20200529Attachment B.pdf

Attachment B
IIIIIIIIIIIIIIT
Alrfitffir
rlf-
David James, Wildfire Resiliency Plan Mgr September 2019
Attachment B
Avista lnternal Work Product
Report Summary
ln June of 2019, a series of wildfire workshops were convened to evaluate opportunities to
reduce the risk of wildfire associated with Avista's transmission and distribution systems.
Those workshops together with consideration from the Wildfire Steering Committee and the
broaderWildfire SME community serve to inform "Avista's Wildfire Resiliency Plan". This
document is a summary of the effort to date and includes preliminary recommendations for
systems & practices along with modifications to existing maintenance & construction programs
The stated goals of the Wildfire Resiliency Plan are:
o Enhance Emergency Operation Preparedness: to recognize wildfire as a recurring threat to utility
infrastructure, the communities we serve, and our customers.
o Promote Safety: to protect physical assets, property, and human lives. To manage the risk of
wildfire through design-based, system operations, asset maintenance, and outreach activities.
o Safeguard Company Assets: to mitigate the impact of direct financial costs and liability exposure
associated with large-scale wildfire events.
ln addition to these objectives, a model-framework was identified to promote a comprehensive
approach to wildfire risk. The elements of the model include:
EOP Response Situational Awareness
Performance Metricslnsurance Review
Risk Monitoring
Communications Plan &
Outreach
Plan Hemenfs addressed in this report
Commission Engagement
The table below summarizes the risk cost reduction (risk savings) associated with transmission
and distribution treatment options. A detailed listing is included in the report. Be advised, the
risk savings and cost estimates are shown as 10 year costs. Most actions are recurring.
System Hardening
Vegetation Management
Fire Resiliency
'Ops Toolkit'
Utility lndustry
Engagement
Partnering with Fire
Protection Agencies
Legislative Opportunities
Electric
Transmission
Base
Primary
Secondary
Future
Electric
Distribution
Base
Primary
Secondary
Future
10 Yr. Risk Cost Savings
($M's)
Low High82327 4086420 112
10 Yr. Risk Cost Savings
($M's1
Low High217 1,3323,144 5,6674,131 8,8263,187 6,904
10 Yr. Cost
Est.
lmplement
$0.35M
$26.5M
$55M
$126M
10 Yr. Cost
Est.
lmplement
$1.1M
$31.1M
192.5M
$1,369M
Planning System Operations &
Maintenance
Weather & Fire Risk
Monitoring
Regulatory & lndustry
Page | 2
Attachment BAvista lntemal Work Product
Wildfire Threat Increasing in the Western States
The number of large wildland fires continues to trend upward. Data from Climate Central's 2016
Western Wildfire Reoort suggests a 3-fold increase in large fires since 1970 and is particularly
acute in sevenal states including Wyoming, ldaho, and Montana where a 10-fold increase has
occurred. ln terms of total acres burned, there has been a 6-fold increase since the 1970's.
Both the freouencv and scooe of wildfires are on the rise.
Large Wildfi r€s lncreaslng Across the West
tlurter of lires la0er thar I .(D0 ocres per ltar ofl U.S. Forest Servke hnd
m
IB
fl
rr0 ur ns m
2016 Climate Central - Western Wildfires
Adrooa
Cafibmia
New i/lexico
tJtah
Nevada
It$hlngton
Oregon
Baho
Wyoming
Montena
lnformation from the 2016 Western
Wildfires report also indicates that
the number of days associated
"High Fire Dangef or "Red Flagf'is
increasing. Though southwestern
states are most at-risk, note that
Washington and ldaho are ranked
in the top ten. This increases the
probability of fire starts and
elevates the overal! risk of fire
impact.
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9
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Page | 3
Avista lntemal Work Product
Washington State Responds to Wildfire
ln Washington State, the Department of Natural
Resources (DNR) takes the lead on most large
wildland fires outside of federallands. ln 2015, the
DNR published a 20-year "@
!!4" for Centraland Eastern Washington and
identified 2.7 million acres (30%) as'unhealthy
forest'. ln these areas, fuel loading and drought
conditions have resulted in forests most at risk of
catastrophic wildfire.
Treatment plans include, commercial logging
activities, thinning, prescribed buming, and re-
planting with native species.
An acronym has emerged in the ftre vernacular to
describe the interaction between forest land and
human development: Wildland-Urban lntertace
(WU\. Homes built in or near forest lands add to
fhe cosfs of fire suppressrbn. /n Washington alone,
2.2 million homes are located in WUI areas
(Washi ngton DN R, 201 8). Avrbfa's fire resil ie ncy
plan willfocus attention and treatment in these WUI
areas.
