Loading...
HomeMy WebLinkAbout20200529Exhibit A.pdfAttachment A t9 Attachment A Avista has been delivering safe and reliable electric energy for over 130 years. Our history is one of collaboration with communities and customers to ensure a balance of safety, economic vitality, and of stewardship. Recent wildfires have galvanized our commitment to public safety, emergency preparedness, and to protect our regional economy. Wildfires represent a growing threat to homes, businesses, and our way of life. This Wildfire Resiliency Plan represents Avista's commitment to mitigating potential wildfire risk associated with the delivery of electricity. lt also affirms our commitment to working closely with community leaders, with property owners, and emergency first responders. This Plan Ieverages the Company's experience with responding to adverse weather and environmental conditions including wildland fires. lt also represents the knowledge of Avista's employees, that of peer utilities, together with fire protection and land management agencies. This is who we are. Heather Rosentrater Senior Vice President, Energy Delivery and Shared Services Sincerely, Date: May 28,2O2O 2lPage G : May 28, 2020 WILDFIRE RESILIENCY PLAN Attachment A This report reflects the combined effort of mony Avisto employees. Though many honds were involved in the development of this document ond their contributions should not be overlooked, I would like to ocknowledge several key individuols without whom this report would not hove been possible. To Bob Brondkomp for doing the early work to quontify wildfire risk and for leoding the PNW Utility Wildfire Forum ond the Spokane County Fire District committee. To Greg Hesler for initioting the 'coll to oction' ond for his counsel throughout this process. To Dovid Howell for his unwovering leodership & personol support ond for responding to Greg's collto oction. And finolly, to Heother Rosentroter for moking Wildfire Resiliency one of her top priorities ond for lending her voice to the issue. Mony voices, one message. Thank you oll for your time, involvement, counsel, ond commitment to this effort.il,David James, Wildfire Resiliency Plan Manager The steering commiftee members of Avista's Wildfire Resiliency Plan approve this document. David Howell Bruce Howard Director,ElectricOperations Sr.Director,Environmental Affairs Signature Signature Bob Brandkamp Sr. Manager, Enterprise Risk Signature Date Date Date Elizabeth Andrews Sr. Manager, Revenue Requirements Signature Casey Fielder Manager, Corporate Communications Signature Annie Gannon Ma nager, Communications Signature Date Date Date Alicia Gibbs Manager, Asset Maintenance Signature Greg Hesler Vice President, General Counsel & Chief Compliance Officer Signature Date Date 3lPage May 28,2O2O WILDFIRE RESILIENCY PLAN Attachment A Executive Summary Objective This report details the recommended response to the increasing threat of wildfires within Avista's service territory. The recommendations within this report seek to reduce the risk of wildfire from the interaction of Avista's energy delivery system and the environment as well as the impacts of wildfire to Avista's system. These recommendations represent Avista's initial Wildfire Resiliency Plan. The Plan will be periodically reviewed to ensure consistency with industry best practices and that it is providing benefits to customers and the communities Avista serves. Bockground Avista's Wildfire Resiliency Plan reflects the Company's 130-year operating history combined with recent efforts to quantify and respond to the financial, safety related, and service reliability risks associated with wildfires. Risks are not static and this Plan will be updated to align with environmental, political, financial, and other factors that influence those risks. Plan objectives include focus in the following strategic a reas : o Protect lives and property o Ensure emergency preparedness and align operating practices with fire threat conditions o Protect Avista's energy delivery infrastructure Protectinq Lives ond Property Though many elements of this plan focus attention on Avista's transmission and distribution infrastructure and the effort to reduce spark ignition events, the reader should not lose sight of the plan's primary objective: to protect lives and property by reducing the number of utility involved wildfires. ln November 20L8,18,804 structures were destroyed and 85 residents lost their lives in the wildfire at Paradise, California. Though investigations continue, it is clear that the initiating action involved one of PG&E's transmission towers. This fact spurred actions by utilities across the nation, including Avista, to mitigate the potential for causing such fires. Avista provides electricalservice to over 380,000 customers with many customers living in elevated fire risk areas. A key factor in Avista's plan is how best to reduce the likelihood of a wildfire caused by Avista's electric operations. The recom mendations contained in this plan are based on the ability to reduce the risks associated with public and worker safety, the risks to property and infrastructure, and to lessen the impact of electric system outages. The relative importance of those risks is indicated in the graphic. 4lPape Relative lmportdnce of Risk Foctors oworker & Public SafetyoHomes & Property Or,..,r,. r",,,." Disruption outrrity lnfrastructure WIt t){: IRF RESIT IT NCY T't AI! May28,2O2O Attachment A Post Fire lVlitigotion Avista has a long history of responding to adverse operating conditions including wildfires. ln October of 1991, 60 mph winds combined with persistent drought sparked over 90 fires in the Spokane area.l Most of those fires were the result of vegetation contacts with powerlines. More recent fires in the Colville and Davenport operating districts have also influenced operating, maintenance, and design construction practices. This Plan builds upon that experience to mitigate the risk of wildfires. A few examples are shown below: Sbd Fd6 Transmlssion lin6 constructed with tubular steel pobs to protact critkal infrastructure. Dry f.nd Op.rrdtlt ilodG Durint fire saasoo distrlbutbn lines DO ilOI automatkally recbsc aftcr a line fault. RktTrtc P'otram Dead.nd dyitf, trcc3 that mlglt falllnto powcrllncs .rG removcd. GrU ]lrrdadn3 UpSrades to inft.structure in dsatcd flra risk arcas will protcct llnes from firc damate and limlt the spark-Bnltlon potentLl of line faultr. Nan 6rn Dry lrnd Additional circult reclos.rs wlll bc d.ploycd in elevatcd flre risk areas. DNtit l D.EcolLcdo.r Collection of UDAR suNey data to automatc tha identification of potcntial vegetat'on conflicts. Fho $faty icrdncss Avista and Fire crews to conduct Joim training and ficld erercises. Emcc.ncy (EOPI lmidcnt Command Structurc deployad durinE emerglnclcs. L lncreosed Frequency and Severity of Fire Activity The number and size of wildfires is increasing throughout the western United States. Data from the United States Forest Service (USFS) indicates that the number of large fires (>1000 acres) has tripled since 1970. Also, the duration of fire season has grown by over 100 days. A report from NASA's global science department summarizes the situation indicating six underlying trends.2 1Spokesman Review, Sl2UtS "Firestorm 1991" 2 NASA, global science, www.climate.nasa.gov/blog/2830 5lPage WILDFIRE RESILIENCY PLAN Current Practice Wildfire Resiliency May 28,2020 Attachment A 1. There ore more fires (51% of fires in the western U.S. have occurred since 2000) 2. And those ftres ore lorger (since 1950 acres burned per year has increased 600%) 3. A smoll percentage olthe west has burned (1t% of land mass impacted since 1950) 4. The same areos keep burning (-3lol of land is subject to cyclic wildfire activity) 5. Fires are burning more coniferous forest than ony other type ol landscope (since 2000, wildfires have shifted from burning shrub-lands to coniferous forest) 5. Wildfires ore going to have o big impaA on our luture (climate simulations from National Oceanic and Atmospheric Agency (NOAA) researchers suggest a 2OO-5OO% increase in the number of large fires by mid-century) 40% of Avisto's distribution ond 20% ot' transmission lines ore locoted in elevoted fire threot oreos. 12j,300 Avisto electric customers reside in these oreos. Researchers at NOAA predict that by mid-century l2O4L-20701,4 the conditions for'very large fires' will substantially increase throughout the western United States. The graphic on the right indicates the percentage increase for very large fires. Note that areas of eastern Washington and northern fdaho suggest a 300% to 4OO% increase. This trend, based on NOAA climate studies, combined with development in fire prone areas is projected to make wildfire one of the most significant environmentalthreats in the western United States.s Washington State's Department of Natural Resources is responsible for fire suppression on over 13 million acres of private and state owned forest lands. lts 2015 forest health report states that, " Neorly 2.7 million ocres of eostern Woshington forestland need treotment to be more resilient ogoinst insects, diseose, ond wildfires." That report recommends a variety of treatments including mechanical thinning and prescribed burns. To compound the issue, there are two million Washington homes located in elevated fire threat areas.3 *r" tfu" NOAA Fire Threot (2041-2070) - lndicotes the % lncreose of Very Lorge Wildfire Conditions (> L000 ocre fires) hoES r.rlt6da, t rrLrti'' - 0Joao, to to & !o .6 3 Washington Dept. of Natural Resources Forest Health, www.dnr.wa.gov/ForestHealth 4 National Oceanic and Atmospheric Administration, www.climate.gov s Caitlyn Kennedy, "Risk of Very Large Fires Could lncrease Sixfold by Mid-Century in the US," Climate.gov, August 25, 2015, https://www.climate.gov/news-features/featured-images/risk-very-large-fires-could-increase-sixfold-mid-century-us SlPage WlLDlilRE RESILIENCY PtAN May 28, 2020 Attachment A Public Sofety Power Shutoff ln November 2OL8, a wildfire near Paradise, California burned over 18,0O0 homes and resulted in 85 fatalities. No wildfire in modern history has created an industry response equivalent to the 'Camp Fire'. The California Public Utilities Commission mandated that utilities develop fire m'ltigation strategies. As a result, major utilities in California pre-emptively shutoff power to prevent spark-ignitions from overhead powerlines. This system is known as Public Safety Power Shutoff (PSPS).6 Though Avista is closely monitoring the situation in California and continues to work closely with utility peers including PacifiCorp, Pacific Gas & Electric, San Diego Gas & Electric, and Southern California Edison, at this time Avista does not plan to ore-emptivelv shutoff power to mitigate the risk of wildfire. This report details 28 individual recommendations aimed to reduce the risk of wildfires. Many of those elements support a system that Avista developed in the early 2000s. This system is known internally as Dry Land Mode or Dry Land Conditions (page 28). Avista operations and engineering staff support enhancements to the existing Dry Land system and believe it provides a balanced approach to mitigating wildfire risk while maintaining electric service during fire season. As detailed in this report, Avista's Dry Land Mode system involves both identifying electric circuits that operate in elevated fire risk areas and the reconfiguration of protection systems. Several elements of this plan support enhancements to that system including: o Development of a Fire-Weather Dashboard (computerized fire risk prediction system) o Annual electric distribution fuse coordination report (optimal protection) o Recloser event reporting (continuous improvement of protection systems) . Dry Land Mode engineering review (comprehensive system review). Dry Land Mode 'trigger' (initiate seasonal protection based on fire risk threshold) o Midline recloser communication (retrofit existing circuit reclosers with monitoring & control equipment) o Additional midline reclosers in elevated fire threat areas (aligning system protection with fire risk) o Wildland Urban lnterface (identify elevated fire risk zones) o Substation SCADA (retrofit existing substation with monitoring & control systems) It is impossible to prevent all tree contacts or equipment failures associated with the electric delivery system. However, by adding defense strategies specifically designed to reduce spark-ignition sources, Wildfire Resiliency represents a holistic approach to safeguarding human lives, property, and infrastructure against the threat of utility involved wildfires. 6 Public Safety Power Shutoff - California PUC - www.cpuc.ca.gov/deenergization TlPage WltDFlRt RESItIENCY PLAN May28,2O2O Emergency Operating Plan Attachment A Gools ond Objectives of Avisto's Wildfire Resiliency Plon Emergency Response .To prepare and train for episodic wildfire events. To recognize wildfire as a recurring threat to utility infrastructure, the communities we serve, Avista employees and customers. Protect Life and Property .To protect physical assets, property, and human lives against the threat of wildland fires. To recognize fire potential as a manageable risk element of Avista's operating and maintenance strategies. Safeguard Company Assets .To mitigate the probability and consequence of direct financial and liability costs associated with large scale fire events. Throughout the development of this Plan, a modelframework has been used to balance risks, costs, and benefits. Collaboration extended well beyond the internal walls of Avista to include voices from the community, fire protection professionals, regulators, utility peers, and professiona! service and material suppliers. Undcrrtand Rbk Desl6n fortheth. Understand the Risk * Combining int'rostructure doto with fire threot and weother conditions to yield o 'Jire risk potentiol' metric. Design for the Risk - Adopt tronsmission and distribution moteriols and construction to minimize the potentiolfor utility involved fire ignition. Plan for on Event Prepore field and ot'fice support stot'l through troining ond field simulation exercises. Portner with others - Collaborqte with others to leverage the strengths of various partners and create a stronger response system for oll involved. 8lPage Promote Safety Financial Protection Wi ldf ire Resiliency Framework May 28,2020 WII.DIIRT RESILIENCY PLAN Attachment A Wildfire Resiliency Plon Elements This Plan includes 28 individual recommendations grouped into four categories. These categories are similar to other utility wildfire plans including those from PG&E, SDG&E, SCE, and PacifiCorp:7 o Grid Hardening - by replacing infrastructure in fire prone areas, the likelihood of a spark-ignition source is mitigated and critica! infrastructure is protected from the impacts of fire. . Vetetation Management - by identifying potential conflicts on an annual basis and prioritizing those risk from highest to lowest, Wildfire Resiliency aligns resources with risk metrics. Situational Awareness . Situational Awareness - by adding line and monitoring equipment, system operators can respond quickly to variable weather and fire threat conditions. o Operations & Emergency Response - through training and simulation, Avista personnel will be better prepared to work with fire professionals during an event. Plan recommendations also reflect cost prudency and were adopted on their basis to: o Leverage existing asset programs and operating practices o Promote public safety . Mitigate financial risk The following tables provide more information about the recommendations. 