work was performed: with 4,192 trees pruned along the
distribution circuits, and 554 trees pruned along transmission lines.
Most significantly, 679 trees were removed along the distribution circuits and another 292 trees
removed along the transmission lines. These trees were all determined to be high risk trees and
in need of removal. High risk trees can fall-in and contact a conductor, taking the conductor
down. Trees were removed, either as inventory reduction or because of identification as high
risk.
Another key element for the vegetation management program is the Company’s new pole
clearing program. In 2020, Rocky Mountain Power cleared the bases of all 4,712 distribution
equipment poles inside of the FHCA. Pole clearing consists of clearing all vegetation in a 10-foot
radius cylinder of clear spare around the pole.
2.4 Situational Awareness Program
Weather Stations
In 2020, Rocky Mountain Power entered into an agreement with a third-party vendor that
provides customized weather forecasts, which the Company uses to improve situational
awareness and make informed decisions. These forecasts are used to determine when to
dispatch field crews to perform on-the-ground monitoring of conditions during periods of
elevated wildfire weather conditions. The vendor’s forecasts are based on information from
both company-owned weather stations and weather stations with publicly available
information.
In addition to the 11 weather stations installed in 2019, there were 10 new stations installed in
2020 bringing the total to 21 weather stations in Rocky Mountain Power’s Utah service territory.
These stations have been sited to provide weather data for forecasting weather conditions in
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selected areas of the FHCA. Additional weather stations are planned to be purchased and
installed; however, the locations are yet to be determined. As the weather station system is
built out it is continually reviewed for effectiveness in areas of concern and will continue to be
added to when information is determined to be needed on new areas.
Cameras
To expand situational awareness, Rocky Mountain Power invested in high definition video
cameras. Working with AlertWildfire and the Utah Fire and State Lands (FFSL), communication
towers were reviewed to select 14 tower locations that would provide the greatest viewsheds
into the Utah FHCA to not only get a real time view of transmission and distribution lines but
also help facilitate a rapid suppression response to any fire ignitions by firefighting resources.
These cameras include 360° rotation, pan/tilt and zoom capabilities. In 2020, the Company
finalized 14 camera locations and entered into an agreement with AlertWildfire, to have
cameras at these locations operational by the start of the 2021 wildfire season. Through web
access on www.AlertWildfire.org/utah, the live camera views are available to the public at all
times. As part of ongoing collaboration with fire suppression agencies, Rocky Mountain Power
is sharing login capability with the Utah Division of Forestry, FFSL, Utah Emergency Management
groups and other fire-fighting resources throughout the state of Utah.
2.5 Environmental Program
Avian Protection Plan and Wildlife Protection Plan
Rocky Mountain Power continued implementation of its pre-existing Utah Avian Protection Plan
(APP) in 2020, retrofitting 2,866 poles in Utah to address avian electrocution risks. This work
has the added benefits of reducing wildfire risk associated with bird or animal contacts. In
addition, as part of the APP and in accordance with Company state and federal wildlife permits,
the Company managed hazard nests to reduce potential fire risks. Specifically, Rocky Mountain
Power surveyed targeted locations with historic avian mortalities or nests. If needed, facilities
were retrofitted to meet current standards for wildfire and avian protection. This effort
included surveys at 33 poles and retrofitting at 14 poles in the Cedar City district in 2020.
Locations in the Park City district have also been identified for a 2021 survey.
As part of new wildfire mitigation programs launched in conjunction with the Wildland Fire
Protection Plan, Rocky Mountain Power began development of its Wildlife Protection Plan
(WPP) for Utah in 2020. The WPP is intended to identify and mitigate areas where animal
contacts with lines could pose wildfire risks. Planned line rebuilds and enhancements for
wildfire protection within the FHCA will address the risk of wildfire associated with avian or
animal contacts in these areas. Therefore, efforts are being focused on areas where habitat and
animal contacts may pose wildfire risks. Historical data was gathered for wildlife-caused
outages and compared with wildfire risk areas in GIS. Based on this analysis, locations were
prioritized, and a circuit identified for surveys and retrofitting in 2021.
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Habitat Enhancement and Fuels Reduction Partnership Projects
During 2020, Rocky Mountain Power had discussions with the Shared Stewardship (SS) and
Watershed Restoration Initiative (WRI) regarding potential partnership opportunities. Rocky
Mountain Power participated in a Shared Stewardship stakeholder meeting in June 2020 and
reviewed WRI proposed projects during the fall of 2020. The Company also had discussions with
the U.S. Forest Service (USFS) Dixie Field Office regarding proposed WRI partnership projects to
reduce pinyon and juniper encroachment near Enterprise and Pinto that are in proximity to
several transmission lines. In-kind vegetation work completed by Rocky Mountain Power is
currently planned for 2021 completion with an estimated cost of $1.5 million.
2.6 Performance Metrics and Monitoring
A key metric for evaluating the effectiveness of mitigation strategies, especially as projects are
completed every year, will be the outages during fire season inside of the FHCA. The below
graphs provide a baseline of the last six years of outages inside the FHCA both in and out of fire
season.

While inspections and fusing projects have been completed inside FHCA regions, many of the
line rebuilds are still underway and the benefits will not yet be realized. While outages in these
regions have declined from 2019 to 2020, outages during fire season still show a slight increase
from 2019 levels. These outages are greatly attributed to the catastrophic windstorm that Utah
experienced in September. Of the 168 outages which occurred during the 2020 fire season, 66
(39%) were attributed to damages associated with this storm.

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Like distribution, many of the transmission rebuild projects are currently in design, permitting
and or construction. As such, benefits have not yet been realized in these results. Improvements
on the transmission system from previous years has continued the overall downward trend of
transmission outages. The transmission system experienced a decline in events when compared
to 2019, both in the total number of outages and outages during fire season.
3. Changes to the Plan
There were no material changes to the original plan that have been determined to be required
as projects have been started and completed.

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1
CERTIFICATE OF SERVICE

Docket No. 21-035-35

I hereby certify that on June 1, 2021, a true and correct copy of the foregoing was served
by electronic mail to the following:

Utah Office of Consumer Services
Michele Beck [e-mail]
[e-mail]
Division of Public Utilities
Madison Galt [e-mail]
[e-mail]
Assistant Attorney General
Patricia Schmid [e-mail]
Justin Jetter [e-mail]
Robert Moore [e-mail]
Victor Copeland [e-mail]
Utah Division of Forestry, Fire, and State Lands
Jason Curry [e-mail]
Rocky Mountain Power
Data Request Response Center [e-mail]
Jana Saba [e-mail]
[e-mail]
Tim Clark [e-mail]

_____________________________
Kaley McNay
Coordinator, Regulatory Operations