Aftachment B
2015 DNR 2l-Year Forest Health Strategic Plan
IASTERN WASH IN6TON ACTIVE
RE5TORATION NEED BY OWNERSHIP
The stale of Washittgton lt,ls trtort tfi.rn 2l
rrrillr,trr ertts Ol lott,!llJnrl ,,^iitll rl}1,rr;lirrr.t-:v II)
tttilli0ti lt,i'.stc<l,,ir..r itr i r]!' llr \\J.r)lilttrlt,'rl Ti i-
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Page | 4
Attachment BAvista lnternal Work Product
Reading this Report
The SME workshops and subsequent analysis has focused on understanding the risk exposure
of wildfires in general, but also the opportunity to reduce risk through specific actions. Risk is
quantified as the probability an event occurring times the financial impact of the event.
(Risk = Probability X lmpact) ln this report, impact is characterized as the sum of:
1) Direct Financial Cost (replacement costs, fire suppression, 1't party damages) +
2) Customer (interruption cost estimate (lCE), 3d party claims) +
3) Safetv (public and employee injuries)
For example, if one considers the risk exposure associated with using fire retardant paint on
wood transmission poles, the probability of a wildfire impacting a transmission line is generally
1-2 times per year. (Probability of Occurrence = 1-Zyear)
The impact costs including the cost of replacement, fire suppression, public and worker safety,
and customer disruption ranges between $961,000 and $1,378,000 per event. This translates
into an accumulated 10-year inherent risk value ranging from $9,610,000 to $27,560,000.
lnherent risk indicates the risk exposure before treatment.
Now consider what happens if fire retardant paint is used. ln this scenario, the probability of
occurrence remains unchanged (1-2lyear) butthe 1O-year managed risk ranges between
$4,285,000 and $4,830,000. The risk reduction or'risk savings' is the difference between
inherent and managed risk. This report includes both inherent and managed risk costs together
with the treatment implementation costs. Again, all costs are indicated as 10-year accumulated
amounts and are order of magnitude estimates. For the fire retardant (FR) paint example, the
table on page 7 indicates:
Description
Wood Pole Fire
Retardant
lnherent Riqk ($M)Low High9.6 28
Managed Risk ($M)Low High4.3 4.8
lmplement
10-year
$2.5M
ln the body of this report, proposed treatment actions are identified and grouped as:
Base tevel - efforts that support or enable other actions; or standalone actions that can be
readily incorporated by the organization.
Primary - actions that represent significant value (risk reduction) and are recognized as industry
best-practices.
Secondary - actions that represent the highest risk value but require significant human and or
financial commitments.
Future - identified as providing value but of lower priority and therefore, not considered in the
initial phase of the Wildfire Resiliency Plan.
o
a
a
a
Page | 5
Attachment B
Avista lnternal Work Product
Electric Transmission
ln 2006, Avista adopted tubular steel poles as the'standard
installation' for 1 15 and 230 kV powerlines. Approximately 30% of
Avista's transmission system is now steel and as circuits are
reconstructed and poles replaced, that percentage will continue to
increase. ln 2009, NERC published lhe"Transmlssion Vegetation
Managemenf' standard FAC-003-2 which fundamentally reshaped the
industry's approach to transmission line clearance activities. For
Avista, the combination of system hardening and well maintained
rights-of-way have increased the fire resiliency of the transmission
Transmission fire ignition events
are rare. From 2014 to 2018 there
were 611 sustained outages but
only 252 between May and
September (fire season).
However, there were over 3,000
momentary outages and nearly half
of those (1,500) occurred during
fire season. Eighty percent (80%)
of transmission line faults are
momentary (less than 5 minutes)
and are generally the result of
lightning, wind, and planned
switching operations. Conversely,
the impact of fire to transmission
structures can be significant. The
replacement cost of a single wood
transmission structure ranges from
$7,500 to over $25,000 and
damages to conductor can
escalate into the millions of dollars.
June 2019 WW-Wanapum Fire
2@S*Avlcta adopts
staal stnloturas as
shndard oon$trucfiqn
2W* NERC Vegaffion
Menagomant$ffire
ICIffif;q$S$
Page | 6
Avista lnternal Work Product
Base Level Actions (transmission system)
Description
EOP & Fire ICS
Fire Weather
Dashboard
Engineering Review
Post Major Event
Wildfire Compliance
Tracking
Tota!
!nherent Risk ($M)
Low High9.6 17.74.8 8.8
1.0 6.9
Managed Risk ($M)
Low High9.6 17.64.3 4.8
0.9 2.4
Attachment B
lmplement
10-year
$50k
$sot<
$100k
9.6 18 2.2 2.7 $1 50k
25 51 17 28 250k OpX
100k GapX
1. EOP and Fire ICS- fire events are distinct from other storm-outage scenarios and Avista's Emergencv
Operatins Plan (EOP) should reflect that reality. ln most fire situations, outage restoration should be
secondarv to emplovee and oublic safetv. Restoring power in an active fire area may expose line
personnel to unnecessary risks and draw evacuated residents back into homes and businesses. Also,
there is broad consensus that Avista should have a representative in all fire ICS situations. The
representative would serve as the liaison between fire command and utility personnel such as
system operations, distribution dispatch, electric operations, and engineering. The division
operations manager would serve in this capacity or delegate a staff member.
