Mon 4/13: Deadline today, 5pm. Comment about PG&E to the Wildfire Safety Advisory Board.

Photo from full report here.

Action: Write a letter to tell the Wildfire Safety Advisory Board that PG&E is on the wrong path again.

Apparently today is “WRITE LETTERS DAY!” PG&E has stated that they would like to use their antiquated, expensive, wasteful and counterproductive method of stripping out all trees near their lines, versus replacing their own equipment with safer versions.

We have just been informed about an opportunity to communicate with the Wildfire Safety Advisory Board about what PG&E should be doing to prevent the next out-of-control fire. 

Here is a model letter…

To Wildfire Safety Advisory Board:

Thank you for analysis of the issues on Wildfire Safety. There are quite a number of very good comments overall and we appreciate that, but unfortunately important  priority issues have not been addressed. We know from all reports and news articles that PG&E’s  run to failure business model has resulted in frayed, unsafe wires as a major  source of utility associated wildfire in California. And taking out the forests en masse will not stop antiquated  bare wires from sparking and breaking in high winds, causing grass fires that quickly turn into forest fires. Yet, PG&E is spending $680 million on cutting trees and only spending $240 million on replacing distribution conducters. 

The number one thing to focus on is to replace unsafe wire, but this has not been addressed. SCE is replacing 750 miles a year with triple insulated hard steel center wire that can withstand broken branches, as well as animals and balloons and other dangers.  In contrast, PG&E is only replacing 200 miles this year with single insulated steel center wires. This Is the place to focus on if there is a serious intention to solve this problem instead of allowing PG&E to decide how little they can get away with doing. PG&E stated that it would be 10 years before they can  stop PSPS, but at this slow rate of replacement, it will be more like 20, if not more. It’s time to stop allowing the utilities to set their own inadequate standards that got us into this situation. 

There are at least 2700 miles of unsafe wire in high risk Tier 2 and 3 areas of PG&E territory. They should replace this within 3 years (not 20) if there is sincere intention to reduce PSPS events, reduce utility caused wildfire and to save lives. In addition, the inflated  costs that PG&E quotes per mile should be challenged. 

Ultimately, the CA Public Utilities Commission (CPUC) needs  to update the inadequate General Orders — improving these regulatory codes to adequately guide the  utilities. The Commission has full power to address the defects and omissions in their General Orders, specifically the complete absence of any mention of computerized circuit breakers. Most importantly, Wildfire Mitigation Plans should move forward upon the initiative of the Commission and its engineering staff, rather than allowing utilities to set their own regulations. The goal is to dramatically improve the fire and electrocution safety performance of all utilities operating in California. SB 901 did not obstruct the Commission’s authority. 

PG&E has 22,000 miles of antiquated, unsafe bare 6-gauge wire, and General order 95 still allows this.  It is time to take this inadequate wire out of the code, so it’s no longer legal to use it. The Office of Safety Advocate (OSA) had clearly stated this in the past, but was ignored. . Now,  the OSA has now been disbanded and all its valuable safety recommendations disregarded. The new Wildfire Safety Division has taken over the duties of the OSA, but there is no sign that its valuable analyses and recommendations were used as guidelines by the utilities, or that the information is being used by the CPUC, so the WSD should be urged to recommend that it be so. 

Only the most robust agenda of replacing unsafe conductor, and installing computerized protective relays,  will make California utilities fire-safe and we await the WSD to come forward with those kind of recommendations. 

Thank you for your consideration,

{Your name and organization} 


Wildfire Safety Advisory Board analysis here


(The information following are the main points presented. To view the full report in pdf format, including public comments and photographs, go here.)

RULEMAKING 18-10-007 FEBRUARY 7, 2020

The CA Public Utilities Commission (CPUC) has General Orders that define standards of performance for the Investor Owned Utilities they regulate. In the area of Wildfire Mitigation however, the CPUC has allowed the IOU’s to define their own standards of performance. The result has been a non-uniform mix of responses that range from barely acceptable to unacceptable.  In developing our comments, we are asking the CPUC to expand and update their existing General Orders to incorporate uniform practices, including circuit design, thus redefining “Best Practices” in response to Wildfire Mitigation, which can be adopted by all of the IOU’s across the State of California. An example of existing obsolete circuit design is the 22,000 circuit miles of #6 bare copper wire. This issue was directly pointed out by the Office of Safety Advocate in 2017 to be phased out, but was disregarded.

