Application of SAN DIEGO GAS & ELECTRIC )

COMPANY for Review of its Proactive De- )

Energization Measures and Approval of Proposed )
Tariff Revisions )
(U 902-E) )
)

Application No. 08-12-___

Exhibit No.: (SDG&E-2) _________

PREPARED DIRECT TESTIMONY

OF SOHRAB A YARI
ON BEHALF OF SAN DIEGO GAS & ELECTRIC COMPANY

BEFORE THE PUBLIC UTILITIES COMMISSION

OF THE STATE OF CALIFORNIA

DECEMBER 2008

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 TABLE OF CONTENTS

I. INTRODUCTION............................................................................................................. 1

II. OVERVIEW OF FIRE PREPAREDNESS PLAN ........................................................ 1

III. OVERVIEW OF FIRE RISK CONDITIONS ............................................................... 3

IV. STEPS TAKEN TO ADDRESS REGIONAL FIRE RESK.......................................... 4

V. LONG TERM ELECTRIC SYSTEM REINFORECEMENTS................................... 5

VI. IMPROVE PUBLIC SAFETY BY MORE CONSERVATIVE OPERATION

DURING HEIGHTENED FIRE CONDITIONS........................................................... 7

VII. IMPLEMENTED OPERATIONAL ELEMENTS OF FIRE PREPAREDNESS

PLAN FOR HEIGHTENED FIRE CONDITIONS..................................................... 10

VIII. PROPOSED OPERATIONAL ELEMENTS OF FIRE PREPAREDNESS PLAN

TO INITIATE PROACTIVE DE-ENERGIZATION ................................................. 13

IX. ACTIONS TO IMPLEMENT PROACTIVE DE-ENERGIZATION ELEMENT OF

FIRE PREPAREDNESS PLAN..................................................................................... 16

Appendix...................................................................................................................................... 19
I. Developing Operational Plans to Address Heightened Fire Conditions.................... 19
II. Fundamental Aspects of Fire Preparedness ................................................................. 22

Attachment A: Fire Preparedness Summary Plan

Attachment B: Map 1, 2008 Wildland Fire Area
Attachment C: Map 2, 2008 Potential De-energization Area

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 1 PREPARED DIRECT TESTIMONY

2 OF SOHRAB A. YARI

3 ON BEHALF OF SDG&E1

4 I. INTRODUCTION

5 I am the Director of Electric Transmission & Distribution Engineering for San Diego Gas

6 & Electric Company (“SDG&E”). The purpose of my testimony is to provide a background of

7 fire risk conditions, a general explanation of the engineering and operations aspects of SDG&E’s

8 Fire Preparedness Plan, including measures that SDG&E has already implemented, and finally,

9 to present for Commission review the proactive de-energization element of the Fire Preparedness

10 Plan that SDG&E intends to implement on September 1, 2009. I use the term “Fire Preparedness

11 Plan” to include measures that are already implemented as well as the pending implementation of

12 proactive de-energization.

13

14 II. OVERVIEW OF FIRE PREPAREDNESS PLAN

15 SDG&E has developed a Fire Preparedness Plan to modify operating practices during

16 periods of heightened fire risk to enhance overall public safety. A summary of this Fire

17 Preparedness Plan is Attachment A of this testimony. The primary purpose of the Fire

18 Preparedness Plan is to initiate consecutively more conservative operating policies as fire risks

19 escalate. The most conservative element of the Fire Preparedness Plan is the de-energization of

20 very selective electric circuits that have overhead facilities in areas particularly susceptible to

21 wildland fires during the most extreme fire risk conditions. In the 2008 plan, approximately

22 45,000 of SDG&E’s 1.4 million customers are in or near the highest risk fire areas and could

23 have potentially been impacted by proactive de-energization. As will be described later in the

1
My witness qualifications are appended to this testimony.

#225087 SAY-1
 1 testimony, since the outages would be dependent on local weather conditions as monitored at 15

2 remote automated weather stations, the likelihood is that 1,000 to 10,000 customers would be

3 affected at one time. (The data from these 15 weather stations during September and October of

4 2008 showed that only one area met all the conditions that would have resulted in proactive de-

5 energization on one occasion. On October 1, 2008 extreme weather conditions were recorded in

6 the Cameron area.2 Approximately 4,150 customers would have been impacted if proactive de-