2. Fire Weather Dashboard- situational awareness is vitalto decision making; especially in operations
control rooms or emergency operations environments. Weather data is readily available in the
public domain as is fire condition information. There is strong consensus that these oublic
information streams should be combined to support decision making including public safety power
shutoff (PSPS). Though PSPS is recognized as a 'deferred action', actions included in the resiliency
plan will support a future deployment.
3. Engineering Review Post Major Event - transmission engineering requests time to conduct damage
assessment following a significant event. The EOP should include a 2448 hour stand-down period
allowing engineering staff to determine the appropriate scope of reconstruction.
4. Wildfire Compliance Tracking - in order to monitor and measure the effectiveness of the Wildfire
Resiliency Plan, the Committee recommends metric monitoring similar to NERC/CIP. This system
would provide a clear record of performance and track modifications to the program.
Page | 7
Primary Actions (transmission system)
Avista lnternal Work Product
Inherent Risk ($M)
Low High9.6 17.79.6 28
15
1.8
36
Description
Digital Data Collection
Wood Pole Fire
Retardant
Fuel Reduction
1"t Responder Training
Total
29
2.3
77
Managed Risk ($M)
Low High
0.9 2.44.3 4.8
Attachment B
lmplement
10-year
$7.5M
$2.5M
$15M
$1.5M
$26.5M
opX
3.0
0.3I
29
0.9
37
1. Digital Data Collection - Laser Detection & Ranging (LIDAR) is widely recognized as an industry best
practice and provides accurate locations of structures, vegetation, buildings, roads, and etc.
Transmission Engineering currently uses this technology to monitor conductor ground clearance.
That data can be used to determine vegetation management work plans and to assess the
effectiveness of treatment. This system could become Avista's 'system of record' for both
vegetation management and system integrity. LIDAR is quickly becoming the industry de-facto
standard for transmission vegetation management due to its ability to quantify tree growth rates,
tree fall-in risks, and to accommodate a variety of risk/benefit scenarios. The tobulor estimote
reflects stondolone doto gothering ond onolysrs costs. However, we onticipote cost savings by
reducing the need for ground based activities and helicopter oeriol patrols.
2. Wood Pole Fire Retardant - fire resistant paint has been used on Avista's wood transmission
structures since the late 1990's, and in most cases, paint is applied from ground-line up to 5-8 feet.
This has proven to be an effective treatment for transmission structures not subiect to tree crown
fire activiw. However, maintenance funding for this activity has been constrained and the
recommended application frequency of once every three to five years has not been met. A new
product in-use on SCE's system consists of a fire-activated pole wrap (GENIC Fire Mesh) and does
not require follow-on maintenance. Transmission engineering is currently evaluating this product.
The June 2019 Wollo Wollo-Wonapum fire impacted opproximotely 77 miles of tronsmission line.
These poles hod been treoted with FR point in 2009 ond mony structures were protected os o result
of this opplication. Totdl repoirs ossocioted with the fire totoled 57.2M however gg!rylg!2
of a 77 mile section of this focility ronges between S73M ond S20M dollors.
3. Fuel Reduction- though State and Federal agencies are actively pursuing fuel reduction strategies,
most do not encompass electric transmission facilities nor do they involve localfire protection
districts. The Steering Committee recommends that Avista participate with localfire districts to
reduce the fuel loading in critical areas such as multi circuit corridors, critical infrastructure areas,
and extreme risk fuel zones.
4. 15t Responder Training - line personnel respond to a variety of emergency situation including pole
fires and must have basic fire suppression skills. During fire season, fire protection agencies often
impose work-site restrictions that involve fire watch and area preparation. Conversely, fire fighters
are often tasked with working around utility infrastructure and must have a basic awareness of
electric hazards. Joint training with Avista line and fire district personnel currently occurs but only
on an as-needed basis. The Steering Committee recommends that joint training occur annually.
Page | 8
Avista lnternal Work Product
Secondary Actions (transmission system)
Inherent Risk ($M)
Low High4.8 8.8
1.0
Managed Risk ($M)
Low High0.2 1.4
Attachment B
lmplement
1O-year
$s0M
Description
Conforming
Transmission Rights-of-
Ways
Engineering Line Patrols
Construction follow-up
Fire Protection
Expedited Response
Additional Line Patrols
in WUlAreas
Total
4.4
54
68
3.0
9
0.2 0.2 $3M
UNK
2.4 $2M
4
0.9
50M CapX
5M OpX
1. Conforming Transmission Rights-of-Way - though, wholesale expansion of transmission corridors is
well beyond the scope of this effort, conforming rights-of-ways to established engineering and
vegetation management standards should be evaluated on a case by case basis. This effort would
be constrained to WUI areas or circuits with known vegetation issues.