PG&E has demonstrated that it is a bad partner and has failed to change, even when faced by bankruptcy or being taken over by the State. We will provide information and examples of how PG&E is still cutting corners on safety, is unresponsive to the community, fails to communicate, and as a result there is little confidence that PG&E can provide a safe electric grid.

PG&E’s billions of dollars of liability burden, if invested in infrastructure, would have solved the wildfire ignition problem. Whenever we hear that it’s too costly to make these investments, we have to consider the costs of the wildfires and the costs of PSPS continuing into the future.

Our comments will cover the following:

1. Wires not Trees: 

PG&E is planning to spend $680 million on removing trees in 2020 and only spending about $240 million on replacing 240 miles of distribution conductor (we believe that that number is highly inflated). PG&E will spend over $500 million on removing trees up to 200 feet from their right-of-way alone. Regulations require a 4’-radial clearance (to last a year) from the wires. PG&E is claiming that removing thousands of trees “within striking distance” of the wires is justified. There are no metrics given to prove this will prevent wildfires or to validate this massive expenditure. Stronger, insulated wires will prevent arcing-caused wildfires, as well as the other 50% of fires caused by problems like animals, vehicle impacts, balloons and equipment failure. It’s the wires that cause the fires, not the trees and we should focus on the wires.

PG&E is depending on Enhanced Vegetation Management (EVM) to solve the wildfire issue, but it is failing to make the electric system safer – and instead potentially exacerbating the spread of fire, by focusing on trees. If NOT replaced and upgraded, no amount of tree removal will protect those lines from a branch blown from afar, or from the other causes of utility-associated wildfire including vehicles, animals, balloons and others that en toto equal the danger from vegetation impacts – causing breakage, arcing and, thus, electrocution and wildfires. In fact, if the distribution lines are cleared as planned, it will create tunnels that will, during high wind wildfire situations, become conduits for wind-blown firebrands. These flaming missiles will be blown along, far past the body of the fire itself, until it hits and set fire to residences and businesses at the end of the tunnel. This is what happened in Paradise, and in Australia, and PG&E’s EVM will contribute to the spread of destruction. (San Mateo Fire Protection for Homeowners’ workshop.) PG&E does not address the issue of wind tunnels in its WMP.

By NOT doing an EIR, there was no need to prove the efficacy of the program to reduce fire, no need to mitigate the enormous environmental destruction resulting from the clearance (especially from the removal of healthy, mature trees and impacts on riparian corridors), and no need to discuss the alternative ways to protect the distribution system – including replacing the antiquated conductor. The creation of wind tunnels during a fire storm was not considered, leading to mass loss of life and property. 

2. Infrastructure

Insulated Wire/conductors 

The CPUC has neglected to establish safety standards and regulations regarding criteria for conductor and computerized protective relays, the two most important aspects of a safe grid.  SCE has defined their Standard conductor, triple-insulated wire, with a hard steel center, which should be the Best Practices standard and PG&E fails to define what their conductor will be. Computerized protective relays have already been developed and tested by major electrical engineering companies – and are installed in Europe and Australia. However the IOUs are discussing this technology as though they are developing it now. The Commission needs to step in and require the use of this technology.  

PG&E states in its WMP the following: “Replacement of bare conductors with three-layer design of covered conductors (as tree wire) will reduce the likelihood of faults due to trees, branches, animals, or birds contacting lines, and will minimize situations where wires slap together in high winds, which can generate sparks or molten metal. The HFTD areas within PG&E’s service territory have a high volume of vegetation with large overhangs and ground fuels; PG&E expects covered conductor to be an effective risk mitigation in these areas. The covered conductor will also often be higher gauge that the wire it replaces, which will reduce the potential for failures related to smaller conductors. PG&E is replacing bare overhead distribution primary (high voltage) and secondary (low voltage) conductor with covered conductor in HFTD areas.”

 From the quote above, one would assume that PG&E is planning to significantly upgrade the cable to the same quality cable as what SCE originally tested and decided to make “Standard” (steel reinforced center with triple insulation). We expect that to be the case. PG&E must be held to the same standard, rather than the vague “covered conductor” of the final sentence.