7 energization was in affect. After 3 hours, the weather conditions reached the level where the

8 service restoration process would have begun.) Since large portions of wildland vegetation has

9 reestablished in the area that burned in 2003, based on preliminary information, it is expected

10 that the total number of customers potentially impacted by the 2009 highest risk fire areas could

11 increase to approximately 60,000.3

12 The Fire Preparedness Plan defines three levels of fire risk conditions (Elevated Fire

13 Condition, Red Flag Warning Condition, and Extreme Fire Condition), which are conditions

14 warranting more conservative operating practices. Generically, the changes in the operating

15 practices during an Elevated Fire Condition and a Red Flag Warning Condition relate to the

16 specific actions taken when protective equipment indicates a fault condition4 on a circuit in the

17 areas of the system that have been identified as being particularly susceptible to wildfire ignition.

18 As mentioned above, the most conservative operating practice is proactive de-

19 energization of electric circuits in specific areas that have the highest risk of fire during the most

20 extreme conditions.5 Proactive de-energization would only be implemented during a period of

21 Extreme Fire Condition accompanied by extreme weather/environmental conditions (very high

2
Cameron is near Campo and Boulevard, in Southeastern San Diego County.
3
The 60,000 customer number is based on preliminary data which will be finalized in the first four months of 2009.
In 2008, approximately 45,000 customers lived in or near the Highest Risk Fire Areas and would have been
potentially impacted by proactive de-energization.
4
A fault condition is when power flow exceeds expected limits.
5
The methodologies used to determine the fire risk thresholds and identification of areas particularly susceptible to
wildland fires are discussed in the Appendix.

#225087 SAY-2
1 winds, low humidity, and very dry vegetation). This combination of conditions is expected to

2 occur infrequently (zero to three days per year). De-energizing these facilities would reduce the

3 potential that the electrical facilities could be involved in a wildland fire. This proactive de-

4 energization component of SDG&E’s Fire Preparedness Plan is the primary topic of SDG&E’s

5 Application to the Commission. Other information included in this testimony provides

6 background and understanding of SDG&E’s other fire preparedness efforts already in place so

7 the Commission and others can have a solid foundation to review SDG&E’s proposed proactive

8 de-energization measures.

10 III. OVERVIEW OF FIRE RISK CONDITIONS

11 Southern California has many unique characteristics that contribute significantly to the

12 risk of large scale fires. These characteristics include population distribution patterns,

13 topographical characteristics and, most notably, weather patterns.

14 A. Seasonal Weather Patterns

15 One of the characteristics of Southern California that increases fire risk is the typical

16 weather pattern of long periods of sustained dry weather followed by a relatively short rainy

17 season. This area of the country also has unique wind characteristics where wind storms known

18 as “Santa Anas” bring hot, dry air from the desert east of San Diego and quickly lower the

19 relative humidity causing vegetation to dry out. These wind storms can be severe and last for

20 several days. In addition, the extended drought over the past several years not only has stressed

21 the local water supply, it has contributed to increased levels of dead and dying vegetation.

22 B. Fuel Loading

23 The fuel available for large scale fires is mostly natural vegetation in less populated

24 areas. Some of these fuel areas are the result of topographical features in rugged canyon areas

25 that are avoided by developers. There are also fairly large areas of relatively sparsely populated

#225087 SAY-3
 1 land surrounded by Federal, State, and local park lands comprising larger wildland areas. All of

2 this compounds the natural annual cycle of the quick growth of vegetation in the spring followed

3 by the vegetation drying out, usually with some vegetation dying, during the summer and fall.

4 This results in large quantities of dry fuel available to feed fires in late summer and fall.

5 C. Localized Weather Conditions

6 The topographic features of San Diego and southern Orange counties, which include

7 mountains, valleys, canyons, beaches, and deserts, result in unique localized weather conditions.

8 The National Weather Service develops four separate weather forecasts (Coastal, Inland,

9 Mountains, and Desert zones) for this area of southern California. In addition, the localized

10 topography within these regions results in isolated variations, especially in wind speed and

11 direction. These localized weather patterns combined with localized fuel load significantly

12 impact the fire hazard risk in specific areas throughout San Diego and southern Orange counties.

13 A description of the methods that were used to attempt to quantify these risk factors and identify

14 the areas and time periods of highest fire risk is covered in the Appendix of my testimony.