7 California Public Utilities Commission, www.cpuc.ca.gov/wildfiremitigationplans/ 9lt'age WlLDFlRI RESILILNCY PLAN Transmission Fire Retardant (FR) Program FR paint program requires refresh every 3-5 years Genic Fire-Mesh wrap with 2O-year expected life Will reduce operating expense to maintain fire protection of transmission wood poles Transmission Line lnspection Aerial surveys to identify structure defects (reliability based) Aerial and ground inspections to identify structure defects (fire risk based) Reduce transmission fi re ignition events which are less likely than distribution related fires, but generally result in larger fires Dry Land Operating Mode (DLM) Seasonal implementation (single mode) Adapted to fire-weather (multi-mode) metrics By aligning DLM modes with weather and fire threat conditions, operators can balance service reliability with fire risk potential May 28,2020 Attachment A Risk-Based Steel Conversion Reduce likelihood of damage to Avista transmission assets. 20% of Avista's transmission assets are located in elevated fire threat areas Transmission Grid Hardening Condition-Based Steel Conversion Condition based pole, conductor, and equipment programs Risk based approach to replacing equipment and conductors associated with spark-ignition potential Reduce likelihood of distribution related fi res. 40% of Avista's distribution assets are located in elevated fire threat areas Distribution Grid Hardening Human based ground and aerial inspections Augment with computer automated analysis to identifo vegetation encroachment and structural defects Allows for scenario based planning of treatment options and serves as the QA tool to assess the efficacy of previous field work Ditital Data Collection Strengthens relationships between Avista and fire first responders and reduces fire severity threats to infrastructure No formal program Partnering with Fire Agencies to remove fuels near critical infrastructure Fuel Reduction Partnerships Align right-of-way boundaries to fire risk potential Protect critical infrastructure and serve as fire break Widen Transmission Rights- of-way No formal program Reduce tree fall-ins, which are 3 times more likely to occur than grow-ins Annual Risk Tree Cadence based program (e.g. 1-3 years) System-wide effort to annually identify and remove dead, dying, and diseased trees Work with customers in elevated fire risk areas to remove tall growing trees from underneath powerlines Reduces the risk of tree grow-ins and subsequent spark-ignition sources Public Outreach "Right Tree, Right Place" Campaign General information available to all customers ReGdnmcndation qrnc{ltStrtC Futurc Stltc Ecncfrtr Fire-Weather Dashboard Weather forecast data subject to individual interpretation By combing weather forecast and fire threat condition data, operating personnel will have clear guidance relative to likelihood and potential impact of fires Promotes a more consistent approach among operations and emergency managers Additional Distribution Circuit Reclosers Based on system protection and reliability performance Deployed in elevated fire threat areas. Reflects a risk- based strategy Supports the evolution of Avista's Dry Land operating mode to align with forecasted weather and fire threat conditions l0 lPage WIIDIIRE RISITIENI CY PtAN May28,2O2O SCADA added to new or reconstructed substations. Reflects a condition based approach Enables control and monitoring of substation equipment including circuit reclosers in elevated fire risk areas (as stated above)Substation Supervisory Control & Data Acquisition (scADA) Attachment A The Wildlond lJrbon lnterface (WUI) The interface area between forest lands and human development is referred to as lMldj4llUfban lnterface (WUl). Homes and businesses located near the WUI are most at-risk from the impact of wildfires and are often located in rural areas that lack fire suppression resources. ln 2019, Avista's GIS Technical Group created a WUI map for the electric service territory based on the following principles: o Fuel Concentration - areas identified as having moderate to high fuel concentrations were considered. Fuels data was derived from the U.S. Department of Agriculture's Wildfire Hazard Potentialmap.s o Housing Density - parcels smaller than 20 acres were included in the analysis but highly- developed urban areas were excluded. Urban areas do not meet the definition of Wildland Urban lnterface because fuel canopies are dispersed and fire protection is readily available. The WUI map helps to identify and prioritize areas of greatest risk and serves to inform the recommendations and operational decisions related to wildfire resiliency. The Plan denotes the 8 U.S. Department of Agriculture, data.nal.usda.gov/dataset/wildfire-hazard-potential....... 11 lPage WILDFIRE RESILIENCY PLAN Avista EOP to delineate wildfire from other storm events. Avista to offer assistance at all fire lCS. Coordinate Avista system restoration with fire protection and evacuation activities Emergency Operating Procedure & Avista lncident Command Representative No formal wildfire policy None Develop fire-specific performance metrics to ensure that Plan objectives are beins met Supports the adaptation of the Resiliency Plan to meet current operating and environmental conditions Wildfire Performance Metrics Developed in Q3/2019 Categorize Avista T&D infrastructure with respect to fire ignition potential and fire imoact consequence Focuses vegetation management and grid hardening efforts in the highest fire risk areas Wildland Urban lnterface (wUl)map No formal program Annual fire safety trainint to Avista field personnel and electrical hazard training to fi re protection personnel Promotes safety of first responders and supports a variety of partnerint activities including fuel reduction and fire adapted communities Emergency fi rst responder training Expedited Fire Response Draft MOU under consideration with Spokane Fire Districts (2020 Pilot Proiect) Fire agency personnel to investitate transmission line faults during fire season Suppress fires before they have an opportunity to spread May 28,2O2O Attachment A combination of WUI Tiers 2 & 3 as "elevated fire threat areas". These areas comprise 40% of Avista's electric distribution and 2OoA of the high-voltage transmission systems. Elevated fire threat levels are depicted in orange (Tier 2) and red (Tier 3) highlighted areas. Portions of the map not highlighted are classified as Non-WUl and represent areas with low fuel concentrations, very low housing densities, or large urban areas (> 10,000 population). The Plon denotes the combinotion of WU I Tiers 2 & 3 os "elevoted fire threot oreos". These oreos comprise 40% of electric distribution and 20% of transmission systems. Elevoted fire threot levels ore depicted in oronge (Tier 2)ond red (Tier 3). Portions of the mop not highlighted ore classified os Non-WUl ond represent oreos with low fuel concentrotions, very low housing densities, or densely populoted urbon oreos. Summory of Risks ond Costs Precise identification of the risk-cost for any given year is not realistic, and for wildfires, there is a significant difference between smallfire events which can occur many times per season versus a large scale event which may occur once every few years. Therefore, in order to represent a more realistic picture of relative risks and costs, a 10-year planning horizon was adopted. 12 lPage May28,2020 WITDFIRE RESILIENCY PIAN lnterface +f jr if.--+ ILIIir ffiutuffid a aDamr2018lswldlEMrdMlinx) rc ddt tl3bti Slen FErd b, E nc Dot+ 9E G l|l/{ Attachment A Risk and cost values shown in the following table represent a lO-year planning horizon, and include both incremental operating expenses as wel! as capital improvements to infrastructure. Capital plan elements are projected to sunset in 10 years but the majority of expense items are on-going and are generally related to vegetation management. ln simple terms, risk is the product of the probability of an event and financial consequence: Risk = (The likelihood ol occurrence, or probobilitfl X fihe linoncial impoa ol on event) lnherent Risk - describes the current state risk level and reflects defense strategies already in place. Manased Risk - describes the future state risk level with the addition of Wildfire Resiliency elements. The values shown for risk are percentage based and reflect a range for each category. Note that vegetation and grid hardening risk scores indicated a bounded range because the probability of occurrence is based on the frequency of forced outages, and the frequency of electrical outages is well understood. However, an event's impact can vary widely based on several factors including weather, fire risk levels, emergency response, and location. Note that the managed risk scores represent future state levels and lower levels of event probability and event outcome. The column labeled 'Risk Reduction' indicates the average percentage difference between current state and future state risk levels. Risk and Cost Sum and ldaho Electric Enhanced Vegetation . Management : Situational Awareness Operations & Emergency Response Grid Hardening & Dry Land Mode 13 lPage 48.3-100 25.9-100 19.7-100 41-100 3.2-14.5 0.8-1.1 s.3-23.4 0.7-2.7 887o s5,1oo,ooo Ss1,175,ooo 98%s17,955,000 s1,019,000 76%S3oo,ooo s2,37g,ooo 98Yo 5245,600,000 55,014,000 Plan Total 44.1-100 2.8-t2.s 8996 $268,965,000 $s%se6,ooo As noted, the wildfire resiliency program includes electric system (Washington and ldaho) capital investments of 5268,955,000 over 10 years with corollary operating expenses of $59,586,000. Expenditures are illustrated on the following page from 2020 through 2029. The single largest capital investment is grid hardening of the electric distribution system. This accounts for S193,200,000 invested in distribution systems located in elevated fire risk areas and another 544,000,000 invested in the transmission system to convert from wood to steel poles. These two Plan elements account for 88% of total capital spend. For operating expense, three elements: T&D digital data collection, annual risk tree, and the public safety initiative 'right tree right place' account for !VItDTIRL RISItIt N(Y PIAN 2020-2029 Operating Horizon lnherent Risk (range %) Managed Risk (range %) Risk Reduction (avg%l 10-yr Capital lnvestment (s) 10-yr Operating Expense ($) May 28,2O2O Attachment A S42,7OO,OOO 1720,6l overthe same 10-year period. Though, this Plan includes 28 recommendations to mitigate the risk of wildfire, these five elements account for 85% of the total orosram investments. Avista Wildfire Resiliency Plan Cost Forecast s3s,000 53o,ooo s2s,ooo s2o,ooo s1s,o00 s10,000 ss,ooo So r Capital I Operating I 202t 2022 2023 2024 2025 s16,98s s27,oss s31,380 s31,380 s31,380 ss,371 s6,917 $7,43s s7,3s4 56,772 2029 s31,380 ss,oe6 _qooo <,\ 2020 ss,26s 52,41.6 2026 531,380 $6,s40 2027 s31,380 s5,ose 2028 s31,380 5s,627 r Capital I Operating Potentiol Operoting & hlointenonce Expense Cost Reductions The goal of wildfire resiliency is to reduce the overall risk associated with wildfires. ln short, the benefits of this Plan are largely measured in terms of risk reduction for all parties involved. However, we recognize the potentialfor costs savings and cost shifts from operating and maintenance expense activities towards capital investment. The overall impact of cost savings is speculative until the Plan becomes operational and performance data can be analyzed. However, one objective of this Plan is to reduce the number of equipment failures and tree related outages and by doing so, avoid emergency response. Consider a hvpothetical scenario wherebv Wildfire Resiliencv reduces these outages bv 10%. From 2014 to 2018, the electric distribution system experienced 5,200 outages per year. This corresponds to an annual frequency index (SAlFl) of 1.1 with a duration index (SAlDl) of approximately 2 hours and 20 minutes. On average, 57 customers were impacted during each outage. Equipment failures and tree related outages account for approximately 1,000 outages per year and it is these outages that wildfire resiliency aims to mitigate through grid hardening and enhanced vegetation management. lf those outages were reduced by just 10% (100 outages), the reduction in customer impact would equate to S99O,Z8O per year.e Again, this is a hypothetical exercise to illustrate the Plan's value proposition. e Based on Avista Asset Management Risk Analysis Standard (service interruption .os1 = $63 per customer* hour) 14 lPage Wll.DFlRE RESItIENCY PtAN May28,2O2O Cost Savings/ShiftPlan Element Benefit Attachment A The following table lists several potential cost savings opportunities associated with wildfire resiliency. It should be noted that this Plan indicates program level spend estimates and does not differentiate between incremental and embedded costs. Though many Plan elements represent incremental costs, some activities will simply be absorbed by the workforce. For example, annual fire safety training will occur at monthly safety meetings which are wel! established. This imbedded cost is estimated at S1,300,000 over 10-years. However, the bulk of the Plan elements including enhanced vegetation management and grid hardening represent additionalactivities and incrementalcosts. As previously indicated, these categories account for 85% of overall program costs. Annual Risk Tree and Right Tree Right Place Programs Digital Data Collection Grid Hardening Situational Awareness (communication & control systems) Operations & Emergency Response 15 lPage lmproved System Performance (fewer outages) Automates data gathering process for vegetation and structu re condition inspection I mproves System Performance (fewer outages) Enables remote monitoring and control of equipment Better prepared and equipped first responders Reduced spend on emergency response and unplanned repairs Reduces field inspection activities. Enables automated OA/aC functions Reduced spend on emergency response and unplanned repairs Reduced service related truck rolls Reduces the risk of injury and accidents Wlt Dt lRI Ri:SltIENCY PtAN May 28, 2020 Attachment A Conclusion The risk of large wildfire events is increasing across the western United States. The recent fires in California serve to illustrate that utility operating risks are increasing due to wildfires. Managing this risk is criticalfor customers, communities, investors, and the regional economy. Avista has taken a proactive approach for many years to manage wildfire risk, and through this Plan, the Company has identified additionalwildfire defenses. The goals, strategies, and tactics set forth in this Plan reflect a quantitative view of risk. Additional research, conversation and analysis with Avista's operating staff and steering group provided critical qualitative and contextual information that also shaped the recommendations. This combination of quantitative and qualitative analysis ensures the recommendations are robust, well-rounded, thoughtful, and align with the Plan objectives. Comprehensive risk analysis indicates a cumulative 10-year financial risk of at least Sg blttlon dollars. This value includes the accumulated risks associated with all 28 Plan recommendations and should not be interpreted as a precise financial estimate. A better metric is the percentage of risk mitigation which reflects a 90% reduction for the overall Plan. Though planned investments in infrastructure and vegetation maintenance defenses represent the bulk of costs, human investments in training, partnerships, and engagement with customers are core components of Wildfire Resiliency. Wildfire Resiliency represents a departure from traditional utility strategies aligned with meeting customer demand (capacity) and maintain ing service conti nu ity (rel ia bility). Avista's strategy aligns with other utility wildfire plans by adding defenses in four key areas: vegetation management, grid hardening, situational awareness and operations and emergency response. Avista has a long history and tradition of 'doing the right thing'for our customers and the communities we serve. Working together to promote safety and manage the risk of wildfire is not a new concept but simply one that will be built upon. End of Executive Summary 16 lPage WILDFIRE RESITIENCY PLAN May28,2O2O Partnering with Others The Western Energy lnstitute The Edison Eledric lnstitute Washington Deportment of Noturol Resources ldaho Department of Lands AEGIS lnsuronce PNW Utility Wildfire Group (PSE, PAC, CHPD, IPC NWE, PGE, AVA) The University of ldoho ldoho Smort Growth lnitiotive Spokone County Fire Distrids City of Spokane Fire Deportment Spokone Valley Fire Deportment Palouse County Fire Distrids Spoka ne Eme rg e ncy Manogeme nt NOAA & NWS (Weather) Wdshington Utilities ond Tron sportatio n Co m mittee (WUTC) ldaho Public Utilities Commission (IPUC) Woshington Dept. of Notural Resources (DNR) Utility Taskforce Weste rn Gove rnof s Associotio n West Coost Utility Commission Seminar (Vendors) Quantum Spotiol Genics Corporotion Geo Digitol Corporotion Western Weother The Eoton Corporotion TROVE Corporotion Wildftre Resiliency Plon Goals Risk Assessment.................... Attachment A TABLEOF CONTENTS Executive Su mmory....... Wildfire Resiliency Plan Overuiew.,...........78 20 20 25 28 )9Grid Hardening & Dry Land Mode D-L6(L7 Distribution System Grid Hardening .30 D-13 D-6 D-8 Additional Dry Land Mode Circuit Reclosers ......................31 Dry Land Mode Effectiveness Study .............32 Dry Land Mode Trigger ...........34 38 .39 .4L 50 .51 .53 .55 Plan Recommendations Summary ... Plon Recommendotions by Category ST-12 Transmission System Grid Hardening .35 ST-10 Transmission lnspection Program........ ...,.....36 ST-5 Transmission Wood Pole Fire Retardant Protection .37 Enhanced Vegetation Management ................ D-10 Electric Distribution Annual Risk Tree....,.. D-11 Public Safety lnitiative: "Right Tree, Right Place" D-14 Distribution Digital Data Collection ...............43 ST-5 Transmission System Digital Data Collection .45 D-4 lncorporating Vegetation Management into Distribution Designs ..........49 Situationa! Awareness..... D-15 Substation SCADA D-tz Distribution Management System (DMS) Communication ST-2 Fire-WeatherDashboard Operations & Emergency Response ST-1 EmergencyOperatingProgram(EOP)............. ST-3 Transmission Design's Role in Major Event Response............ ST-4 Wildfire Performance Metrics ST-8 Wildfire Training for Avista First Responders ST-9 Expedited Fire Response D-1 Fuse Coordination Study D-2 Circuit Recloser Event Reporting D-3 Fire lgnition Tracking System D-5 Fire Suppression Water Additive D-7 WUI Layer in Avista GIS System D-9 WildfireNotificationSystem.......... Conclusion. Addendum. lTlPage 57 .58 .59 .60 .60 .6L .62 .53 .63 .64 .64 .55 66 67 May 28,2O2O WILDFIRE RESILIENCY PLAN Attachment A Wildfire Resiliency Plan Overview Avista's Wildfire Resiliency Plan reflects the Company's 130-year operating history combined with recent efforts to quantify the financial risk of wildfires. Risks are not static and this Plan will adapt and evolve over time to align with environmental, political, financial, and other factors that influence those risks. The foundation of this Plan is the monetization of risk resulting in a series of recommendations to: o Protect Avista's energy delivery infrastructure o Enhance vegetation management programs and reduce tree contacts with powerlines o Deploy additional system monitoring and control equipment o Align operating practices and emergency response with fire threat conditions Post Fire Mitigotion Avista has a long history of responding to adverse operating conditions including wildfires. ln October of 1991, 60 mph winds combined with persistent drought sparked over 90 fires in the Spokane area.lo Most of those fires were the result of vegetation contacts with powerlines. Recent fires in the Colville and Davenport operating districts have also influenced operating, maintenance, and design construction practices. This Plan builds upon that experience by leveraging current defense strategies and focusing efforts in elevated fire risk areas. A few examples are shown below: Steel Poles Transmission lines constructed with tubular steel poles to protect critical infrastructure. Dry Lend Operating Mode During fire season, distribution lines DO NOT automatically reclose after a line fault. Rbk Tree Profam Dead and dying trees that might fall into powerlines are removed. Emergency (EOP! lncident Command Structure deployed during emergencies. 10 Spokesman Review newspaper, "Firestorm 1991", August 27,20L5 publication 18 lPage WltDFlRt R['SltiIl'.1 CY PtA[] Grld Hardcnlng Upgrades to infrastructure in elevated flre risk areas will protect lines from fire damage and limit spark- ignition potential of line faults. NenGen Dry lrnd Additional circuit reclosers deployed in elevated fire risk areas to allow alignment between fire risk conditions and system protection. DlShal Data Collectlon Collection of LIDAR and Hi- Res Photography to automate the identification of potential veSetation conflicts and structure defects. Flrc Safety Readlness Avista and Fire crews to conduct joint training and field exercises. Cu rrent Practice Wildfire Resiliency May28,2O2O Attachment A lncreosed Frequency and Severity of Fire Activity The number and size of wildfires is increasing throughout the western United States. Data from the United States Forest Service (USFS) indicates that the number of large fires (>1000 acres) has tripled since 1970. Also, the duration of fire season has grown by over 100 days. The graph below indicates wildfire frequency from 1950 to 2017.11 20L7t.rk trh ;h 1950 th ndlrn Over the post six decodes, 61% of fires in the western U.S. hove occurred since 2000. tnd 40% of Avisto's distribution ond 20% of transmission lines ore locoted in elevoted fire threat oreos. 123,300 Avisto electric customers reside in these oreos. iitiiiiiiiii!;iii;!;ii;iii;ii;iiii;ii;ii:IIiSIIStIgrRq9qtBlEiii;Ei;;(lt Washington State's Department of Natural Resources is responsible for fire suppression on over 13 million acres of private and state owned forest lands. lts 2015 forest health report states that, " Nearly 2.7 million acres of eostern Woshington forestlond need treotment to be more resilient ogoinst insects, diseose, and wildfires."l2 That report recommends a variety treatments including mechanical thinning and prescribed burns. To compound the issue, there are two million Washington homes Iocated in elevated fire threat areas. ln September of 2015, the Corpenter rood fire impocted 64,000 ocres of lond neor Dovenport, WA ond domaged 42 structures. The costs to suppress this fire exceeded S2oo million.l3 11 NASA, www.climate.nasa.tov/blog/2830 12 Washington Department of Natural Resources 2O-year Forest Health Plan (2017) 13 Spokesman Review newspaper, Carpenter Road Fire, September 15, 2015 19 lPage WILDtIRE RESILIENCY PLAN May28,2O2O Attachment A Researchers at the National Oceanic and Atmospheric Agency (NOAA) predict that by mid- century QO4L-2O70!,, the conditions for'very large fires' will substantially increase throughout the western United States.la The graphic shown to the right indicates the percentage increase for very large fires. Note that areas of E. Washington and N. ldaho indicate a30f.%to 4OOo/o increase. The combined trends of more frequent and larger fires combined with development in fire prone areas is projected to make wildfire one of the most significant environmentalthreats in the western United States.:sG 5 * s.rt a, rar f,t, llor !,ffi Wildfire Resiliency Plan Goals Objective: This report details Avista's recommended response to the increasing threat of wildfires to the energy delivery system. The plan will be periodically reviewed to ensure that it is consistent with industry best practices and continues to provide benefits to customers and the communities Avista serves. Gools of the Wildfire Resiliency Plon The stated goals of this Plan are: 1. Emergency Preparedness - to prepare and train for episodic wildfire events. To recognize wildfire as a recurring threat to infrastructure, the communities we serve, Avista employees and customers. 2. Promote Public & Worker Safety - To protect physical assets, property, and human lives against the threat of wildland fires. To recognize fire potential as a manageable risk element of Avista's operating and maintenance strategies. 3. Financial Protection - To mitigate the probability and consequence of direct financial costs and liability associated with large scale fire events. Risk Assessment Wildfire Risk Fromework Recommended actions described in this Plan are based on Avista's Enterprise Risk Model and Asset Management risk methodology. ln addition to risk analysis, a modelframework was established to help guide the process for identifying, quantifying, and adopting recommendations. 14 lnternet source: www.climate.gov/news-featuresfeatured-images/risk-very-large-fires-could-increase-sixfold-mid-century- us 20 lPage May 28,2020 NOAA Fire Threot (2041-2070) - lndicotes the % lncrease of Very Lorge Wildfire Conditions (> 1000 ocre fires) WILDTIR[' RESII IENCY PLAN Wildfire Resiliency Framework Attachment A tlndcrst rnd the Rrsk L)csip,n (or the' Risk tA$r6) Oo*ucrh,Opcrtlhr&Il&hre Podner Plan for the probohilityof an event Understand the Risk - Combining infrastructure data with fire threat and weather conditions to yield a 'fire risk potential'metric. Design for the Risk - Adapt transmission and distribution materials and construction to minimize the potentialfor utility involved fire ignition. Plan for an Event- Prepare field and office support staff through training and field simulation exercises. Partner with Others - Direct collaboration with Fire Protection Agencies and customers to reduce fuel loadings near homes and powerlines. Rlsk Assessrn e nt l\,4 eth o do I o gy The recommendations in this report are based on their ability to reduce the operating and financial risk of wildfires. Understanding how to quantify risk is fundamental to understanding the content of this report. ln order to illustrate this concept, consider the risk of distribution pole fires. Pole fires are a common occurrence on overhead electric distribution system and generally occur when dust and other contaminates accumulate during a prolonged period of drought. ln most years, the drier months of July through September present the most likely period to experience a pole fire. For each pole fire there is an associated risk cost. 21 lt',r 1: r' May 28,2020 wtr t)r lRt tit :;! lt l.l( \ I | /rt,J Attachment A On average, Avista experiences 92 pole fires per year. ln most cases, Avista crews use fire suppression equipment to contain the fire and repair any damage. In some instances, pole fires are conveyed to the ground and can spread quickly under the right fuel and weather conditions. Wildfire Resiliency risk modeling considered three potential impacts: Public Safety - the cost of injuries associated with Avista employees and the general public. Service Reliability - the costs associated with service disruption based on the Department of Energy's Interruption Cost Estimator (lCE). For Avista customers, this value is S53 dollars per customer-hour. Financial lmpact- the replacement costs of infrastructure (direct) and third party claims to reimburse for property damage, timber loss, and fire suppression (indirect). The following toble provides on example of outcomes ond impocts. Sr,soo Ssoo S2oo s12s ,500s71 0.1 .002 Safety-Employee s10,000 s2,000,000 52oo sr8,000 s190,000 Direct Financial lndirect Financial {minor) lndirect Financial (large) Safety-Public (minorl Safety-Publlc lmajor) Relaability (minor) Reliability (moderatel Reliability (majorl Total (per event! lnherent Risk = 92 events/year x $/event lnherent Risk over 10- year planning horizon (assumes level rate! 22!Page May 28,2020 Optimistic S1,soo Ss,ooo s100,000 .05 , s2,500 o.7 Pessimistic Optimistic s20,000 s2,000,000 s7s,oo0 sso,ooo s10,000,000 Avista crews responding to pole fires 3d Pafi costs (e.g. suppression) Ground fire spread by wind and fuel loading Employee injury ranging from minor burn to back or shoulder injury lnjury Fatality Service point (2-15 customers) Lateral circuit (140-240 customers) Feeder circuit (1500-3000 customers) Pole fire risk cost per year. This is illustrotive of the ronge used in the Wildfire Resiliency Plan for o sub element of distribution grid hordening .01 .001 0.25 0.0s s2,ooo S30,ooo s378,000 s140 S3,600 S9,soo S14,s15 s1,335,380 $roo s2,000 , Pessimistic S7,soo s2,0oo s4,000 S3,7so Ssoo Slo,ooo Sr,aoo s6,000 s18,900 s48,800 s4,499,500 S13,3s3,800 s44,896,fit0 WILDFIR[. RESII III{CY PI AN Probability per event NotesRisk Cost (S)lmpaa Cost (S)Outcome Attachment A The table on the previous page reflects the inherent risk (current state) of pole fires. Poles fires are mitigated by replacing wood crossarms with fiberglass units. ln the above example, the outcome scenario or impact would remain unchanged but the probability of occurrence would be drastically reduced. For illustration purposes, if one assumes an 80% efficacy rate, the new risk costs ranges from 52,670,000 to 58,880,000 reflecting a median risk reduction of 523,300,000 over the 10-year planning horizon. This value would then be compared to cost estimates to determine if the treatment is warranted. ln May and June of 2079, o series of Wildfire Risk Workshops were focilitoted by Avisto's Business Process lmprovement teom to ossess the overoll risk cost of wildfires. Six individual workshops were held over o 75- day period involving 30 employees. Over 760 treotments were identified ond neorly half of those were onolyzed for their risk reduction capocity. Ultimotely, 28 treotments were carried forword ond serve ds the individuol recommendotions in this report. Pole fires generally occur on wood poles with wood crossarms. Since the early 2000's, Avista The Wildlond Urbon lntert'oce (wut) has adopted fiberglass crossarms as the standard An additionat element of risk reduction includes the prioritized application :i:kt.:."j]il:ffi:jff;'ilijffJ"J:l;il:; of solutions. Recommendations within this report consider geographic location and apply risk reduction measures in areas with higher fire threat potential. Homes and businesses most at-risk from the impact of wildfires are those located near the boundaries of forest lands and in rural areas that lack fire suppression resources. ln 2019, Avista's GIS Technical Group created a Wildland Urban lnterface map based on the following principles: Fuel Concentration - Areas identified as having moderate to high fuel concentrations were considered in the analysis. Fuels data was derived from the U.S. Department of Agriculture's Wildfire Hazard Potentialmap.ls Housing Density - Parcel's smaller than 20 acres were included in the analysis but highly-developed urban areas were excluded.LG Urbon oreos do not meet the definition of Wildland lJrbon lnterfoce. 1s USDA, Wildfire Hazard Potential, 2018 16 Avista Gl5 System, Electric Distribution Service Connections 23!t'age WlttlrlRl RtSltltN(Y PL/iN I i May 28,2O2O Attachment A WUI Risk Levels - Similar to the work done in California, Avista's WUI identifies three wildfire risk levels TIer 1- Moderate levels of fuel and low to moderate housing densities (low) I- Moderate to high levels of fuel and moderate housing densities (medium) I- High fuels levels and moderate to high housing densities (high) Avista's Wildland lnterface Map This Plon describes the combinotion of WUlTiers 2 &j os "elevoted fire threot oreos". These oreos comprise 40% of the electric distribution ond 20% of the tronsmission systems. Elevoted fire threat levels ore depicted in oronge (Tier 2) ond red (Tier j) highlighted oreos. Portions of the mop not highlighted ore clossified as Non-WUl ond represent oreos with low fuel co nce ntrotio n s, ve ry I ow housing densities, or densely populoted urbon oreos. Mony of the elements described in this Plon will be deployed only in elevoted fire threot oreos including grid ho rde n i ng, d igitol d ota collection, a nd fi re -s pecific oeriol inspections. 