 Also, comparisons regarding the replacement of bare conductors with “covered” and / or fully insulated main conductor distribution cable. “Covered” conductor is not necessarily fully insulated by engineering standards.  The Commission needs to clarify this distinction between Covered and Insulated and make it a part of its General Orders.

Operation of Non-Exempt Fuses 

PG&E estimates it has roughly over 15,000 non-exempt fuse devices located in the Tier 2 and Tier 3 HFTD areas. The operation of these fuses pose a potential fire risk and PG&E has a plan to replace these units over the next several years. This is far too long to allow the threat to continue.

Non-exempt fuses refer to fuse cutouts that CDF/CalFire determined were dangerous for wildfire ignitions many years ago.  Thus the term “non-exempt” refers to standards set by CDF. The Commission’s regulations continue to permit the use of these dangerous  and obsolete devices. Non-exempt fuses have the same problems as all expulsion fuses in that when they trip (blow) on an overcurrent event the fuse expels hot molten metal and other hot debris onto the ground.  This is not just a fire safety problem. Any pedestrian beneath one of these fuses when it blows will be injured, in some cases severely injured

No Emergency?

In their 2020 WMP SCE commits to replacing 700 miles of old conductor in the 2020 calendar year and PG&E commits to only 240 miles. (p. 18) At 7000 miles of Tier 2 and 3 that PG&E has committed to repairing, it will be decades before enough conductor is improved to improve safety. What about the rest of the 22,000 miles in tier 2 and 3 high fire risk?


PG&E is accumulating violations to their Utility Right-of-Way Exemptions from CalFire.

In a March 30, 2020 email from Eric Huff (Staff Chief, HQ Forest Practice Program) wrote regarding a request for information about PG&E’s Timber Harvest Plan Utility Right-of-way Exemptions. (These Exemptions gave PG&E a permit to cut trees up to 200 feet from the right-of-way without a THP for each property affected, but required they adhere to all THP regulations.) The request came from Calaveras County resident, Susan Robinson who learned of possible actions by PG&E that resulted in serious violations relating to wildfire prevention. Huff stated, “My understanding is that violations have been issued for failure to have the required fire box and fire tools on the project site, failure to have a copy of the Exemption on the project site, operations on saturated soils, and falling of trees in a Watercourse and Lake Protection Zone. Inspection reports have documented disagreement between the inspector and the utility representative in the determination of what constituted a “Danger Tree” likely to make contact with a powerline among other issues.” Even the CalFire Inspector does not agree that the trees being removed are all “hazard” tree, which are the only trees that are permitted under the Exemption. PG&E takes advantage of the exemption and is spending over a half a billion dollars to do this. 

Most importantly, the fact that violations are issued for not having the required fire equipment (which means being unable to stop a fire if they cause one) is reason for deep concern since the whole objective is wildfire mitigation. We continue to make the case that PG&E does not inspire trust in their behavior. They talk “safety” in their WMP, but they do not practice it in reality.

Unsafe Practices 

PG&E has unsafe practices regarding contractors’ employees, specifically in regard to CalOSHA required toilet facilities. They are also failing to consistently remove slash and wood resulting from its vegetation management activities, impacting property owners and increasing fire danger. 

PROBLEM 1. PGE CONTRACTORS ARE ENDANGERING PUBLIC HEALTH AND SAFETY re Covid-19 by not providing portable toilets (i.e. Porta Potties) for tree crews. CalOSHA has indicated that workers should drive to nearby toilets. Because of Covid-19, public toilet access is even more limited than previously. Usually in rural areas toilet access is non-existent anyway – or limited by excessive travel time. 

In other areas, it is now extremely difficult to find a toilet, and most remaining open stores require a purchase for toilet access. Most restaurants are closed, and those remaining open for pick-up limit toilet access to paying customers only. Sometimes the only vehicle available is an enormous bucket truck with chipper attached, which is exceedingly impractical for toilet trips. As a result, workers have no other alternative than to relieve themselves on public or private property.

SOLUTION: Provide portable toilets for crews but PGE has only occasionally done so when property owners have insisted. Further detail and specific complaints detailed in the Further Comments Section and to view the full report in pdf format, including public comments and photographs, go here.



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