15

16 IV. STEPS TAKEN TO ADDRESS REGIONAL FIRE RESK

17 Many public safety agencies and other organizations have recently evaluated their

18 operations with respect to fire risk mitigation. In our area, building codes have been revised and

19 fire agencies have conducted media campaigns to educate the public on fire preparedness and

20 promote maintenance of defensible space around residences. In this same spirit of improving

21 public safety, SDG&E has evaluated its operations in areas of high fire risk and implemented

22 modifications to its operating practices during heightened fire risk conditions. Specifically,

23 SDG&E expanded inspection (ground and aerial) of overhead facilities in critical areas (which

24 facilitates timely repairs when required), expanded the installation of conductor spacers on

25 distribution circuits in critical areas, began more aggressive vegetation management efforts,

#225087 SAY-4
1 began construction to “harden”6 the 69kV circuits (wood-to-steel pole conversion, increased

2 conductor spacing, and use of heavier conductors) in critical areas, and began installation of

3 additional distribution sectionalizing switches in strategic locations to minimize outage impacts

4 to customers on lengthy distribution circuits. SDG&E also initiated customer and public safety

5 agency outreach programs to better prepare for future fire emergencies. These outreach

6 programs are covered in the testimony of Mr. Velasquez and Mr. Lawless.

8 V. LONG TERM ELECTRIC SYSTEM REINFORECEMENTS

9 In an ongoing effort to reinforce the electric system in the Wildland Fire Area (see

10 Attachment B, Map 1), SDG&E is proceeding with the following initiatives to improve public

11 safety, reducing the likelihood of equipment failure under extreme conditions, and to minimize

12 customer impact following potential fires in the future.

13 A. Hardening Overhead Facilities in Critical Areas

14 This work includes the replacement of wood poles with steel poles, installation of heavier

15 conductor, increased spacing between conductors, and the use of fire resistant cross arms in the

16 Wildland Fire Area. The wood-to-steel 69kV circuit replacement projects began in November

17 2007 with replacement of the wood poles that were burned in the October 2007 wildfires.

18 SDG&E will begin the use of steel poles for new distribution construction in the Wildland Fire

19 Area and to strategically rebuild critical distribution circuits. These hardened facilities would

20 also be designed to withstand extreme wind gusts of 85 mph. Hardening of the system will

21 provide improved performance during severe conditions, such as Santa Ana wind events, and

6
“Hardening” of facilities is a term used by SDG&E to refer to physical improvements, including use of fire
resistant materials and/or use of design criteria that exceed requirements in current standards, for this area in order to
make the facilities more fire resistant and to decrease the likelihood of equipment failure under extreme
environmental conditions.

#225087 SAY-5
 1 lessen the risk associated with keeping the circuits in service during these conditions.7 In

2 addition, the hardened facilities would be more resistant to damage if a wildfire passed through

3 the area, therefore they would potentially reduce the time required to restore power in these areas

4 after a large fire.

5 B. Installation of additional circuit sectionalizing devices

6 Work will continue to strategically add automatic sectionalizing devices on long

7 distribution circuits. Separating a circuit into smaller sections will minimize the number of

8 customers impacted, and reduce outage durations and inspection times after a fault is detected.

9 (See Attachment C, Map 2, which shows the areas that would have been subject to proactive de-

10 energization in 2008.)

11 C. Underground Strategic facilities

12 Underground facilities are less susceptible to damage from the dry and windy conditions

13 that increase fire risks. Much less underground construction has taken place in the Wildland Fire

14 Area in comparison to the more urban areas due to the long distances between loads, the

15 ruggedness of the terrain, and the potential environmental impact during construction. SDG&E

16 is exploring strategic locations8 where limited conversion from overhead to underground

17 facilities would make the electric services to critical public safety facilities, such as certain water

18 supply facilities, less susceptible to outages during fires, Santa Ana wind events or other severe

19 conditions.

7
The intent would be to exclude those facilities that have been hardened from being subject to proactive de-
energization. As sufficient facilities are hardened in strategic areas the number of customers potentially impacted by
proactive de-energization is expected to be decreased.
8
These evaluations must consider the construction feasibility in rugged terrain as well as the distances required to
avoid the Highest Risk Fire Areas. Wholesale underground conversion as a means to reduce fire risk is not a cost
effective application. For a fraction of the cost of undergrounding, existing overhead distribution lines can be
reinforced, or “hardened,” to withstand wind loads of 85 mph including use of steel poles, larger conductors, and
greater spacing between the conductors.