24 lPage May28,2020 la o lnterface o?J*'1l r..f Ja L'r'-' -i 16 'At,_t E!.!t 06Eb.0n Wn IrrIt! lr-.&algulfirHedgomdaor9mhtoEa{bown FtD.nd b, Ed. foa4 lf Crn lr1 o , I a o WILDFIRE RESILIENCY PLAN Attachment A Plan Recommendations Summary This Plan contains 28 individual recommendations grouped into four categories. These categories are similar to other utility wildfire plans including those from PG&E, SDG&E, SCE, and PacifiCorp and include: Grid Hardening - Replacing infrastructure in fire prone areas, the likelihood of a spark-ignition source is mitigated and critical infrastructure is protected from the impacts of fire. Enhanced Vegetation Management - ldentifying potential conflicts on an annual basis and prioritizing those risks from highest to lowest, Wildfire Resiliency aligns resources with risk. Situational Awareness - Adding line and monitoring equipment, system operators can respond quickly to variable weather and fire threat conditions. Operations & Emergency Response - Through training and simulation, Avista personnel will be better prepared to work with fire professionals during an event. Plan recommendations reflect cost prudency and were adopted on their basis to: . Leverage existing asset programs and operating practices o Promote safety and safe practices . Mitigate financial risk to property and infrastructure The following tables provide more information about the recommendations. o a a a FR paint program requires refresh every 3-5 years Genic Fire-Mesh wrap with 20-year expected life Will reduce operating expense to maintain fire protection of transmission wood ooles Transmission Fire Retardant (FR) Program Transmission Line lnspection Aerial surveys to identify structure defects (reliability based) Aerial and ground inspections to identify structure defects (fire risk based) Reduce transmission fi re ignition events which are less likely than distribution related fires, but generally result in larrer fires Dry Land Operating Mode (DLM) Seasonal implementation (single mode) Adapted to fire-weather metrics (multi-mode) By aligning DLM modes with weather and fire threat conditions, operators can balance service reliability with fire risk potential Condition-Based Steel Conversion Risk-Based Steel Conversion Reduce likelihood of damage to Avista transmission assets. 20% of Avista's transmission assets are located in elevated fire threat areas Transmission Grid Hardening Distribution Grid Hardening Condition based pole, conductor, and equipment proSrams Risk based approach to replacing equipment and conductors associated with spark-ignition potential Reduce likelihood of distribution related fi res. 40% of Avista's distribution assets are located in elevated fire threat areas 25 lPage May28,2O2O WILDFIRE RESILIENCY PLAN Attachment A Augment with computer automated analysis to identifo vegetation encroachment and structural defects Allows for scenario based planning of treatment options and serves as the QA tool to assess the efficacy of previous field work Digital Data Collection Human based ground and aerial inspections No formal program Partnering with Fire Agencies to remove fuels near critical infrastructure Strengthens relationships between Avista and fire first responders and reduces fire severity threats to infrastructure Fuel Reduction Partnerships Widen Transmission Rights- of-way No formal program Align right-of-way boundaries to fire risk potential Protect critical infrastructure and serve as fire break Reduce tree fall-ins, which are 3 times more likely to occur than grow-ins Annual Risk Tree Cadence based program (e.9. 1-3 years) System-wide effort to annually identify and remove dead, dying, and diseased trees Work with customers in elevated fire risk areas to remove tall growing trees from underneath powerlines Reduces the risk of tree grow-ins and subsequent spark-ignition sources Public Outreach "Right Tree, Right Place" Campaign General information available to all customers Slurr0onsl Aws.rrric Bacdrmgrddoo qrrcotStrb fuurcStrt!Banfit3 Fire-Weather Dashboard Weather forecast data subject to individual interpretation By combing weather forecast and fire threat condition data, operating personnel will have clear guidance relative to likelihood and potential impact of fires Promotes a more consistent approach among operations and emergency managers Additional Distribution Circuit Reclosers Based on system protection and reliability performance Deployed in elevated fire threat areas. Reflects a risk- based strategy Supports the evolution of Avista's Dry Land operating mode to align with forecasted weather and fire threat conditions Substation Supervisory Control & Data Acquisition (scADA) SCADA added to new or reconstructed substations. Reflects a condition based approach Enables control and monitoring of substation equipment including circuit reclosers in elevated fire risk areas (as stated above) Coordinate Avista system restoration with fire protection and evacuation activities Emergency Operating Procedure & Avista lncident Command Representative No formal wildfire policy Avista EOP to delineate wildfire from other storm events. Avista to offer assistance at all fire lCS. Develop fire-specific performance metrics to ensure that Plan objectives are beins met Supports the adaptation of the Resiliency Plan to meet current operating and environmenta I conditions Wildfire Performance Metrics None 26 lPage WIIDFIRF RFSIIIFNCY PtAN May28,2O2O Attachment A Wildland Urban lnterface (WUl)map Developed in Q3/2019 Categorize Avista T&D infrastructure with respect to fire ignition potential and fire impact consequence Focuses vegetation management and grid hardening efforts in the hi:hest fire risk areas Emergenry fi rst responder training No formal program Annual fire safety training to Avista field personnel and electrical hazard training to fi re protection personnel Promotes safety of first responders and supports a variety of partnering activities including fuel reduction and fire adapted communities Draft MOU under consideration with Spokane Fire Districts (2020 Pilot Proiectl Expedited Fire Response Fire agency personnel to invertigate transmission line faults during fire season Suppress fires before they have an opportunity to spread 27 lPage May28,2O2O WILDFIRE RESILIENCY PLAN 2018 California Utility lnvolved Fires ns V ation Contact #ofsource: CAL FIREI Equipment Downed Wire Fuse Animal Total Attachment A Plan Recommendations by Category Grid Hardening & Dry Land Mode Nearly 10% of Avista distribution outages are related to equipment and conductor failures. These include transformers, overhead conductor, connectors, insulators, and larger equipment like circuit reclosers and voltage regulators. Over 600 outages per year occur due to these failures. Recent data from the California State Fire Authority (CAL FIRE) indicates that over 1,000 utility involved fires occurred in California during 2018. The breakdown of that data is shown below and indicates that 38% of utility events were related to utility equipment. CAL FIRE estimates that utility ignition sources account for approximately 10% of wildfires across the state, while data from Washington State indicates a range of 4-6016 for the Pacific Northwest region.l7 Though the contribution is relatively low, wildfires are increasing in both size and number across the western United States, and represent a significant risk to companies. Currently, Avista does not track fire ignition events associated with transmission or distribution line faults. As noted, Avista's Outage Management System (OMS) is the system of record for T&D customer outage records, and, in many instances, forms the basis of fire probability used in this report. Between 2014 and 2018 the breakdown of Avista's distribution system outages is summarized in the table on the left. Based on this information and subsequent risk analysis, the grid hardening objectives are: 1. Reduce the number of spark ignition events on the distribution system (Event Probability) 2. Reduce wildfire impact to transmission lines (Event Outcome) 17 Western Utility Commission Wildfire Seminar, Portland OR, April 2019 28tPage WILDFIRE RESItIENCY PtAN As port of the wildfire Resiliency Plon, Avisto will trock fire ignition doto o ssociote d w ith powe r I i ne electricolfoults. Annual Avista Electric Distribution Unplanned Outages rce: Avista 2014-2018 OMS 6.2% 42,7% 9.s% 2.8% L.5% 9.0% 2.1% 26.r% on Contact ductorOH Equipme Pole Fire Public Fire Wind Animal Car Hit Pole Storm Related & UG May 28,2O2O Attachment A As part of Wildfire Resiliency, Avista will focus grid hardening efforts in the Wildland Urban lnterface Tier 2 and 3 areas (elevated fire risk). The program includes: o Transmission Wood Pole Fire Retardant Protection (Fire-Mesh Wrap) o Transmission Line Fire lnspection Program o Transmission Grid Hardening (Wood to Steel Pole Conversion) . Dry Land Mode engineering review . Dry Land Mode standing operating procedure (initiating) o Distribution Midline Recloser in WUI Areas o Distribution Grid Hardening Grid hardening efforts reflect the bulk of capital investment in the Wildfire Resiliency Plan. On average, equipment and conductor failures account for L0% of allforced outages and reducing those outages is a primary objective of this Plan. Many sources of powerline outages are difficult to control, including winter storms, strong wind events, thunderstorms, and public caused outages including vehicular accidents and trees that are felled through powerlines. However, by upgrading powerline conductor and equipment, these failures are manageable and represent a cost effective means to reduce the overall number of spark-ignition events. Take for instance, pole fires. The mechanism that causes pole top fires is well-known and is related to insulator leakage current which increases during periods of hot, dry weather when insulators become covered with dust and other contaminants. This leakage current can be concentrated between wood to wood contacts such as the contact point between wood crossarms and wood poles. In the early 2000's, Avista began using fiberglass crossarms and this has virtually eliminated fires on poles with the new fiberglass crossarms. As part of Wildfire Resiliency, wood crossarms on structures located in elevated fire areas will be replaced with fiberglass units. Grid hardening risk levels and costs are summarized in the table below. lnherent Risk Exposure (category %) 41-1OO Managed Risk Exposure (category %) 0.7-2.7 Risk M %l ,gg% Total Operating Expense , Total Capita! lnvestment S5,o14,ooo S24s,600,ooo Various internol reports including the Wildfire Summorv Risk Anolvsis ond Wildfire Resiliencv Cost Plon included o numbering system used to trock individuol Plan elements. For exomple, the Plon element designoted os "D-76/77 Distribution System Grld Hordening" is described on the next severol pages. That numbering system is mointoined throughout this report to ossist with continuity between vorious internol reports and datosets. 29 lPage May 28,2O2O WltDf lRF RtiSILIENCY PtAN D-1.6117 Distribution System Grid Hardening Recommendation: Attachment A Replace aging and obsolete equipment in elevated fire risk areas (40% System) Cost: Benefit: 523,000,00Olyear Capital Investment (5193,200,000 total over 10 years) Reduced fire events caused by Avista's electric distribution system. Distribution grid hardening represents the single largest infrastructure investment in this Plan. Pole fires, together with equipment failures, can potentially be reduced by replacing aging and deteriorated poles, equipment, and conductors. Though Avista has well-established programs to replace poles, conductor, and equipment, existing programs are condition-based and aligned with reliability objectives. Wildfire grid hardening objectives are focused on reducing the number of spark ignition events. The following activities are included in the distribution grid hardening plan: . Replace wood crossarms with fiberglass units o Remove small copper wire o lnstall wildlife guards (e.g. fuse holders, lightning arrestors, and transformer bushings) o Replace wood poles with steel poles at 'high value' locations (e.g. highway crossings, corner poles, and heavy equipment poles) o Eliminate open wire secondary districts o lnstall wedge/bail clamps at hot tap connection points Pole fires are a significant contributor to wildfire risk. Each year there are approximately 90 pole fires on Avista's distribution system, and the vast majority are related to wood on wood contact between crossarms and poles. The combinotion of wood poles with fiberglass crossorms rorely cause pole top fires. This is o proven tactic for reducing the risk of utility involved fires ond is o component of distribution grid hardening. 30 lPage May28,2O2O WILDFIRE RESITIENCY PtAN Attachment A Avista adopted the use of fiberglass crossarms in the early 2000's and has been replacing wood units steadily since that time. However, many wood crossarms remain on the system. By replacing wood crossarms in elevated fire risk areas, the number of pole fires can be significantly reduced. Of the grid hardening efforts listed above, this is the most cost effective treatment to reduce fire risk. The following table lists current outage rates for each treatment. The data is from the 20L4-20L8 operating period and reflects an annual rate. % of System OutagesOutage DriverMaterialUnit Annua! Outage Rate Wood Crossarms SmallCopper Wire Wildlife Guards Secondary Wire Districts Hot Tap Connection Source Pole Fires Primary Conductor Failures Animal related outages Secondary Conductor Failures Primary Connector Failures Totals Avisto OMS 2074-2018 92 81 557 101 1,087 t.5% L3% 9.Oo/o 1.6% L.L% L4.5% 69 Risk Evaluation: Distribution Grid Hardening lnherent Risk Exposure (category %) Managed Risk Exposure (category %) Risk Mitigation (average %l Total Capital lnvestment Benefit: 31 lP.,r5:e 39.3-94.5 0.3-1.9 98% Stgg million D-13 Additional Dry Land Mode Circuit Reclosers Recommendation: To install additional circuit reclosers in elevated fire threat areas (40% System) Cost:560O,OOO Capital lnvestment (55,400,000 total over 10 years) S44,4OO Operating lnvestment (5444,000 total over 10 years) Provide protection schemes that can adjusted for the wildfire threat based on the operating location. Midline circuit reclosers are often deployed on long distribution lines where substation-based equipment cannot adequately protect the entire length of the circuit. Urban distribution lines are typically 5 to 10 miles in length, while rural counterparts can extend hundreds of miles. As noted, Avista is evaluating its current dry land program and, although that work is on-going, there is consensus that additional equipment will help delineate elevated fire threat and non-WUl areas. lt is estimated that upwards of 75 modern reclosers will be installed on the system, which is approximately one additional t^vlt t)t lRl ttt !lt lt l'l( Y t,t At'l 2020-2029D-LGI L7 : Distribution Grid Hardening May 28,2020 Attachment A recloser for every two rural distribution circuits. The situation is illustrated on the following page where elevated fire threat areas exists near the end of a distribution line. Distribution Main Trunk Line Midline Clrcult R.clo6rr L - - - - -l By adding circuit reclosers at strategic locations, Avista Distribution Operations can re-task those devices during periods of elevated fire danger to operate in fire protection mode rather than reliability mode. A proposed scheme is illustrated in the block diagram below. fubst.tlon Orcult Rcdoecr lncreasing Fire Threat Conditions NON.WUI Avisto hos used o summer operoting strotegy or "Dry Lond Mode" since the eorly 2000's. Avisto onticipotes odopting DLM to fire threat conditions ond re- tosking circuit reclosers to align with field conditions. D-6 Dry Land Mode Effectiveness Study Recommendation: To conduct an engineering review of Avista's Dry [and Mode protection scheme (in-process since March 2O2Ol Costs: Benefit: S100,000 Operating Expense (2 year engineering review) More timely and responsive protection schemes that minimize fault energy and reduce the potentialto start a wildfire. During fire season, Avista operates a significant portion of the distribution system in what is referred to as Dry Land Mode (DLM). Electric circuits in DLM mode are operated with auto-reclosing and instantaneous overcurrent tripping disabled. ln this configuration, faults that occur on lateral circuits are 32 lPage WILDFIRE RESILIENCY PLAN Circuit Recloser added at this locationfor DLM i .'