2. Engineering Line Patrols.... - transmission engineering conducts annual aerial patrols to ensure
structural integrity and to monitor other direct hazards such as bird nests and building
encroachments. Currently, this is an open loop process and by closing this process, a clear record of
treatment is maintained.
3. Fire Protection Expedited Response -80% of transmission line outages are temporary with the line
first tripping and then automatically reclosing. ln most scenarios, Avista crews are not dispatched to
inspect these lines unless there is a secondary indication of a problem. Recent discussions with local
fire districts indicates a willingness to investigate the potential for fire events after a trip-reclose
event. This system would be deployed in conjunction with the distribution 'dry land condition'
declaration and apply only to participating fire district areas. At this point, it is unknown whether
localfire districts would seek compensation.
4- Additional Line Patrols in WUI Areas - a major theme in the California utility plans is the emphasis
on structure inspections in fire prone areas. lnvestments in more frequent patrols would support
both engineering and asset maintenance objectives.
1
Page | 9
Futu re Actions (transmission system)
Avista lnternal Work Product
lnherent Risk ($M)
Low High0.5 1.00.9 2.40.2 0.5
7.8 8.7
Description
Minor Rebuild
T/R Patrols
Supervised 115 kV
MOAS Operation
Splices & Obsolete
Conductor
Fire-wise Education
RAff Road System
lnspect before re-
energizing policy
Red Card Certification
Fire Prevention Grant
Writer
ln-house fire
suppression crews
Fire training for pre-
apprentice tree crews
lncrease ground
clearance standards
Dry Land Mode
Marker Balls on static
lines
Advanced Line
Protection
Total
9.6 17.6
0.9 2.4
2.5
Managed Risk ($M)
Low High0.2 0.80.8 2.20.1 0.1
0.4 0.9
4.4 5.5
0.4 1.0
Attachment B
lmplement
10-year
$30M
$1.8M
$40k
$7.5M
$3M
$40M
$250k
$380k
$700k
$1.sM
$1.5M
$25M
$1.8M
$2,5M
$10M
3.8
4.8
0.2
1.0
4.3
0.4
6.9
4.8
0.5
4.8
1.8
4.0
0.9
4.8
2.4
57
13.8
0.5
13.8
6.9
0.2
0.2
0.9
0.9
0.4
0.1
1.0
0.1
28 1.3
3.6
11.3
4.43.6 4.4
42 't59 22 47 $126M
1. Minor Rebuild - to supplement the existing pole replacement program with a focus on wood to
steel conversions in the WUI areas.
2. T/R Patrols - similar to expedited fire response but would involve dispatching Avista personnel
following an isolated trip-reclose event. Expedited response is a more targeted approach.
3. Supervised 115 kV MOAS - many 115 kV air switches can be remotely operated. lf air switches
operate incorrectly, arcing may result and could produce an ignition.
4. Splices & Obsolete Conductor - conductor splice failure is rare. From 2014 to 2018, only 4
conductor/connector outages were reported.
5. Firewise Education - combined with distribution 'right tree-right place' public outreach program.
6. R/W Road System -to construct permanent roads on transmission rights-of-ways.
7. lnspect before energizing - to expand existing field practices of ensuring personnel and equipment
in the clear before re-energizing a circuit that was taken out of service for maintenance.
8. Red card certification - to provide 3-5 day training to line personnel effectively making them fire
fighter qualified.
9. Fire prevention grant writer- paid staff writer to apply for federal and state grant monies.
10. ln-house fire suppression crews - dedicated firefighting personnel and equipment.
11. Fire training for pre-apprentice tree crews - an addition to the existing program effectively making
tree personnel firefighting qualified.
12. lncrease ground clearance standards - to increase 115 and 230 kV ground clearance design
standards.
Page | 10
Attachment BAvista lntemal Work Prcduct
13. Dry Land Mode -to adapt the non-reclosing practice for electric transmission lines.
14. Marker Balls on Statac Wires - ln the 199Os, severalaerial marker balls failed associated with
electric field stress.
15. Advance line protection - adding line relays and communication equipment to existing transmission
lines.
Page I 11
Avista lnternal Work Product
Electric Distribution
The vast majority of electric outages occur on the distribution
system but the impact to customers is restricted by line fuse
action (1-100 customers typical). To contrast this situation,
transmission outages are infrequent (low probability) but often
impact thousands of customers. The exact opposite is true in a
majority of distribution outages where the fuse protection scheme
limits the impact to outages to lateral circuits. However, from a
fire prevention standpoint, the distribution system is the ignition
source for most utility caused fires. Data from the Outage
Management System (OMT) indicates that annually, one hundred
(100)fire ignition events are associated with overhead distribution
lines. ln almost all cases, these fires are extinguished by 1't
responders including Avista line servicemen. lt is the distribution
system that requires more focus with respect to fire ignition and
this risk is especially acute in the wildland-urban interface (WUl).