#225087 SAY-6
 1 D. Obtain Authorization and Implement More Stringent Vegetation Management
2 Policies
3 Current laws and environmental restrictions limit SDG&E’s ability to manage vegetation

4 that might present a hazard to electric facilities on both public and private land. In order to

5 improve public safety, SDG&E will work with local governments, public safety agencies, the

6 Commission, and the legislature as appropriate to modify current laws and regulations to allow

7 for increased vegetation management in the critical wildland areas. One forum that will explore

8 this issue in the near-term is the Electric Safety OIR (R.08-11-005), which was recently initiated

9 by the CPUC.

10
11 VI. IMPROVE PUBLIC SAFETY BY MORE CONSERVATIVE OPERATION
12 DURING HEIGHTENED FIRE CONDITIONS
13 Electric utilities have always strived to consistently provide safe and reliable electric

14 service to their customers. When outages occur, utilities generally attempt to restore power to

15 customers as quickly as reasonably possible. As soon as worker safety can be assured, utility

16 workers begin repair of damaged facilities even under extreme weather conditions. However, to

17 improve public safety during heightened fire conditions, SDG&E has examined potential

18 modification of normal operating practices under certain conditions. The steps that have already

19 been implemented, as well as some of the long-term initiatives were briefly discussed above.

20 One initiative that was proposed but not implemented during the 2008 fire season is the proactive

21 de-energization of very selective circuits during extremely high fire risk conditions

22 A. Identification of fire risk condition levels

23 Since Fire Agencies no longer identify a specific fire season, SDG&E determined that it

24 could evaluate the seasonal and event specific fire risk throughout the year by monitoring

25 specific parameters that are good indicators of fire risk. After evaluating the fire risk threshold

26 data, SDG&E identified four discrete levels for use in triggering successively more conservative

27 operating practices as fire risks escalate. As summarized in Attachment A, these levels are

#225087 SAY-7
 1 applied to the specific geographic areas described in the next section of the testimony, thus

2 minimizing the direct impacts to customers. These levels are defined below:

3 • Normal Operating Condition: This level is declared when live fuel moisture is greater

4 than 75% as identified by Cal Fire

5 • Elevated Fire Condition: This first level of heightened fire risk is declared when live

6 fuel moisture is less than or equal to 75% as identified by Cal Fire

7 • Red Flag Warning Condition: This second level of heightened fire risk is declared

8 when SDG&E is in an Elevated Fire Condition and the National Weather Service

9 declares a Red Flag Warning for high wind or low humidity.

10 • Extreme Fire Condition: This third level of heightened fire risk is declared when

11 SDG&E is in an Elevated Fire Condition, the National Weather Service declares a Red

12 Flag Warning for high wind or low humidity and wind speeds in any of the Highest Risk

13 Fire Areas are forecast to or actually do equal or exceed 35 mph sustained or 55 mph

14 gusts accompanied by sustained winds equal to or greater than 30 mph.

15

16 B. Areas where operations are modified during heightened fire risks

17 As discussed in the Appendix, SDG&E identified two specific geographic regions in

18 which operating restrictions would apply during specific fire condition levels (see Attachment B,

19 Map 1). These regions are:

20 • San Diego and southern Orange counties Wildland Fire Area: This area was

21 identified by combining the moderate, high, and very high severity areas within the Cal

22 Fire Hazard Severity Zone data. It covers much of SDG&E’s service territory. During

23 Red Flag Warnings for high winds or low humidity, operating restrictions apply in those

24 portions of the Wildland Fire Area covered by the Red Flag Warning.