..ri, rl [: 'r' Fi :. ' lbllowHagWrmlry (Dl"ir+) May28,2O2O Attachment A cleared through fuse action while faults on trunk segments are cleared via circuit reclosers. During the Avista wildfire workshops, engineers agreed that the dry land operating system could be improved. A small work group was formed including several area engineers, the manager of protection engineering, and electric servicemen. The group is expected to issue recommendations prior to the 2O2O fire season. Most Avista circuit reclosers are configured with three automatic breaker trips and two reclose settings. Normal and DLM modes are illustrated below. Normal Configuration DtM The initial recloser trip is generated via instantaneous overcurrent relay and accounts for only 5-10% of total fault energy. The remaining recloser trips occur via time-delay relays and are coordinated with downstream fuse devices. lf the fault is located downstream of a fuse, the fuse will blow and isolate the faulted segment. However, if the fault is located on the main trunk line, the circuit recloser will go through the automatic trip-reclose sequence to a final open, or lock-out condition. As the illustration suggests, by limiting the circuit recloser to a single, time-delay trip, fault energy can potentially be reduced by up to 50%. 33 lPage May 28, 2020 WILDFIRE RESIlIENCY PLAN Attachment A D-B Dry Land Mode Trigger Recommendation: To develop a fire threat index to determine when Avista initiates Dry Land Mode (com , June 2019) ln 2019, Avista's TechnicalServices group created a system to gather information from the Wildland Fire Assessment System (WFAS)l8 and used that information to determine when the distribution system would be set to dry land conditions. The DLM "trigge(' was established as: 1) When 30% of Avista's Electric Operating area is designated as "High" fire threat, or 2l When 10% of the operating area is designated as "Very High" By providing a clear metric, Avista aligns its operations with fire threat conditions Costs: Benefit: lnherent Risk Exposure Managed Risk Exposure Risk Mitigation {average %} Total Operating Expense Total Capital lnvestment S2,OO0 operating Expense per year (520,000 over 10 years) System operations that are consistent with wildfire risk. The GIS Technical Services group creoted o f ire threot index mop for electric operations. this doily repott for )uly 18, 20L9 is shown for the north ond south operating areas. Areas indicoted with yellow, orange, ond red highlights ore ossocioted with Hiqh, Very High, and Extreme f ire danger. Doto Source. USFS/WFAS, Missoula Montona S43-G9.0 million 56.2-L7.4 million 83% Sss+,ooo Ss.+ million Risk Evaluation: Dry Land Mode Operating Program (D-6, D-8, and D-13) 18 Wildland Fire Assessment System (USFS), Missoula MT, wfas.net 34 ll',r1ro Wllt)f lR[ liFslllFt'l(Y []lAl'l trilo 6,. I t Dry Land Operating Program 2020-2029 May28,2O2O Attachment A ST-12 Transmission System Grid Hardening Recommendation: To convert wood poles to steel structures in elevated fire threat areas (20% System) Cost: Benefit: 35 lPage 55,000,0000 Capital lnvestment (544,000,000 tota! over 10 years ) Reduce the impact of wildfire on Avista's operating system. Avista began installing tubular steeltransmission poles in the late 1980's, with full adoption of steel as a standard material item in 2005. Since then, reconstruction projects have converted a number of circuits from wood to steel, and that trend will continue. Though Avista is committed to steel conversion, one of the objectives of the Wildfire Resiliency Plan is to accelerate that process in fire prone areas. The largest capital transmission investment in this Plan is wood to steel conversion, at a cost of S44 million dollars over a lO-year period. As noted, a significant risk to transmission lines is the impact from wildfires. OIl.tac.t f,gr r.l llrAl Avista's 230 kV system wos initially built in the lote 1950's ond eorly 1960's, ofter the construction of the Noxon Ropids and Cobinet Gorge doms. ln 2003, portions oJ the systenl were upgroded as port of the West ol Hatwoi ogreement with Bonneville Power. Severol wood lines were converted to steel during thot time period including: t w.rdd.b A SteelPole Be a co n - B o u ld e r - Rot h d r u m Be newo h-Shaw nee ( new I i ne ) Beacon-Bell #5 ,iffi ll*erlo lmtt tlrol Substation Wood Pole Avista 230 kV Transmission The overoge oge oJ tronsmission wood poles is 54 yeors (2020 dato).Itfird lft , bo Risk Evaluation: Transmission Grid Hardening (Wood to Steel Pole Conversion! ; tnherent Risk Exposure (catetory %l nla Managed Risk Exposure (category %) , n/a : Risk Mitigation (average %| :, n/a TotalCapitaltnvestment $++ million ta WItDIIRE RTSILIENCY PLAN fafiirt hH.t May 28, 2020 Attachment A ST-10 Transmission lnspection Program Recommendation: To conduct annual fire threat assessments of the transmission system Cost:5200,000 operating Expense (52,000,000 total over 10 years ) S300,000 Capital lnvestment (53,000,000 total over 10 years) ldentify and repair system defects prior to failure.Benefit: Malaged Rlsk Exposylg I Risk Mitigatlon {average %f Total Operating Expense i Total Capital tnvestment Visual inspection of assets is a fundamentaltenet of any preventative maintenance plan. This is a widely accepted process for generation power plants and electrical substations, but inspection of thousands of miles of powerlines presents unique challenges. Transmission Engineering has conducted annual aerial inspections for many years, and Avista will continue to leverage that experience. By identifying defects before they present as equipment failures, inspections help to minimize fire ignition events. While current programs are geared towards identifying reliability risk (e.g. Osprey nests, gunshot insulators, cracked crossarms, woodpecker damage, etc.), a wildfire based approach focuses attention on other factors: A. Logging or other construction activities near powerlines B. Excessive conductor sag over agricultural or roadway areas C. Corroded attachment hardware D. Disruptions or changes to the ground profile E. Unauthorized attachments or encroachments F. Thermal issues (e.g. hot splices or connectors) G. Wood debris slash piles in right of way This list is not intended to be a complete list, but rather to contrast the differences between conve ntiona I inspections based on reliability and those focused on preventing utility involved wildfires. Risk Evaluation: Transmission lnspection lnherent Rr--sk Exposure $+-sS m:tlion S1,1-2.6 million 94% Sz trltillion $g utllion 36 lPage lncreasingly, UAVs or Drones are being used to inspect powerlines. Avista plans to deploy this technology as part of Wildfire Resiliency. May 28, 2020 WILDFIRE RESIIIENCY PIAN Attachment A 5T-6 Transmission Wood Pole Fire Retardant Protection Recommendation: Wrap wood poles with a fire-resistant materia! Cost: Benefit: 5250,000 operating Expense (52,450,000 total over 10 years ) Protect wood poles in grassland areas from the impacts of fire. Fire damage to the Lolo-Oxbow 230 kV line in the early 2000's prompted Transmission Engineering to initiate a fire retardant (FR) wood pole painting program. Wood transmission structures are painted near ground line, which is an effective means of preventing damage caused by ground fires. Though Avista has experience with Osmose'Fireguard', the paint product must be reapplied every three to five years and the maintenance expense is on-going. Avista has participated in a number of peer utility forums including Western Energy lnstitute's Wildfire Task Force.le At that meeting, Southern California Edison (SCE) discussed their work with Genics Corporation to develop a wire mesh product that is chemically reactive to extreme heat. As of this writing, SCE has installed Fire-Mesh on over 1,300 poles and plans to fire wrap 20,000 more poles in 2020. Avista will adopt this program as part of their effort to protect transmission system wood poles from the impact of grassland fires. On Morch 3'd, 2020, Avisto conducted o field test of the Genics Fire-Mesh product. An FR wropped pole wos subjected to o 3)-minute fire ond sustoined only minor domage. Unlike FR paint, this mesh product does not require on-going maintenonce ond con be opplied much more eosily than paint. Risk Evaluation: Wood Pole Fire Retardant Protection i lnherent Risk Exposure , 59.5-28 million Managed Risk Exposure 54.34.8 million I Risk Mititation (average %| ' 76% Totaloperating Expense 52.45 Million le Western Energy lnstitute Wildfire Meeting July 19-20,2019, SDG&E 3TlPage WILDFIRE RESILIENCY PtAN May 28,2O2O En hanced Vegetation Management Vegetation management is an integral part of maintaining overhead electric distribution and transmission lines. Historically, utilities have trimmed and removed trees with a focus on improving reliability and reducing the frequency of outages. With the increasing threat of wildfires as a result of poor forest health, past fire suppression activities and periods of prolonged drought, Avista plans to enhance vegetation management practices especially in elevated fire threat areas. For the five year period from 2014 to 2018, there were nearly 2,000 tree related events on Avista's electric distribution network.2o Though tree induced fire outcomes are not specifically tracked, consensus among Avista operating personnel suggests that vegetation contacts with overhead powerlines represent a significant fire hazard. This is consistent with other utility risk assessments. Attachment A 2014 Windstorm Domoge North This Plan recommends the following enhanced vegetation management activities: o Transmission and distribution system digital data collection (LIDAR) o Fuel reduction partnerships o Widening transmission rights of way o Annual risk tree surveys o Review and support of the Right Tree, Right Place customer safety initiative The ten year cost forecast to implement a fire-informed, enhanced vegetation management program is approximately SSf mitlion dollars and willsupplement current maintenance activities. These wildfire specific vegetation management activities would be implemented in addition to, not in place ol the regular five-year vegetation management cycle to maintain system reliability. The forecast of risks and investments is summarized below. i lnherent Risk (range %| 48.3-100 Managed Risk (range %) 3.2-L4.5 , Risk Mitigation (average %) 88Yo TotalOperating Expense SS1.Z tvtillion TotatCapital tnvestment SS.l Million 20 Avista Outage Management System, 20L4-20t8 dataset 38 lPage WItDFIRE RESItItNCY PtAN May28,2O2O Attachment A D-10 Electric Distribution Annual Risk Tree Recommendation: To identify and remove dead, dying, and diseased trees, or 'risk trees' adjacent to distribution lines. (IOO% System) Cost: Benefit: ln order to identify 'at-risk' trees, Avista plans to use a combination of traditional, ground-based inspections and aerial digital data collection. By identifying trees that are dying or diseased, Avista can remove those trees that represent a fall-in risk to nearby powerlines. ln total, 40% of Avista's distribution system is located in elevated fire risk areas (see the WUI map on the following page). During the five year period between 2014 and 2018, 503 trees fell into electric distribution lines during the late spring and summer months (May-September). ln total, trees account for nearly 400 outages per year with fall-in events outnumbering grow-ins by nearly a 3 to 1 margin. ln short, most tree related outages are caused by trees located outside of the right-of-way falling into powerlines. And, vegetation contacts during periods of moderate to high winds represent a significant contributor to the fire risk profile. This is a combination that the Wildfire Resiliency Plan aims to mitigate. Forests face an increasing threat of insects, drought, and poor land management. A warming climate is contributing to these factors and there is general consensus among foresters that significant stem loss will occur over the next several decades. The 2017 USDA Forest Health report includes drought statistics that indicate wide-spread drought conditions from 39 lt'age 52,500,000 Operating Expense (525,500,000 total over 10 years ) Reduce interaction between vegetation and Avista's distribution facilities. Moisture dillerence z-srcote(MDZ) 1s-2 (erdreme drought) a--2- -1.5 (6evere drought) E.-t-5- -t (moderate drought) > -1- -o.5 (nild drotrgfrt) > -O.H).s (neer rrcrrnal)r@lG EA >o.5-1 (mild surplus) I >1-1.5 (moderab eurplus) I >1.5-+ (severe aurplusfI.2 (extreme eurpfus) @)Fotesledale.asrrz Ecoregion Eectbnboundary WITDFIRL RLSIIIFNTY PIAN May 28,2020 20 1 3- 20 17 P r e ci p itotion o J lnterfece A O G.: ,o E \ 0 -j o o' ?ii;lj I .i' t,r 6 Eo ( o;ftP..a- I.a 'f td,'& ao' o 1, I,'I-'t Attachment A 2015 to 2OL72r, with many areas rated as severe to extreme (see illustration). One might observe that this is only a 3-year period and not indicative of an underlying trend. However, data from the S-year period from 2013 to 2Ot7 indicates an even deeper drought, especia!!y throughout California and the desert southwest. Wildland Urban lnterface (WU l) Avista's WUI map indicates the potential for utility caused wildfires and their impact to homes and communities. lt also represents where treatment plans will be targeted. Elevated fire threat is noted as the Tier 2 (orange) and Tier 3 (red) areas and encompasses 40% of Avista's electric distribution system. Risk Evaluation The risk of trees falling into powerlines represents a significant financial cost, with the lO-year inherent risk estimated that exceeds SZ.g dollars. The risk and cost-benefit estimates are indicated below. tnherent Risk Exposure (category%l 2t.844.3 Managed Risk Exposure (category %) 1 Risk Mltlgation (average %l Total Operating Expense s25.5 Million 21 U.S. Department of Agriculture, fs.fed.us/foresthealth/publications/conditionsreport_2017.pdf 40 lPage WltDrlRE RESILIENCY PtAN 83% May28,2O2O Attachment A D-11 Public Safety lnitiative: "Right Tree, Right Place" Recommendation: To contact customers located in elevated fire threat areas and work with them to remove tall trees near (40% System). Cost: Benefit: 41 lPage S1,000,000 Operating Expense (59,500,000 total over 10 years ) Reduce interaction between vegetation and Avista's operating system. "Right Tree, Right Place" Avista currently supports an approach to vegetation management called "right tree, right place." Through this approach, Avista seeks to educate landowners about utility-compatible trees, and publishes a brochure, which states , "Avisto provides a no-cost inspection and mitigotion to make the following certoin tree-reloted situotions safe." The brochure includes a graphic (above) indicating that only Type l, low growing, trees should be planted near powerlines. ln the five year period trom20L4 to 2018, there were 322tree 'grow-in' incidents during the fire season (May-September). Like tree fall-ins, these incidents tend to happen during windy days and thus elevate the risk of starting and spreading a fire. From a wildfire resiliency perspective, there is opportunity to build on and reshape this program, which may include additional agency partnerships and public outreach, to minimize the fire-related risk presented by trees coming into contact with Avista's electric system. By partnering with fire agencies, such as Washington Department of Natural Resources and the ldaho Department of Lands, Avista can reach residents living in elevated fire threat areas and work with them WITDTIRL RLSILIEN(Y PIAN May 28,2020 Attachment A to remove incompatible trees. By incentivizing owners to remove tall growing trees, Avista can reduce the risk of fire and the need to trim trees in the futu re. It is recommended that a "right tree, right place" program be established similar to Avista's energy efficiency rebate program. lt would allow customers to submit a request and select from a list of qualified contractors. This would ease the burden on internal resources and encourage local tree trimmers to become line clearance certified. ln this Plan, the recommendation would focus on areas associated with elevated fire risk. An additional element of this program would be partnership with fire agencies, such as Washington Department of Natural Resources and the ldaho Department of Lands, and to work with agency partners to create fire-adapted communities. Risk Evaluation Trimming customer owned trees is a known dissatisfier. Customers sense a loss of control and perceive the activity as 'happening to them' rather than 'occurring for them'. By providing customers with a choice about removing trees, we promote a partnership focused on fire prevention rather than utility operations. lnherent Risk Exposure Managed Risk Exposure Risk Mitigation (average %) Total Operating Expense 42 lPage May28,2O2O S553-1,145 million 52.3-28.2 million 98% 59.5 Million WItDFIRE RFSII IEI'J( Y PI AN Type 7 low growing trees ore compotible with utility overheod powerlines ond pose little or no threot to their operotion. 