Fire ignition sources
include tree contacts with
powerlines but also include
animal contacts, equipment
failure, and electrical pole
fires. Between 2014 and
2018 there were 1,933 tree
related outages with 1,011
occurring during fire
season. Over that time
period there 462 reported
pole fires (see inset).
Attachment B
Though vegetation management spends $5-7M annually,
there is a $3M work backlog and the number of danger
trees continues to increase.Iussock itoth (attacks fir trees)
liltlIlIllSL
A warming climate and drought conditions haye sfressed frees resulting in widespread
damage from insects and disease. ln many cases, trees subT'ect to insect damage die
within six to eighteen months making it difficult to identify dead or dying trees with
ground patrols.
Whereas the risk profile of transmission rb largely assocrated to the costs of fire impact to
fransmlssion lines, the risk profile of distribution is aligned with ignition. The 1991 Firestorm
involved over ninety (90) ignition evenfs. A majority of those fire starts were related to
distribution lines.
Page | 12
20m - Fiberglaee Xarmo
a@t€d cFtcm wido
(ra&r,eo pole firee)
2008- Dry t and Mode
Piqhctlon dBwlopod
Avista lnternal Work Product
Base Level Actions (distribution system)
!nherent Risk ($M)Description Low High
Comprehensive Fuse 41 107
Coordination Study
Formalize event 21 82
reporting
Fire ignition tracking 132 547
system
lncorporate Veg Mngt in 20 278
CPC designs
Fire Suppression 53 582
Wetting Agent
Dry Land Mode 21 57
'effectiveness' study
GIS WUI Design Layer 0 0.11
Dry Land Mode'trigger'
ARCOS WF NotificationTotal 288 1,653 71
Managed Risk ($M)
Low High1.6 8.2
1.3 8.4
46 213
10 21
11 66
.6 4.2
0 0.11
Attachment B
lmplement
1O-year
$200k
$400k
$300k
$100k
$50k
$50k
Complete
Complete
Complete
1.1M OpX321
1. Comprehensive Fuse Coordination - distribution faults are a known source of fire ignition.
Miscoordination of fuses may transfer more energy to a fault and increase the probability of a fire
start, Ensurins proper fuse sizing is an important component of the distribution protection system.
2. Formalize event reporting - protection engineering conducts analysis for alltransmission breaker
activity. This would extend that analysis to the distribution system and ensure that circuit
breakers/reclosers are functioning properly. Again, fire ignition is directly related to line fault
activity and ensuring 'as-designed' operation of equipment helps to reduce probability of fire
ignition.
3. Fire lgnition Tracking System - to implement a computerized tracking system for fire ignition events.
4. lncorporate Veg. Mngt in CPC Design - trees are often overlooked during the distribution design
process and subsequent unplanned treatment is often expensive and disruptive.
5. Fire Suppression Wetting Agent - additives are commercially available that extend the 'wetting'
properties of water. During periods of high fire danger, crews often use water to spray down an
area prior to performing work. Water additives such as Cold Fire significantly increase the
effectiveness of this procedure.
6. Dry Land Mode 'effectiveness study - report by Protection Engineering on the overall effectiveness
of DLM together with recommendations for future enhancements.
7. GIS WUI Design Layer- Engineering services has developed a Wildfire Urban lnterface layer based on
the national wildfire hazard potential (WHP - 2018). This layer will be used to identify fire risk areas
and help prioritize maintenance and reconstruction efforts.
Page | 13
Attachment B
Avista lnternal Work Product
8. Dry Land Mode'trigge/ -the USFS publishes a daily 'fire threat index' ranging from low to extreme
This system is in use at Avista now determines when we reconfigure distribution circuits to operate
without automatic reclosing.
9. ARCOS WF Notification - Distribution Dispatch uses a computerized notification system to call-out
crew resources during outages. That system is now being used to notify key personnel, including
senior management, in the event of a fire that threatens customers or infrastructure.
Primary Actions (distribution system)
Description
Annual Risk Tree
" Right Tree-Right Place"
Midline Recloser
Communications
Additional Midline
Reclosers
Total
Inherent Risk ($M)
Low High2,816 5,722563 1,14514.6 29
3,416
Managed Risk ($M)
Low High264 1,2262.25 28.20.25 0.28
!mplement
10-year
$5M
$15.5M
$600k
22.6 39 5.63 13.2 $10M
6,935 272 1,268 10.6M GapX
20.5M OpX
1. Annual Risk Tree - to conduct annual inspections and treatment programs in WUI areas. Currently,
hazard tree assessments are conducted as part of the 5-year routine maintenance program.