#225087 SAY-8
 1 • San Diego and southern Orange counties Highest Risk Fire Areas: These areas were

2 identified by SDG&E using Cal Fire fuel ranking and fire history information. Operating

3 restrictions apply in these areas whenever SDG&E is in an Elevated Fire Condition or

4 Red Flag Warning Condition. The Highest Risk Fire Areas will be reevaluated on an

5 annual basis and modified as fuel conditions change. It should be noted that the “Highest

6 Risk Fire Areas” are a subset of the “Wildland Fire Area.” The 2008 Highest Risk Fire

7 Areas are shown as the cross hatched areas on Attachment B, Map 1.

8 Since an electric circuit is a linear element that takes power from a power source to serve

9 the customers loads, when a portion of a circuit is de-energized, any portion of the circuit down-

10 stream from the de-energized portion is also de-energized.9 SDG&E has examined the circuits

11 that are within, or pass through, the Highest Risk Fire Areas and determined the geographic areas

12 that would potentially be impacted if the circuit was de-energized. These areas are called the

13 Potential De-energization Areas. The Potential De-energization Areas are larger than the

14 Highest Risk Fire Areas because they include the portions of the circuit entering into the Highest

15 Risk Fire Areas, as well as portions of the circuit outside the Highest Risk Fire Areas, but

16 downstream of the sectionalizing device.

17 Each circuit that has overhead facilities within or passing through the Highest Risk Fire

18 Areas, is associated with one of 15 Remote Automated Weather Stations (RAWS) that are within

19 or near the Highest Risk Fire Areas. This results in 15 discrete geographical areas which are

20 individually monitored and potentially subject to proactive de-energization.10 These 15 RAWS

9
For the same reason, it is not possible to exempt individual customers from proactive de-energization. In order to
improve public safety it is essential that the entire circuit downstream from the de-energization device be de-
energized.
10
In 2008, SDG&E installed 11 automated wind monitoring stations on existing electric facilities to supplement the
wind data provided by the RAWS. Once these wind monitoring stations have been calibrated and the data verified,
the additional data will eventually allow further segmentation and refinement of the discrete geographic areas
subject to proactive de-energization to reduce the number of customers impacted when Extreme Fire Conditions are
indicated in an area.

#225087 SAY-9
 1 are operated by Cal Fire, US Forest Service, or the Bureau of Land Management and

2 electronically report weather measurement data on an hourly basis. This weather data is critical

3 in determining which circuits are experiencing Extreme Fire Conditions. (The Potential De-

4 energization Areas and locations of the RAWS are shown in Attachment C, Map 2.)

5
6 VII. IMPLEMENTED OPERATIONAL ELEMENTS OF FIRE PREPAREDNESS
7 PLAN FOR HEIGHTENED FIRE CONDITIONS
8 A. An operational plan is implemented during heightened fire conditions

9 SDG&E’s Fire Preparedness Plan procedure outlines the operating restrictions required

10 for overhead facilities during varying levels of fire weather conditions. This procedure

11 implements specific actions to be taken by SDG&E for its 69kV and distribution circuits during

12 certain fire weather conditions. These actions are staged for various fire weather condition levels

13 in order to balance electrical reliability to SDG&E’s customers with the risks associated with

14 those fire weather conditions. Those actions escalate and de-escalate as fire weather conditions

15 change.

16
17 1. Progressively conservative operations are implemented during
18 heightened fire conditions
19 Throughout the electric supply system, protective equipment continually monitors power

20 flow and automatically operates to very quickly de-energize equipment if unusually high levels

21 of power flow are detected. These devices are similar to the circuit breakers or fuses in our

22 homes. However, unlike the circuit breakers and fuses in our homes, much of this protective

23 equipment is capable of automatically re-energizing the circuits or portions of the circuit. For the

24 69kV and distribution circuits, the devices that re-energize the electric facilities are known as

25 reclosers. Reclosers are critical in maintaining system reliability and minimizing outages to

26 large numbers of customers when individual components of a circuit fail and have been

27 disconnected from the circuit. Reclosers can be programmed to operate in various ways to

#225087 SAY-10
 1 coordinate with other reclosing devices in the system and maximize reliability. Under normal

2 operating conditions the reclosers are set to operate as follows:

3 • 69kV Circuit Reclosers: The reclose cycle allows only one reclose attempt and the

4 cycle automatically resets after the line remains energized for approximately two

5 minutes.

6 • Distribution Circuit Reclosers: The reclose cycle allows either one or two reclose

7 attempts and the cycle will automatically reset after the line remains energized for

8 approximately two minutes.