2020-2029D-l1: Right Tree, Right Place Campaign Attachment A D-1,4 Distribution Digital Data Collection Recommendation: Annual digital surveys of the elevated fire threat areas. lncludes computer post processing (40% System). Cost: Benefit: This element is similar in scope and function to ST-5 "Transmission Digital Data Collection" whereby LIDAR surveys, high resolution photography, and infrared images would be collected on Avista's overhead distribution lines The project scope is limited to elevated fire threat areas. Avista operates 7,600 miles of overhead primary distribution lines, and nearly 40% of those facilities are located in elevated fire threat areas However, unlike transmission, distribution lines have lateral, branch circuits that make aerial surveys difficult. Ground based techniques, similar to Google Earth's Street View Project, may be deployed in combination with conventional and drone aircraft. 43 lPage S1,000,000 Operating Expense (57,750,000 total over 10 years ) ldentify conflicts between vegetation and system structural defects 10% 6.5% 3% 50% 30.5% Electric Distribution Outoge Rates (Events/Year) 600 Overheod Equiprnent Foilures 400 Tree Reloted 200 U nde rgro u nd E q ui pme nt 3,100 Wind & Weather 1,890 Other Sources (Source dato: Avisto outage ntonogentent systenl 2014 2018) Avista maintains distribution vegetation on a five year cycle, or about 20% of the system per year. This includes trimming trees and removing trees. This is a reliability-based approach generally known as 'routine maintenance'. By deploying annual digita! inspections, Avista willtransition towards a more 'risk-informed' approach combining elements of fire threat risk (i.e. WUI Map and lnfrastructure Health lndex) with the volume of vegetation and the proximity to energized lines and equipment. Though this treatment is justified solely on its ability to identify potential vegetation conflicts, high resolution photography and infrared imagery also support structural inspections. A number of use cases have been identified. wIDliRf titjsiltFNCY t,tn t! May 28,2O2O lnherent Risk Exposure (category %) Managed Risk Exposure (category %) Risk Mitigation (average %) Total Operating Expense Attachment A LIDAR USE CASES: . VegetationVolume & Proximity (Grown-in Risk). DangerTree(Fall-inRisk). RAItt Encroachment (buildings, roads, utilities). Joint Use lnventory(billing). Conductor tine Clearance (NESCViolations) IMAGERY USE CA5E5: . Equipment Damage (broken x-arms, leaking transformen). Change Detection (open fuse bank, blrd nest, attachment). Hot Spot Detection (spllces, connecton, insulators). Equipment Inventory (added to GIS system of record) 21.8-44.3 L.O-4.4 92% Sz.zs tvtitlion LIDAR Survey Hi Res Photo lnfrared lmage Risk Evaluation Annual risk tree and digital data collection rank at the top of treatment options to reduce the opportunity for powerline fire ignitions. Maintaining an accurate inventory of both infrastructure and vegetation in the elevated fire threat areas is a critical component of fire resiliency. 441 D-14: Distribution Digital Oata Collection 2020-2029 May 28,2020 Attachment A ST-5 Transmission System Digital Data Collection Recommendation: Annual digital survey of the transmission system (LOO%I Cost: Benefit: 5750,000 Operating Expense (56,825,000 total over 10 years ) ldentify potential conflicts with vegetation and structure defects. Avista operates 700 miles of 230 kV and 1,570 miles of 115 kV transmission lines throughout eastern Washington, northern ldaho, and western Montana.22 Vegetation management of the transmission grid is subject to NERC regu lation FAC-003-4 which requires that all 230 kV and select 115 kV circuits be patrolled annually to assess vegetation growth both in the right-of-way (encroachment) and adjacent to the right-of-way (fall-in risk). Since 2006, Avista has conducted annual aerial patrols as part of the Compa ny's Tra nsmission Vegetation Management Plan (WMP).23 The regulatory focus on transmission has helped reduce conflicts between vegetation and powerlines, and adding fire-informed, risk-based elements to existing programs, Wildfire Resiliency aims to build upon that success. lncreasingly, utilities are using LIDAR (light detection and ranging) to assess vegetation encroachment of overhead powerlines. The ability to collect survey data via an aerial platform is a significant advantage over ground-based techniques. This technology is helping vegetation managers identify, prescribe treatments, and audit field work using machine learning computer algorithms. Since transmission lines are linear features and located within established corridors, data can be collected via fixed wing aircraft equipped with multiple instruments including LIDAR, Hi-Resolution cameras, and near-infrared detectors. By collecting data annually, Avista vegetation and asset managers can detect changes from year to year, including unauthorized encroachments, as well as assess the proximity to vegetation, and quantify the risk of tree fall-ins. Transitioning from human based inspections to digital data collection will have a substantial impact on data accuracy, work processes, productivity, and record keeping. 22 2019 Avista Quick Facts 23 Avista Transmission Vegetation Management Plan, see Addendum 45 lt'age WltDtlRl ttL!ltltN(Y t'l/rN May 28,2020 Attachment A Risk Evaluation The relatively low risk of contact between vegetation and transmission lines reflects Avista's commitment to comply with NERC regulation FAC 003-4. Between 2014 and 2018, only 21 tree related outages were reported on the transmission system.2a Though collecting digital data will improve our ability to identify both tree grow-in and fall-in risks, benefits extend beyond vegetation management and include the ability to automate the structure inspections, detect thermal hot-spots, and conduct field work audits. lnherent Risk (Sl Managed Risk ($l Risk Mitigation (average %| Total Operating Expense Cost: Benefit: ST-9 ConformingTransmission Rights-of-Way Recommendation: Widen transmission line rights-of-way in elevated fire risk areas (20% System) S9.5 - S17.7 Million s0.9 - s2.4 Million 88% 56.8 Million 5500,000 Capital lnvestment (55,000,000 total over 10 years ) Reduce interaction between vegetation and Avista's transmission facilities. Typically, transmission line corridors are established via negotiations with private landowners and include a centerline description and specify width (e.9. 50-100 feet wide). Avista transmission lines have standard width requirements: o 230 kV- 100 feet o 115 kV H-frame (2 pole)- 50 feet r 115 kV single pole - 50 feet Although, variations exist in particular circumstances, standard corridor widths provide sufficient clearance between conductors and adjacent vegetation. However, some historic transmission line easements do not meet today's standards and elevate the risk of vegetation contacts. Likewise, transmission circuits located in public road rights-of-way do not necessarily allow Avista to manage vegetation on adjacent properties. CDA-Rothdrum 115 kV along US Hwy 95 The photograph on the right shows a 115 kV line routed along US Highway 95 near Hayden, ldaho. Trees located on the adjacent property cannot be managed without 2a Avista Outage Management System, 20L4-20L8 dataset 46 lPage WltDilRF IrESltltt.I (Y PIAN ST-5: Transmission Digital Data Collection 2020-2029 May 28,202O Attachment A owner consent. By addressing these areas through easement acquisition, Avista reduces vegetation risks. Risk Evaluation At the time of this report, Avista has not conducted a complete inventory of corridor agreements. lt is important to note that easements obtained prior to 1950 are generally 'non-width specific'. Although courts have interpreted these easements as conforming to current standards, the risk of disputes with adjacent landowners still exist. Likewise, circuits located on public road rights-of-way do not allow for vegetation management on adjacent properties. While the cost-benefit ratio for this activity is relatively low, benefit calculations from the fire risk workshops did not take into account the ability to maintain and reconstruct facilities. Expanding corridor 'rights' drives benefits that go beyond the risk of wildfire. lnherent Risk Exposure Managed Risk Exposure Risk Mitigation (average %! Total Capital lnvestment Cost: Benefit: S4.8 - S8.8 Million So.2 - S1.4 Mittion 88% Ss lvtillion S167,000 Operating Expense (S1,500,000 total Reduce fuel loading near operating facilities an relationships with fire first responders. ducted by the local Fire over 9 years ) d strengthen working ST-7 Fuel Reduction Partnerships Recommendation: Participate in annual fuel reduction efforts con Districts (9,9, w-gshinsol DN!, tda!9 !oL) The Washington Department of Natural Resources (DNR) has embarked on a 2O-year plan to improve forest health on 2.7 million acres of forest land in central and eastern Washington. As Hilary Franz, Washington Commissioner of Public Lands, states: "We hove a lorest health crisis in our stote....... Hot, dry conditions coupled with diseosed and dying forests ore leading to explosive wildfires.'as ln 2077, a record number of wildfires (1,850) cost Washington taxpayers over StSO million in suppression costs alone. Since 1970, both the number and size of wildfires has increased substantially. The United States Forest Service (USFS) estimates that large fires have tripled in number since 1970 and the lengh of the wildfire season is now 100 days longer.26 2s lnternet Website: dnr.wa.gov 26 Climate Central, Western Wildfires, 2016 47 ll',rr.t, \ryltI)IIRF ti[Sllltl"] (Y I'lAl'J 2020-2029ST-9: Conforming Transmission Rights-of-Way May 28, 2020 Attachment A By partnering directly with fire protection agencies including the Washington Department of Natural Resources and the ldaho Department of Lands, Avista plans to work alongside forest thinning and brushing crews to remove excess fuels and to reduce the severity of future fires. Projects that remove fuels near critical infrastructure such as the Beacon Hill area (see photograph) are an opportunity to both reduce fire risk and to strengthen relationships between Avista and fire protection personnel. Over the course of Plan development, Avista has met with several fire protection agencies and a building ond threotened severol tronsmission circuits. Residents recurring theme has emerged : lt is importont were evacuoted os the fire spreod to over 7(D acres. over 50 thot Avisto operoting personnel maintain strong fire engines responded to the bloze' working relationships with locol ond state fire agencies. This Plan contains opportunities to strengthen those relationships through joint training and simulation exercises, joint efforts to promote fire-adapted communities, and through fuel reduction projects. The following graph illustrates the correlation between hotter summers and large fires on federal lands. Hotter Years Typican[ Have I'lore Large Fires neor moin IN IDAHO, THE NUMBER OF LARGE FIRES ON FEDERAT LANDS HAS INCREASED FROM 10 (1970) TO OVER 30 PER YEAR. IN 2009, OVER 1.5 MILLION ACRES OF FEDERAL LANDS WERE IMPACTED BY WITDFIRES IN IDAHO Av.ro ge Sprlrrg/Sutiltlor ianrpentrrer trFl LrgoFln:sorr hrartSarvie Lard I B !,,I s $ 43lPage .trrtmd l^rprhrrnxtffitollmtffi !6rilCgltffi !.rr!ellrltlodnliclM CinrnarrqFaclul F rnrs.#hodtficrl :!r r r:! fll) c sir lx While Federal and State efforts to improve forest health involve widespread thinning and prescribed burns, Avista's approach will target areas adjacent to critical infrastructure and be performed in conjunction with localfire districts. Recent work with local fire districts, together with the ldaho Department of Lands and Washington DNR, have already identified several potential projects. WILDFIRE RESIIIINCY PIAN May28,2O2O Attachment A Risk Evaluation While Avista cannot reasonably marshal resources to impact forest health on a landscape level, it can support local efforts to conduct mechanicalthinning and prescribed burns. Avista plans to invest S150,000 annually to assist with local efforts to reduce fuel loading. D-4 lncorporating Vegetation [Vanagement into Distribution Designs Recommendation: lncorporate vegetation clearing into distribution design packages (addition to work process) lnherent Risk Exposure Managed Risk Exposure Risk Mitigation (average %) Total Operating Expense Cost: Benefit: lnherent Risk Exposure Managed Risk Exposure Risk Mitigation {average %} Total Capital lnvestment 49 lt'a5t, S15 - S29 Minion 53 - S29 Million 27Yo St.s tvtillion S10,000 capital labor ($100,000 total over 10 years ) Reduce interaction of vegetation with Avista's distribution facilities S20 - S278 Million S1o - S21 Million 9O%o Sloo,ooo During the Avista Wildfire Risk Workshops, participants cited examples of electric distribution designs in conflict with existing vegetation. By incorporating vegetation treatment into the design process, potential conflicts are addressed prior to construction. This is largely a training exercise for the Construction Project Coordinator (CPC) department, but does add to the overall design effort and requires coordination between construction and vegetation management functions. Risk Evaluation \^/lt tll lut l{[ 5il ll l"i( Y t'l Al.J ST-7: Fuel Reduction Partnerships 2020-2029 D-4: !ncorporating Vegetation ManaBement into Distribution Designs 2020-2029 May 28,2020 Attachment A Situational Awareness The ability to monitor and control electric transmission and distrlbution equipment is critical when responding to wildfires. This effort will leverage existing systems including Transmission SCADA (supervisory control and data acquisition), Distribution DMS (distribution management system), and AMI (automated meter infrastructure or "smart meters"). These systems are known technologies and offer scalable opportunities to enhance wildfire resiliency. ln addition to leveraging existing systems, Avista will develop a "Fire-Weathe/' dashboard, combining elements of weather forecasting and fire threat assessment. This computerized system will help system operators, district managers, and area engineers make informed decisions related to fire risk potential and estimated fire impact spread & severity. Avista's Wildfire situational awareness plan consists of three elements: r Fire-WeatherDashboard o Substation Supervisory Control & Data Acquisition (SCADA) r Distribution MidlineEquipmentCommunications The lO-year cost to fully implement these treatments is S19 million dollars and may mitigate the current state categorical risk by as much as 98o/o. A summary forecast of costs and risks are shown below. lnherent Risk Exposure Managed Risk Exposure Risk Mitigation (average %f Operating Expense 2O2O -VlO29 I Capitat lnYestment 2O2O-2O29 50 lPage May28,2O2O 151 -Million 55 - 57 Million 98% ii Mtttion St8 uillion WILDFIRI RESILIENCY PLAN Midline CommunicationsSubstation SCADAFire-Weather Dashboard 2020-2029Situational Awareness Attachment A D-L5 Substation SCADA Recommendation: To retrofit supervisory contro! and data acquisition systems (SCADA) into elevated fire risk area substations (40% Distribution System). Cost:52,000,000 Capital lnvestment (517,000,000 tota! over 10 years) 59,700 Operating Expense (597,000 total over 10 years) Provide ability to adjust protection equipment based on the imminent fire risk and weather conditions. 