2. "Right Tree-Right Place" -this is an established program throughout the industry and promotes the
planting of Type I trees near powerlines. Type I trees mature at heights less than 20 feet and pose
no threat of fall-in or grow-in to electric lines. Avista has worked with city officials, arborists,
developers, and individual landowners promoting this concept but has not conducted a wide-spread
public campaign nor offered an incentive program to promote the removal of Type ll/lll trees. Right
Tree-Right Place is a vehicle, a brand that we can broadly support and has the potential of drastically
reducing the need for vegetation management maintenance in out-years.
j. Midline Recloser Communications - modern electronic circuit reclosers are capable of remote
operation and monitoring via cell modem, 4-wire telephone, or fiber optic communications. Though
our current standard includes communications, many existing units operate locally. Adding 'comms'
is a cost effective solution to support various functions including emergency operations, system
planning, and distribution system management functions such as integrated volt-var control.
4. Additional Midline Reclosers - the ability to limit fault exposure on the distribution system is a well-
established risk mitigation technique. The fire ignition potential of a line fault is related to current
and clearing times. By adding circuit breakers to the system, both quantities are reduced.
Page | 14
Secondary Actions (distribution system)
Avista lnternal Work Product
lnherent Risk ($M)
Low High2,816 5,722132 547
Managed Risk ($M)
Low High132 5640 1.6
11
143
Attachment B
lmplement
10-year. $20M
$22.5M
$150M
172.5M CapX
20M OpX
Description
Digital Data Collection
100% Substation
SCADA
WUlGrid Hardening
Total
1,326
4,274
3,189
9,458
66
632
1. Digital Data Collection - note that the values shown for inherent risk reflect the lack of a purely
objective 'system of record' for trees near distribution lines. lt is also indicates the constraints
associated with public rights-of-way and the lack of property rights adjacent to most distribution
lines. Although the inherent risk is likely overstated, vegetation management is the largest risk
element associated with distribution lines. LTDAR imaging is commonly used on transmission lines
and many utilities are now extending that practice to distribution circuits. Portland General is
investing in distribution LIDAR as are most California Utilities including SMUD. * The lO-yeor, $20M
dollor cost does not include offset costs ossocioted with fewer ground potrols ond lobor sovings in
the field.
2. 100% Substation SCADA - Though we've slowly reduced the number on non-scada substations,
there are several remaining stations without visibility. The inability to monitor or control equipment
in these stations is a significant risk component. Substation scada is widely recognized as an
industry best practice.
3. WUI Grid Hardening - during the workshops, several hardware components were singled out such
as fiberglass x-arms, hot tap connections, steel poles, and obsolete copper wire. Rather than list
them individually, the group consensus is to modify the GridMod program to fire harden system in
WUlareas. Forexample,portionsoftheColvilleL2F4circuitroutethroughWUlzones. Design
scope in that area would include elements to mitigate fire ignition.
Page | 15
Attachment BAvista lnternal Work Product
Future Actions
1. Overhead to Underground Conversion -the systematic conversion of overhead facilities to
underground. Virtually al! new distribution construction is underground and GridMod is converting
circuit segments when feasible and cost effective.
2. Develop Crew Standby - Avista's after-hours crew call-out is strictly voluntary. By paying for crew
stand-by time, personnel would be pre-selected for call-out and reduce overall response during
contingency events.
3. Fiberglass pole top pin - not included in the WUI GridMod proposal, current pole top pin assemblies
are made from steel and are a possible source of fire ignitions. However, analysis of distribution
pole fires indicates that the wood x-arm contact is the primary ignition point for most pole fires.
4. Video Surveillance - many California utilities are using video surveillance to detect fire starts but we
believe the risk value proposition is low.
5. Arc Sensing relays - though pilot work is currently undenrvay to develop the next generation of
distribution relays, this technology is in its infancy.
6. Scarifo pole bases - this is a common practice in dry scrubland environments (sage brush) but a
majority of Avista's rural distribution lines route through forested and agricultural areas.
lnherent Risk lmplement
Description Low Hioh Low Hish 10-year
Overhead Conversion to
Underqround
2,816 5,723 113 195 $500M
Develop Crew "Standby"
Svstem
332 797 66 282 $15M
Fiberolass oole too oin 11 26 5 2.6 $65M
Video Surveillance in
WUI
1.0 1.0 0.2 2.5 $1.35M
Arc Sensing Protective
Relays
23 39 1.1 6.6 $6.5M
Scarify Poles Bases in
WUlZones
8.3 132 1.1 6.6 $14M
S&C lntelliruoter 23 39 1.3 6.6 $13M
Create lntemalFire
Work Restrictions
1.0 5.0 0 0.5 $750K
Non Exoulsive Fuses 0.5 2.6 0.2 0.8 $10M
Full Length Treated
Poles
41 164 16 82 $5M
lnset Poles Reduce
Soan Lenoths
16 63 0.6 2.6 $250M
lnsulated Primary Tree
Wire
11.3 21 0.5 2.1 $30M
Avian Covers in WUI 0.3 2.7 0.13 o.17 S72M
50-CLl Poles in WUI 3.3 16 2.3 11.3 $36M
Aerial Cable in WUI 11.3 26 0.1 1.1 $300M
Amend Forest Practice
to remove powerline
adiacent trees
132 613 41 164 $50k
FR 3 OilTransformers 0.1 1 0.1 0.5 $50M
Total 3,431 7.671 24 767 $1,369M
Page | 16
Attachment BAvista lntemal Work Product
7. S&C lntellirupter - an alternative device to a conventional circuit breaker. Adding conventional
midline breakers is a recommended action.