9 Under the Fire Preparedness Plan SDG&E initiated in 2008, when an Elevated Fire

10 Condition is declared, SDG&E turns off or modifies the operation of selected automatic reclosers

11 on the 69kV and distribution circuits in the Highest Risk Fire Areas to only allow one re-

12 energization cycle attempt. (The re-energization cycle for 69kV circuits will be a single reclose

13 attempt; for some distribution devices a second reclose attempt may be made within the first

14 minute.) Reclosers on distribution overhead sectionalizing devices, which cannot be monitored

15 remotely by a system operator, are turned off. Following a single reclose cycle (or if the line

16 attempts to reclose but fails to reclose), the recloser device is turned off remotely until the line is

17 visually inspected and the recloser device is manually reset. (When the recloser device is turned

18 off, it prevents any automatic attempts to re-energize the line.)

19 Operating restrictions for Red Flag Warnings are limited to those warnings that are for

20 high wind and low humidity or for low humidity only. There are no operating restrictions

21 applied for Red Flag Warnings associated with dry lightning. When in a Red Flag Warning for

22 high wind and low humidity or low humidity only, SDG&E turns off the reclosers on the circuits

23 that are in the subset of the SDG&E Wildland Fire Area that is also in the National Weather

24 Service (NWS) weather zone(s) declared under the Red Flag Warning. Following an operation

25 of a sectionalizing device on such a circuit (a “forced outage” due to a fault), the line is inspected

#225087 SAY-11
 1 and re-energized if appropriate to do so. Although the time required to inspect the line

2 potentially increases the duration of the outage, SDG&E believes this additional step is

3 warranted by the heightened fire risk conditions. The method of first “electrically testing”11 the

4 line to determine if the fault condition had corrected itself could present a potentially significant

5 fire risk if the fault condition still exists, especially since the high wind conditions increase the

6 likelihood of permanent damage to overhead facilities. This modified operational practice12 may

7 increase the duration of an outage and the number of customers impacted in comparison to

8 normal recloser operating procedures, but under elevated fire risk conditions and red flag

9 warnings this action is necessary to enhance public safety.

10
11 2. Activate SDG&E’s Emergency Operations Center (EOC) during Red
12 Flag Warning events under Elevated Fire Conditions
13 Whenever the NWS declares a Red Flag Warning due to low humidity or high winds,

14 SDG&E’s Emergency Operations Center (EOC) will be activated. Depending on conditions, the

15 recommended staffing levels are as follows:

16 • The EOC will be staffed with emergency services personnel if the Red Flag Warning is

17 for low humidity only or the forecasted winds during the Red Flag Warning period are

18 not expected to exceed a sustained speed of 25 mph or gusts over 45 mph. During these

19 periods, the emergency services personnel will monitor for changes in the forecasted

20 weather conditions and wind speeds using the NWS and SDG&E weather service data

21 and the actual wind speeds using the RAWS data.

11
Electrical testing is the traditional practice of attempting to re-energize a line prior to a physical inspection to see
if the condition that had caused the fault has been eliminated. This step potentially reduces the duration and number
of customers impacted by an outage caused by a temporary fault condition.
12
SDG&E is evaluating the potential use of a new technology (the “Intellirupter Pulsecloser” manufactured by S&C
Electric Company) that could accomplish electrical testing at a significantly lower energy level. If these devices
result in significantly lowered fire risk, it may allow use of electrical testing during certain elevated fire risk
conditions.

#225087 SAY-12
 1 • The EOC will be fully staffed 24 hours per day during a Red Flag Warning with wind

2 speeds forecasted to exceed 25 mph sustained or 45 mph gusts. At this point, activities in

3 the EOC include monitoring overall weather and system conditions, coordinating field

4 personnel support, and preparing to initiate communications and notifications as

5 conditions warrant.

6 3. Limit maintenance activities that may pose a fire risk

7 During Red Flag Warnings, non-emergency maintenance and construction work in the

8 Wildland Fire Area is limited to those activities that do not pose a potential fire ignition risk.

9 Prohibited activities include cutting, grinding, grading, off-road activity, and other activities that

10 might increase fire ignition risk.

11

12 4. Provide additional field personnel to improve response time

13 SDG&E’s Fire Preparedness Plan describes the company's planned response related to

14 the operation of the 69 kV and distribution circuits to various fire weather conditions. The

15 “Normal Operating Condition” merely refers to normal day-to-day operation. When an

16 “Elevated Fire Condition” is declared, SDG&E will stage switching personnel at specified

17 locations within the service territory. If a Red Flag Warning for high winds or low humidity is

18 declared, SDG&E will stage electric construction personnel in key locations within the declared

19 areas.