33 Avistd Substotions are not currently equipped with control and monitoring systems (SCADA) Benefit: Supervisory Control and Data Acquisition systems or SCADA, are used in many industries to monitor and control manufacturing plants, national defense systems, and utility inf rastructu re, including generation plant a nd transmission circuit infrastructure. These systems, originally deployed in the late 1950's and early L97O's, have matured to current 'fou rth generation' web-based systems. Avista operates approximately 175 substations, ranging from very large, 500 MVA 230-115 kV transmission stations, to small, rural distribution stations. While Avista's transmission system is fully SCADA integrated, a number of distribution stations are not eouiooed with remote monitoring and control svstems. A majority of these rural stations are located in elevated fire risk areas. Avista operates 33 substations without SCADA. These stations are effectively'darK, without any remote sensing, monitoring, or equipment control systems. Though substations are designed to operate autonomously, the inability to adjust protection systems based on weather conditions or de-energize electrical circuits in an emergency elevates the safety risk for emergency first responders. One of the elements of Avista's strategy is to align circuit protection schemes with fire threat conditions (see Dry Land Mode). During the fire season, Avista operates a number of distribution lines in non- reclosing mode, which reduces fault energy by 40-50%. However, weather forecasts that indicate high temperatures and high winds may warrant a more sensitive protection regime, such as TripReclose-Trip, where circuit reclosers rely on instantaneous rather than time-delay tripping. This could reduce fault energy by as much as 70-80%. By adding SCADA, system operators can issue instructions to recloser units and effect changes. Without these systems, servicemen must be dispatched to the substations to manually effect the 51 lPage l ) l , l l Lt r. t t r,' l Ctttt.l I r:,,.'i rr,,,,i: ,i. \/c 1,r,1, {lr',-tIL.ii>t, i r,:l fr rr^.r'l ,;1ir':r',tr :lf i','\/.i) 1 I 5 l.\,', lt.ll]\trt r'til)rl Cirr. lr t May28,2O2O WILDFIRE RESILIENCY PLAN Attachment A change. ln a dynamic system, manual intervention is not practical and may lead to prolonged customer outages and elevated risk. Circuit Recloser Relays Modern circuit reclosers are controlled via microprocessor relays. ln this photograph, a Schweitzer SEL-351R relay is being tested prior to installation Equipment connected to commu nication systems (SCADA & DMS)are continuously monitored and capable of remote operation. This functionality is an important element in Avista's wildfire strategy. Risk Evaluation Avista plans to install SCADA at 33 substations based on their location within the Wildland Urban lnterface. Elevated fire threat areas (Tier 2/3) would be prioritized over non-WUl and WUI Tier 1 areas. Inheren! Risk Exposure Managed Risk Exposure Risk Mitigation (average %| To-ta! Operating Expense Total Capital lnvestment 52 lPage May 28, 2020 s132 -7 Million 100% 5sz,ooo Stz vtitlion So - S1.G Million D-15: Substation SCADA 2020-2029 WIIDFIRF RESILIENCY PtAN Attachment A D-12 Distribution Management System (DMS) Communication Recommendation: To retrofit circuit reclosers with communication systems and enable control and monitoring of equipment in elevated fire threat areas (40% System) Cost:560,000 Capital lnvestment (5540,000 total over 10 years ) 530,000 Operating Expense ISZIZ,OOO total over 10 years) Extending communications for circuit reclosers enables remote operation, and allows operators to align protection schemes with current fire threat conditions Benefit: As part of the 2010 Spokane and Pullman Smart Grid projects, Avista installed a Distribution Management System, or DMS, to collect data from circuit reclosers, voltage regulators, and capacitor banks. DMS is similar to SCADA, but is specific to distribution and can collect data from both substation and powerline devices. However, a number of circuit reclosers located in elevated fire risk areas lack communications and are not included in the DMS system. Extending communications to these devices is like the SCADA initiative and willenable remote monitoring and control of these devices. tused lateral Clrcults M.ln llunk (No Fus6l Sub6ladon Orcult Rcclosrr (scADAl 53 lPage E me rge ncy fi rst responde rs rely on Avista's ability to de- energize electric lines near wildfires i I I I L Eledric Distribution Line Proteaion Avisto operotes 7,600 miles of overheod distribution line ond 40% of thot system is locoted in elevoted fire risk areos. This diogram indicotes o typicol distribution configurotion, with o moin tunk protected vio circuit reclosers (substotion ond midline) ond loterol circuits protected vio fuse links. Circuit reclosers are similor to household breakers ond operote (open) when foult overcurrent is detected. Foults thot occur on loterol circuits ore interrupted when o fuse link opens (thermol operation). By odding communications to midline circuit reclosers, Avisto odds monitoring ond controlfunctionolity, including the obility to operote the device remotely. May 28,2O2O WITDIIRE RESITIENCY PLAN Attachment A Fuse Link Assembly Cutout Midline Circuit Recloser Risk Evaluation Extending communications to circuit reclosers enables remote operation and allows operators to adapt protection schemes to align with current fire threat conditions. For example, Avista may install Hot Line Holds (one shot tripping, no automatic reclose) during red flag warnings. Reducing the potential for spark ignition is an important component of Avista's strategy and adapting system protection to fire threat conditions helps to achieve those goals. lnherent Risk Exposure S14.6 - $29 Miltion Managed Risk Expos_91e , nisk trltitigation (avcrage %l Total Operating Expense Total Capital lnvestment s250,000 - 28o,ooo '99% i)tz,ooo , $sao,boo 54 lPage 2020-2029D-12: DMS Communications May 28, 2020 WITDFIRI RESILIENCY PIAN Cost: Benefit: Attachment A ST-2 Fire-WeatherDashboard Recommendation: Combine weather forecast and fire threat data into a fire predictive, web-based ram. S150,000 Capital lnvestment (5425,000 tota! over 3 years ) 575,000 Operating Expense (56SO,OOo total over 10 years) Better understand and respond to the potential impact of weather conditions on Avista's operating system. Avisto System Operations declared "Dry Land Operoting Conditions" on luly 23, 2019 based on data from the Wildlond Fire Assessment System (WFAS). The Wildland Fire Assessment System (WFAS) operated by the USFS in Missoula, Montana, provides near realtime information on fire threat conditions. This information is an important tool in determining both the probability and impact of wildfires. The precision of weather forecasting and, especially, micro climate forecasting, has significantly improved over the last few decades. Advancements in forecasting, coupled with broadband communication has made weather information more available than ever before. Prevailing weather conditions, including temperature, humidity, and especially wind, are key factors in fire behavior. By combining fire threat information with forecasted weather, system planners, operators, and field personnel are better equipped to predict and respond to wildfires. Doto from the Notional Weother Service for Post Falls, ldsho (3/3/20). Te mpe ratu re, h u mid ity, and wind levels ore important foctors in predicting wildfires. 55!Page WITDFIRE RESILIENCY PLAN May 28,2O2O Attachment A By combining information from the Wildland Fire Assessment System (WFAS) and the National Weather Service (NWS), Avista will be able to quantify fire risk by service territory. An example is shown below. At the time of this report, o detoiled scoping of the "Fire-Weother Dashboord" is not yet complete. 96 hourJuly 16, 2020 48 Hour Service Area Sandpoint i CDA Kellogg St. Maries Lewiston Grangeville Deer Park Spokane othello Davenport Pullman Temp FO Hi/Lo 821s4 86/s8 8o/so 82lso 92168 8s/50 B8is8 821s4 861s4 88162 8s/s5 78lSs Wind mph Gust/Sust L2/4 L6ls L2ls t4l4 28l1it 35rrL5 812 612 4i2 1212 8/4 22114 Fire lndex DLM NOM NOM NOM NOM NOM TRT NOM NOM NOM NOM NOM NOM Temp HilLo esl78 LOL(82 s2/68 9sl66 Lt2l8s LO8l76 L02/80 s817s 99/74 LOO178 96176 ssl6s Wind Gust/Sust s2122 6214s s1-.l20 32lts L2ls 8/4 1616 tzl6 t6le sl2 612 1218 Fire lndex DLM I!EC EC EC E H H H H H M M H M M H H H E M L M M M H TRT NOM NOM NOM NOM NOM NOM NOM NOM Legend: Fire lndex (Low, Moderate, High, Extreme, Extreme Cotostrophic) Dry Lond Mode (Nominal, Trip-Reclose-Trip, Hot-Line-Hold) This is illustration indicates how fire threat indicators might be combined with weather forecasts to influence Avista's operating systems, such as Dry Land Mode. Other activities, including EOP pre- activation and staging first responders, may also be informed through this system. Risk Evaluation Developing a fire-weather dashboard will not reduce fire risk on a standalone basis, however, this information is vital to adapting operations and emergency response to the potential for wildfire. lnherent Risk Exposure Managed Risk Exposure Risk Mitigation (average %l Total Operating Expense Total Capita! lnvestment 55 lr'.r ;t' May 28,2020 S+.9 - S8.8 Million 54.3 - S4.8 Million 33% s650,000 s425,ooo \'v-ll frt lt{f t{i Sll lt n( Y PI Al\j 2020-2029ST-2: Fire-Weather Dashboard I Attachment A Operations & Emergency Response The primary objective of Wildfire Resiliency is to reduce the number of utility involved ignition events and to minimize the damage of infrastructure due to wildfires. The bulk of that effort is rooted in long- term planning and implementation of methods to clear vegetation away from powerlines and to protect infrastructure from fire damage. Meeting these objectives requires a steadfast and committed approach to investing in the energy delivery system. Wildfires will continue to occur, and Wildfire Resiliency includes support elements such as first responder training, defining the role of engineering during major events, and establishing wildfire metrics. Historically, Avista's response to wildfire has been similar to other large scale weather events, with a focus towards outage service restoration. Though major storms present employee and public safety challenges, wildfire is particularly acute with respect to safety. ln addition to mitigating the risk of wildfire, Avista plans to: 1. Prioritize public and worker safety over customer restoration. 2. Recognize wildfire response as a shared responsibility with other emergency first responders. 3. Use performance metrics to adjust and align planned future actions. Plan elements in this category include: o Emergency Operating Program (EOP) document review & fire incident command representativeo Transmission design review of major events o Wildfire performance metricso Emergency first responder training . Expedited fire response (2020 pilot project) o Comprehensive fuse coordination review o Circuit recloser event reportingo Fire ignition tracking system o Fire suppression chemical additive o Wildland urban interface layer in Avista's GIS data systemo ARCOS system wildfire notification operating procedure The cost to align operating tactics with Wildfire Resiliency is S2.7 million over 10 years. However, this is projected to reduce risk exposure by several hundred million dollars. lnherent Risk Exposure (category %) Managed Risk Exposure (category %) Risk Mitigation (average %l Total Operating Expense Total Capita! lnvestment 57 lPage: 19.7-to0 5.3-23.4 76% s2,379,000 S3oo,ooo Wll llllRt Ht 5ll lE l!( Y I't /iN Operations & Emergency Response 2020-2029 May28,2O2O Attachment A Tronsmission & System Operotions Recommendation: ST-1 Formalize EOP response to large scale wildfire events ST- 3 Transmission engineering review after major events ST-4 Establish wildfire resiliency metrics 5T-8 Conduct annual fire safety and electrical hazard training ST-11 Expedited fire district response following transmission line faults Cost:S160,000 Operating expense (S1,593,000 total over 10 years) S10,000 Capital investment (S100,000 total over 10 years) Enhanced awareness and response to wildfire events. Five treatments are described in this section which encompass the overall energy delivery operating environment. Those elements include: o Emergency Operating Program Review & Fire lncident Command Representative o Transmission Design Review of Major Eventso Wildfire Performance Metrics o Emergency First Responder Training o Expedited Fire Response (2020 Pilot Project) Benefit: 58 lPa1re May28,2O2O ST-1 Emergency Operating Program (EOP) Since 2014, Avista has activated the electric EOP, or incident command structure, 15 times, including the Company's largest event, the windstorm in November of 2015. By declaring an EOP, Avista operations shifts to emergency response, with service restoration as the primary objective. Avista Electric EOP 201,4-20L9 Wildfires present a number of safety related challenges. ln August of 2015, Avista activated an EOP in response to numerous wildfires across the service territory. The largest of these fires was the Carpenter Road Fire near Davenport, Washington which impacted 54,000 acres and involved over 1,000 firefighters. Evacuation orders were issued for residents throughout the Springdale- Hunters area and approximately 42 structures were wildfire wind Event snow storm safety damaged or destroyed by the blaze. Though Avista has a long history of responding to wildfire events, it recognizes wildfire as separate and distinct from storm events. Therefore, Avista plans to implement the following changes to its EOP program: 1. Conduct an EOP document review to align with Wildfire Resiliency 2. Formalize resource commitments to Fire lncident Command (Avista Fire Representative) \lttr)F tt{[ tiE5rL tIN( Y Pt Ahl Attachment A ln most large wildfire situations, local response (city, county) is superseded by state and federal authorities. ln Washington State, the Department of Natural Resources is responsible for most non- federal fire suppression, and in ldaho, the Department of Lands takes the lead. ln either state, responses to fires larger than 100 acres triggers a Fire lncident Command Structure (lCS). While Avista has a long history of working closely with fire protection agencies, divisional operations managers have committed to embed Avista field personnel into the Fire lCS. A basic flow-process diagram is indicated below. The primary duty of the Avista representative is to serve as the liaison between the fire lncident Commander and Avista. Embedding Avisto Personnel into Fire lncident