8. Create internal fire restrictions - to mirror work restrictions issued by forest land managers.
Deemed as low value by workshop attendees.
9. Non-expulsive fuses -though conventionalfuse action does represent an ignition source,
observationalfeedback does not support replacing them at this time.
10. Full length treated poles - treated poles offer some fire resistant characteristics but are not
supported by engineering, supply chain, or field operations.
11. lnset poles - reducing span lengths increases overall circuit strength and minimize wire-wire
contacts due to wind and storm events.
12. lnsulated primary tree wire - focus will be on improved vegetation management.
13. Avian covers - extending avian covers in WUI would reduce ignition by animal contacts.
14. 50 C!-1 poles - increases ground clearance
15. Aerial cable in WUl- lnsulted OH cable provides significant insulation but is very expensive and
presents hazards if supporting structures fail.
16. Amend Forest Practices... - when commercialtimber harvest is conducted near powerlines, trees
near electric facilities are often left. These become risk/danger trees to the facilities. Requiring that
these trees be removed helps to minimize fall-in issues.
17. FR 3 Transformers - FR 3 oil does not support combustion but transformer tanks rarely fail during an
electrical fault.
Page | 17
Attachment BAvista lnternal Work Product
Addendum
Q&A:
Q: Why isn't Public Safety Power Shutoff listed?
A: Pre-emptive power shutoff (PSPS) is a system in-use in California (SDGE, SCE, PG&E,
PAC, and others) and while it was discussed during the SME Workshops, it requires systems
and processes not yet available at Avista. However, the concept will be addressed in the April
2020, Avista Wildfire Resiliencv Plan and this plan does include recommendations that would
support a future deployment of PSPS.
Q:Why is 100% Substation SCADA identified as a fire risk?
A: Supervisory control systems are common throughout substation and power generating
facilities and allow for equipment monitoring, unit dispatch, and operational control over
equipment including power circuit breakers, voltage regulators, power transformers, and
generating equipment. The inability to de-energize a transmission or distribution circuit is a
general safety risk and may prevent Avista system operations to de-energize circuits.
Core Logic Study
ln 2018, Avista hired the Core Logic
Company to study the financial impacts
of a large scale, utility-caused wildfire
event. They estimate the property loss of
a 100 year event at$24 million dollars
and a 500 year event at $69 million.
These values pale in comparison to the
$30 billion dollar damage estimate
associated with the 2018'Camp Fire'in
Paradise, CA. However, it should be
noted that the Core Logic study did not
consider loss of human lives nor other indirect costs such as human displacement,
economic disruption, or fire suppression. The societal costs associated with catastrophic
wildfire is difficult to forecast and subject to a number of factors.
Retum Period
(Years)
Non-Exceedance
Probability (%)
Damage
(91
500 99.8 68,727,7t2
250 99.6 47,3L7,3O8
100 99 23,969,406
50 98 12,137,863
25 96 5,360,076
Page | 18
Attachment B
Avista lnternal Work Product
SME Wildfire Risk Workshops
ln the Wildfire Resiliency Plan Charter, March 2019, it was noted that recommended actions
would be based on risk-reduction whether directly financia!, safety related, or related to
customer impacts. A series of workshops were held to identify opportunities to reduce risk on
the overhead transmission and distribution systems. The primary goal of the workshops were
to:
1) ldentify actions to reduce the probability of electric ignition
2) Quantify the consequence or impact of potential actions
The workshops were divided into three sub-sections
1) Design based (material and construction standards)
2) Operations (control center and field operations)3) Maintenance (programmatic asset maintenance and vegetation management)
During the course of the six (6) workshops, over one hundred and sixty (160) actions were
identified. The Business Process lmprovement (BPl) department assisted with the workshops
and assisted with the exercises. An 'affinity exercise'was used to identify actions. During the
affinity exercise, individuals are asked to use post-it notes to note individual actions such as
(examples):
a) Widen transmission rights-of-ways
b) Use steel poles on distribution lines
c) Develop a non-reclosing program (DLM) for transmission
d) Employ a dedicated firefighting crew at Avista
e) Convert overhead distribution lines to underground facilities
f) Develop a fire-weather forecast and monitoring system
ln many cases, workshop attendees had similar items and were asked to group and agree on a
central idea. This provided an opportunity to discuss and clarify the proposed actions.