20
21 VIII. PROPOSED OPERATIONAL ELEMENTS OF FIRE PREPAREDNESS PLAN
22 TO INITIATE PROACTIVE DE-ENERGIZATION
23 A. Proactively de-energize very selectively-determined circuits with overhead
24 facilities within a “Highest Risk Fire Area” only when exceeding the “five
25 trigger” criteria in localized areas
26 During a Red Flag Warning (except for dry lightning), SDG&E’s 69 kV and distribution

27 circuits with overhead facilities that are in or pass through one of the Highest Fire Risk Areas are

#225087 SAY-13
 1 proposed to be de-energized when the following additional weather conditions exist at its

2 associated RAWS. SDG&E has established five triggers for proactive de-energization of a

3 circuit, all of which must be met before a circuit would be proactively de-energized. These

4 triggers13 are as follows:

5 1. Live fuel moisture level is less than or equal to 75%;

6 2. Red Flag Warning being declared by the NWS for high winds or low humidity;

7 3. Relative humidity is less than or equal to 20%;

8 4. 10-hour fine fuel (non-living fuel) moisture is less than six percent; and

9 5. Sustained winds of greater than or equal to 35 mph or frequent wind gusts of greater than

10 or equal to 55 mph accompanied by sustained winds equal to or greater than 30 mph.

11 These trigger levels will be reevaluated on an annual basis to keep them current and to

12 incorporate operating experience from the previous periods of heightened fire risk.

13 On a daily basis, SDG&E’s contracted weather service provides 10-day weather forecasts

14 via e-mail for each of the SDG&E Operating Districts based on forecast information provided by

15 the National Weather Service supplemented by the hourly data from the RAWS. Additionally,

16 the contracted weather service provides SDG&E severe weather alerts, a phased alert system

17 qualified with a color condition status which will vary according to the severity and immediacy

18 of the threat, and confidence the forecaster has that the severe weather will directly affect a given

19 Operating District. These alerts are received via e-mail and will be updated at least four times

20 throughout the day. To supplement our Fire Preparedness Plan, the contracted weather service

21 also provides SDG&E additional alerts for specified weather stations six hours or more in

22 advance of suspected sustained winds greater than or equal to 35 mph or wind gusts greater than

23 or equal to 55 mph. Finally, the contract weather service provides SDG&E alerts via e-mail and

13
The portions of the overhead electrical system that has been hardened would not be subject to proactive de-
energization.

#225087 SAY-14
 1 phone notification for specified weather stations based on wind thresholds of sustained winds

2 greater than or equal to 25 mph (not dependent on red flag being present), sustained winds

3 greater than or equal to 35 mph (red flag must be present), and wind gusts greater than or equal

4 to 55 mph (red flag must be present). An hourly threshold status message will be provided via e-

5 mail listing all weather stations that exceed a current threshold. All observation weather station

6 e-mail alerts include wind direction, speed, gust, relative humidity, and fuel moisture.

7 This information is used to initiate various actions, including activation of SDG&E’s

8 Emergency Operations Center (EOC), initiation of modified operating procedures, initiation of

9 contacts with essential use customers and automated notifications of pending de-energization to

10 potentially affected customers. If time allows, a first round of notifications to essential use

11 customers and potentially affected customers will be initiated four to six hours before the wind

12 levels are predicted to exceed the trigger values. A second round of notifications will be initiated

13 two to three hours before the wind levels are predicted to exceed the trigger levels. The

14 customer notifications and outreach program are covered in the testimony of Mr. Velasquez and

15 Mr. Lawless.

16

17 B. Re-Energization

18 For facilities that have been de-energized, SDG&E will frequently review the weather

19 data to determine when inspections should begin as well as when circuits can be re-energized.

20 The circuits will generally be re-energized when the restrictions due to high winds have been

21 terminated for that weather monitoring station and those circuits have been inspected.

22 Inspections will begin when sustained winds are less than or equal to 25 mph. Generally,

23 circuits will be re-energized when sustained winds are less than or equal to 25 mph for two hours

24 or more, provided they have been inspected. If requested by an outside agency, a line may be re-

25 energized prior to sustained winds dropping to less than or equal to 25 mph for two hours.