Commond Structure ST-3 Transmission Design's Role in Major Event Response The reconstruction cost of overhead transmission lines ranges from 5500,000 to over $t million dollars per mile. This is in sharp contrast to electric distribution facilities which typically range from $150,000 - 5250,000 per mile in rural areas. During the wildfire workshops, engineers and system operators estimated that wildfires impact transmission lines 2 to 4 times per year. Though electric operations is responsible for restoration, during large scale events, transmission design shall be consulted to conduct damage assessments prior to reconstruction. Minima Structure Damage Customers without power Safety lssue (e.g. highway crossing) lsolated Event 59 lPase lnitial Check- ln with Fire lC Attends Daily ICS Briefing(s) Liason between Fire ICS and AvistaManager Oamagq d.nq8ps to orandthlrdProperty party M{orEvent Transmission Design Consulted Prior to Reconstruction May 28,2O2O WII. DFIRT RESIIITNCY T'LAN Attachment A ST-4 Wildfire Program Metrics Electric reliability is determined through a series of metrics established by the lnstitute of Electrical and Electronics Engineers (IEEE), and includes outage frequency and duration. lndices such as MAIFI (momentary outage frequency), SAIDI (sustained outage duration), and CEMI (customers experiencing multiple interruptions) are commonplace throughout the industry. ln contrast, fire metrics are characterized as the number of acres burned, suppression costs, structures damaged, and injuries. Though Avista does track some fire-related information, such as the number of pole fires, it does not have a systematic approach to quantifli the effectiveness of wildfire resiliency measures. It is recommended that Avista implement a set of performance measures to quantify and better understand the risk of wildfire on operating systems. The performance measures should allow for evaluation and continuous improvement. The Plan-Do{heck-Act modelis a continuous improvement technique also known as the Deming Circle or Shewhart Cycle. Establishing wildfire metrics partially fulfills the 'Check' component and drives adjustments to Plan strategies and tactics. Though the Plan must adapt to ever-changing climatic, social, and political influences, the objectives are clear: Emergency Readiness, Public Safety, and Financial Protection. t PLAN DO T ACT CH ECK I €= ST-8 Wildfire Training for Avista First Responders Avista electric operations employees are located in 12 districts ranging from Colville to Grangeville and from Kellogg to Othello. Avista employs over 550 electric line workers who are trained as emergency first responders. As part of this Plan, divisional managers are responsible for conducting basic fire training at one of their monthly safety meetings. Where feasible, managers would involve a fire agency professional to conduct training in the April-May timeframe prior to start of fire season. Though there is consensus among division managers that Avista first responders should have basic firefighting and fire safety training, a core tenant of this Plan is to promote and strengthen relationships with fire agencies. By conducting joint training and emergency response simulations, Avista plans to support those key relationships. 60 lPag,e May 28,2020 WIIDTIRI 11 tSItIEhI CY PIAN Attachment A ST-9 Expedited Fire Response It is recommended that Avista implement expedited response for potential fire related disturbances on the transmission system. Avista's outage management system (OMS) is used to track electric events on both the transmission and distribution networks. As noted, sustained distribution outages are 50 times more prevalent than transmission events. However, 80% of transmission events are characterized as momentary and generally involve the automatic reclosing of circuit breakers to restore power. Though distribution line faults may cause spark ignitions, distribution events generally involve Avista crew response. However, if a transmission line successfully trips and then recloses, no Avista response is triggered. During the development of this Plan, Avista engaged fire agency professionals, including Washington DNR and ldaho lDL, together with Spokane County Fire Districts. lt was through these conversations that the concept of Exoedited Fire Response was developed. During dry land mode operations, Avista System Operator will initiate a 911 call whenever there is an isolated transmission fault. Subsequently, fire fighters will be dispatched to the scene. At the time of this report, a Memorandum of Understanding (MOU) is under review with Spokane County Fire to conduct a 'pilot project' during the 2020 fire season. For purposes of the pilot, the program will extend only to the Spokane County boundaries, and will align with Avista's seasonal declaration of Dry Land Conditions (typical July-September). Risk Evaluation The following table summarizes the risks and estimated 10-year costs associated with the transmission system elements of wildfire operations and emergency response. lnherent Risk Managed Risk Risk Capital Operating ($ Millions) (S Millions) Mitigation (%) lnvestment (S) Expense ($) S13.Gs S13.G5 o Sso,ooos3.95 s1.65 58o/o SIOO,OOO EOP & Fire lCS Engineering Design Review Wildfire Metrics First Responder Training Expedited Response Total 61 lPage May 28,2O2O Srg.a s2.0s Not evaluated $33.sM s2.4s So.e $18.3M 82o/o 71% 7S%$loo,ooo 5150,000 S1,3oo,ooo s93,ooo $1,s93,000 Wltt)t lRt RtSll IEN(Y PtAN Attachment A E lectric Distri b utio n O pe rotio n s Recommendation:D-1 Conduct annual distribution fuse coordination assessment D-2 Evaluate circuit recloser event data to ensure nominal operation D-3 Track the number of powerline caused fire ignitions D-5 Add chemicaladditives to field crew'water cans' D-7 Deploy the Wildland Urban lnterface data-set to the GIS system D-9 Use ARCOS to notify key personnel in the event of wildfire Six elements are included in this section: o Fuse Coordination Study o Circuit Recloser Event Reporting o Fire lgnition Tracking System r Fire Suppression Water Additive o WUI Layer in Avista GIS o ARCOS Wildfire Notification System As noted, electric distribution facilities account for 5,200 unplanned outages per year with a number of these events occurring during the fire season. Though the bulk of distribution risk reduction is associated with enhanced vegetation management and grid hardening, those treatments occur on a long term planning horizon. Elements described in this section inform the near-term operating horizon. Cost: Benefit: D-1 Fuse Coordination Study It is recommenced that Avista ensure proper fuse sizing and coordination on an annual basis. Fuses are an important element in the protection of electric distribution systems. Avista's distribution system is configured as a trunk and lateral system, with lateral circuits protected via fuse links and trunk lines protected via circuit reclosers. Avista's Area Engineers are accountable for ensuring that fuse sizes and types operate in a coordinated fashion. ln simple terms, fuses closest to loads are smallest with increasing fuse size towards the trunk connection (see illustration). 570,000 Capita! lnvestment (SZOO,OOO total over 3 years ) 578,500 Operating expense (Sz8S,OOO total over 10 years) Enhanced distribution operations and fire response. upstream 40T Fuse 15T Fuse 6K Fuse Downstream 62 lPage May28,2020 WILDFIRE RESILIENCY PIAN Attachment A D-2 Circuit Recloser Event Reporting It is recommended to analyze recloser event reports to determine that protection systems are operating nominally. Protection Engineering keeps a log of all transmission line circuit breaker operations and ensures that devices and relays are operating nominally. As communication systems become available to distribution devices, so does the ability to remotely access data from circuit reclosers. To ensure that reclosers are operating nominally and are coordinated with downstream fuse links, it is imperative that system events be analyzed by technical staff. D-3 Fire lgnition Tracking System It is recommended to implement a fire ignition tracking system to better understand and respond to fire events. As noted, Avista's Outage Management System (OMS) is used to track electric outages, and includes information such as: tree fall-ins, car hit poles, wind, animal, underground cable, overhead equipment, and etc. Fire is listed as an outage category, but generally relates to structure fires. Also listed is Pole Fire, which occurs when excessive electricaltracking leads to hot-spots between wood crossarms and poles. However, the OMS system does not include provisions for tracking outcomes beyond direct customer impacts (e.g. customer duration without power). Though still in development, Avista plans to extend mobile data collection devices (e.g. tablet computers) to field first responders. This would replace paper products, including Avista's damage response form. ln order to determine if Wildfire Resiliency treatments are effective, it is important that utility involved fires are tracked by first responders. rl lJtility gr ocle toblet ccnrpLtters ore beinq deployed to c <tndLtc t rlontoge assessmenl artd to docuntent t'ield reptoirs I ltis collection process tuill include prctt,isiort to captLtre fire igniliort evenls 63 lPr6rr'\VIl t)l lRl t(t \ll lt N( Y t't /rlJ May28,2O2O Attachment A D-5 Fire Suppression Water Additive It is recommended to use chemical additives in Avista fire suppression water cans to extend the efficacy of water blankets. Electric line and vegetation field crews are often required to adhere to state and federal fire- related work restrictions. ln many situations, field crews are required to spray their work area with water prior to activity. This helps prevent fire ignitions generated by spark emitting devices such as power drills and saws. Water evaporates rapidly during hot days, but there are a number of chemical additives that delay this process and extend the effectiveness of water blankets. The Fire Protection Research Foundation (www. nf pa.orgfou nation) cond u cted a na lysis i n 2013 to determine the effectiveness of several chemicaladditives. By using one of the chemical additives, Avista plans to increase the effectiveness of water blankets and water based fire su ppression tools. D-7 WUI Layer in Avista GIS System ln September of 20L9, Avista developed a Wildland Urban lnterface map based on the USDA's 2018 Wildland Hazard Potential and Avista's distribution system. This map helps identify and prioritize the work required to clear vegetation hazards and to 'harden' electric lines. The WUI map was developed by Avista's GIS Technical Services group and as of this writing, the WUI map is being published to the Company's GIS applications. GIS Technical Services has the lead on this effort (see addendum D-7 Wildland Urban lnterface for a more complete description). 54!t-age wttt)[tRt RF5tttEt,,l (Y Pt/\N Dr'-Xrd.dnllffihlPl ll air&r x EIGIQF x thTu x C.U Eir x x x EdiPLtL xr-fl)x x x x xfinOax xfinAb&4.x fuCrylbl x x Fn(h! xrirAA 2fl)0 x firft.x x FllEfrE x xniEdx EiCd.A x x x May 28, 2020 Attachment A T[namsnrfift'xr,rrllD-9 Wildfire Notification System ln July of 20L9, Avista Distribution Operations added provisions for wildfire notification to their ARCOS emergenry call- out system. This system allows Distribution Operations to dispatch messaging to first responders and key stakeholders. The Wildfire Notification system sends SMS text messages and emails to a pre-determined list of recipients. The Wildfire Resiliency Plan manager is responsible for updating this list and coordination with the Distribution Operations Manager. Fubl.ct ARCOS Wtldir. Nodacr$on O.t : July lE. 20'19 DavidJam.r fr,/- Mtlfires are increasing boh in size and tequeocy across lhe Wes|€,n Unitsd States. As part of a comprBhensi\rc strBtegy to rlducc the ris* of irE associrLd with Avisla's t-ansmissbn and dEtibl,tion syslems, @ shatr be irstitjted !o ihfom key staleholders, including exeqrtive managernenl, in lhe event o, a wildland fre event. Distibution Op.raions us€slh€ ARCOS rvstsrn to dbp.idr llcld pGrsonncl in the avefli of cr,stollH outag€B or offier mE]gdrcy incidents. Dlr6lrde!.9nJrleEnodfic.dil ln lrra d.rn (dlrD.!ch.r on !h.ll lnldrt lh. ARCOS YYlldfirr This notificalbn will help inform key indivituals ard avoid mEcommunicalim between offce rnd opcfatirg pcrlmnel as w€l as lhird parry fxrividuals See addendum for details. Risk Evaluation The following table summarizes the risks and estimated 10-year costs associated with the electric distribution elements of wildfire operations and emergency response. 2020-2029 Risk & Costs (Electric Distribution Operations) lnherent Risk (S Millions) Yq ss1.s 533e.s Managed Risk (S Millions) 54,9 s4.8s s129.s Mitigation l%l 9t% 9L% 62% Capital lnvestment (s) s20o,ooo s2oo,ooo Operating Expense (S) S2oo,ooo s400,000 s100,000 Sso,ooo s3o,o0o s5,o0o $785,000 Risk Fuse Coordination Recloser Event Reporting Fire lgnition Tracking System Fire Suppression "Wettingl' Agent WUI tayer in GIS ARCOS Wildfire Notification l Totals 65!Pase $317.s Sge.s 88% Not evaluated Not evaluated Sigr $177.8 77% May 28,2020 WITDFIRE RISItIENCY PtAN Attachment A Conclusion Summory of Risks, Benefits, ond Costs The risk and cost expenditures shown in the following table represent a lO-year planning horizon from 2020 to 2029. Note that the Plan includes both operating expense elements as well as capital improvements to infrastructure. Capital elements are planned to sunset after 2029 but the majority of the expense items are on-going and generally related to vegetation management. While project/program cost estimates are normal and routine, assigning financial risk to these fire resiliency measures is new. Avista is committed to reducing the risk of wildfire by incorporating cost justified and prudent measures. Fire resiliency is an important element among many in determining capital and operating expenditures, and funds are not unlimited. lt is not feasible to eliminate the fire risk to the electrical system. The column labeled 'inherent risk' is based on the current state risk for each operating category and indicates the range of risk from optimistic (low) to pessimistic (high). The values are specific to each category with the high end of the range normalized to 100 basis points. The next column labeled as 'managed risK indicates the risk reduction by adding wildfire resiliency defenses (future state). Note that defenses with a high confidence of success were selected and the cumulative impact of choosing 'the best of the best' is to drive the risk exposure downward. The column labeled 'risk mitigation' compares the midpoint of the inherent risk range to that of the managed risk range. Wildfire Risk Benefit and Cost Summa Grid Hardening & Dry Land Mode 41-100 0.7-2.7 98%s245,600,000 88%s5,1oo,ooo S51,175,000 000S5,014, Enhanced Vegetation Management Situational Awareness Operations & Emergency Response 65 lt'ag,e 48.3-100 3.2-4.5 25.9-100 0.8-1.1 19.7-100 5.3-23.4 98o/o 76% S17,96s,ooo S1,o19,ooo s3oo,ooo s2,378,000 WILDIIRI RtsIIII NCY PIAN 2020-2029 Operating Horizon lnherent Risk (range %) Risk Mitigation Capital lnvestment (S) Operating Expense (S) Managed Risk (range May28,2O2O Attachment A Addendum This version is printed without addendum materials. A full report version will be available later and will include the following supporting materials: 1. Wildland Urban lnterface Map (WUl), November 2019 2. Wildfire Risk Summary, Proposed Actions, September 2019 3. Wildfire Resiliency Cost Plan, January 2020 4. Wildfire Resiliency Plan, Project Charter, March 2019 5. Standard Operating Procedures, internal memos, various dates 5. Transmission Vegetation Management Plan (NERC, WMP) 7. Transmission Maintenance lnspection Plan (NERC, TMIP) 8. Distribution Vegetation Management Plan STlPage May 28,2020 WILDFIRE RESILIENCY PLAN