The group then identified the effort and benefit associated with each idea. Effort is associated
with financial commitment, complexity, sustainability, and manpower requirements. Benefit was
based on the relative risk reduction to reduce the likelihood and or impact associated with
wildfire. ltems with high benefit, low effort were noted as the most likely to produce cost effective
results while low benefit, high effort items were discarded. ltems deemed as cost effective and
prudent, moved on to the risk evaluation exercise.
The risk evaluation was modeled after the Asset Management Risk Matrix and the Enterprise
Risk Registry. ln this treatment, a before and after probability was assigned along with the
impacts:
a) Financial (e.9. direct impact to infrastructure, 1st party claims, fire suppression)
b) Customer (the disruption to customers as monetized by multiplying customer*hours by
the interruption cost estimate (lCE, Avista $63/customer*hour) and 3d party claims)
c) Safety (the potentialfor injury to both Avista employees, 1"t responders, and the public)
Page | 19
Attachment B
Avista lnternal Work Product
For example, conversion to underground significantly reduces the probability of electric ignition
with the before or'inherent' risk associated directly to overhead distribution lines. Outage
statistics indicate that Avista's distribution system is involved with approximately one-hundred
fire ignition events per year. Subsequent impact is related to fuel loading and weather
conditions. However, conversion of circuits in the wildland urban interface (WUl) virtually
eliminates tree to wire contacts which is the majority of fire ignition events related to powerlines
During the workshop, the inherent risk associated with'OH/UG Conversion" was 78 or 90
possible points and though the risk was reduced by 38 points, the costs of conversion was
estimated at $500 million dollars over a 1O-year period.
A subsequent'scoring' exercise was conducted by indentifying items associated with:
1. Highest lnherent Risk -- items with significant risk should be considered for treatment
2. Highest Risk Reduction - opportunities that significantly reduce risk should be promoted
3. Lowest Overall Cost - low cost items should be considered before high cost alternatives
Scoring was based on the delineation of:
Gold - Best value (2 points)
Silver - Good value (1 point)
Bronze - Moderate value (0.5 points)
Scores were assigned based on the outcome of the "BPl" lead workshops. ln addition, the
Wildfire Steering Group were asked to identify their top three (gold, silver, bronze) opportunities
for electric distribution. A subsequent employee workshop involving T&D subject matter experts
was convened to gather feedback on opportunities. Again, a review exercise was conducted to
ensure that recommended actions were supported by the broader engineering, operations, and
maintenance communities. lndeed, this report is a summarized version of those outcomes with
Low & No Cost items listed together with Recommended Actions (Should Do), while those
identified as Advised or Deferred did not receive consensus support or are cost prohibitive.
Page | 20
Attachment BAvista lnternal Work Product
The Legacy of Firestorm
The October 16, 1991 Firestorm is firmly etched into the minds
of local residents and WWP employees. Though October is not
generally considered 'high fire season', drought conditions
prevailed and 60 mph winds caused trees to fall through
powerlines. The majority of October-1991 fire ignitions were
related to trees contacting powerlines.
Between 1970 and 1990, population growth in Spokane grew
by 25o/o to 360,000 and during that time frame, homes were
built in unincorporated areas 11 times faster than in cities for a
total of 24,000 new homes in the wildland urban interface.
Avista has a long history of responding to fire events such as
the 2005-06 fires that burned significant portions of the Benton-
Othello line, the 2015 Carpenter Road Fire (Colville), and the
2019 fire that impacted seventeen (17) miles of the Walla
Walla-Wanapum 230 kV line. Nearly every year there is a fire
that impacts the Lolo-Oxbow 230 line. The 'Oxbow' line is
Avista's interconnection with ldaho Power and is an important
asset connecting north and south ldaho. The line routes
through extremely rugged terrain in the Salmon and Snake
River country. Many structures are accessed via jet boat while
others require road building and hours of slow travel to reach.
The impact of wildfire is an ever-present risk to Avista
infrastructu re, ou r em ployees, and customers.
However, fire is unlike other storms that disrupt power and utility experts recognize that service
restoration must be in coordination with fire protection activities and in many instances, be
postponed until it is safe to enter an area. One of the recommended actions is to delineate fire
in Avista's Emergency Operations Procedure to ensure close coordination with fire incident
command and to promote the safety of employees and 1't responders above service restoration
Firestorm Facts
o 114 homes destroyed
o 50 mph wind
o 42 days without rain
o 35,000 acres burned
o 90 fires
o 3,000 calls to 911, 24 hours
o 2 fatalities
o WWP Call Center - 11,000
calls in 2 hours
o WWP pays over S10 million in
fire suppression costs, S50
million in infrastructure costs
Page | 21