#225087 SAY-15
1 IX. ACTIONS TO IMPLEMENT PROACTIVE DE-ENERGIZATION ELEMENT OF
2 FIRE PREPAREDNESS PLAN
3 In the event of a declared Red Flag Warning coupled with very high winds, provided that

4 all of the “five triggers” described above are met, SDG&E will proactively de-energize one or

5 more certain electric circuits that have been determined to be operating under particularly

6 hazardous fire weather conditions.

7 As previously discussed, SDG&E’s Emergency Operations Center (EOC) will be fully

8 staffed as fire risk conditions escalate. In addition to coordination of the de-energizations, the

9 EOC activities will include the coordination of communications pertaining to proactive de-

10 energization with the media, public officials, public safety agencies and potentially affected

11 customers. The details of these communication efforts are described in the testimony of Mr.

12 Velasquez and Mr. Lawless.

13 This concludes my prepared direct testimony.

#225087 SAY-16
1 X. QUALIFICATIONS OF SOHRAB A. YARI

2 I graduated with a Bachelor of Science degree in Electrical Engineering from the

3 University of Texas in El Paso in 1979. I worked as a plant electrical engineer for Lone Star

4 Industries from 1979 to 1980 and was responsible for electrical projects in System Protection and

5 Control. I obtained a Master of Science degree in Electrical Engineering with emphasis in Power

6 Systems from the University of Texas at El Paso in 1983. I joined the Transmission Planning

7 Section of SDG&E in 1982. I had lead responsibility for development of SDG&E’s electric

8 transmission capital budget projects to expand the transmission system within the SDG&E

9 service territory, evaluation of transmission interconnection capabilities to accommodate off-

10 system resources, and the conducting of system analysis. From 1999 to 2004, I served as

11 SDG&E’s Manager of Grid Operations Services, where I was responsible for technical

12 evaluation to identify day-to-day and seasonal transfer capability limits and mitigating measures

13 for the safe and reliable operation of SDG&E’s transmission system. I managed development

14 and coordination of operating procedures to minimize congestion. I also managed SDG&E’s

15 existing transmission contract administration responsibilities and was responsible for overseeing

16 all Reliability Must Run contract, settlements, technical studies and FERC filings. Since 2004, I

17 have served as the Director of SDG&E’s Electric Transmission and Distribution Engineering

18 Department, responsible for design and engineering of distribution, substation, and transmission

19 projects, including the engineering, equipment, and structural design involved in the

20 development of Transmission and Substation Engineering projects.

21 From 1986 to 1998, on a part-time basis, I taught at the senior level at San Diego State

22 University in the Electrical and Computer Engineering department in system network modeling

23 and power flow analysis, system stability, and system protection. Since 2000, I have been

24 teaching a Professional Engineering preparation class at SDG&E in the Electrical Engineering

25 discipline.

#225087 SAY-17
1 I have served as the Chairman of the Western Electricity Coordinating Committee

2 (WECC) Pacific and Southwest Transfer work group, and I have represented SDG&E on the

3 WECC Planning and Operations Committees.

4 I am a registered Professional Engineer (in the Electrical Branch) in the State of

5 California (No. 11591).

#225087 SAY-18
 1 Appendix

2
3 I. Developing Operational Plans to Address Heightened Fire Conditions
4 The first step taken to modify operations to address heightened fire conditions was to

5 analyze and select fire risk thresholds that could be associated with specific areas of the service

6 territory. Since fire agencies no longer identify a specific fire season, SDG&E determined that it

7 could evaluate the seasonal and event-specific fire risk throughout the year based on monitoring

8 specific parameters that are good indicators as to whether conditions are present to where a fire

9 could quickly grow into a large uncontrollable wildland fire. As previously mentioned,

10 SDG&E’s Fire Preparedness Plan applies a stepped response commensurate with the hazard

11 level at that given time. In order to determine when specific action steps needed to be taken,

12 SDG&E set trigger thresholds for the monitored parameters that corresponded with action steps.

13 A discussion of these threshold levels and the logic behind them is presented below. It is

14 commonly understood that the amount of moisture in living plants is inversely proportional to

15 the fire risk of those plants. When fully hydrated and wet, the plants are a low fire risk.

16 However, as they lose moisture during the dry season, their fire risk increases. The U.S. Forest

17 Service and Cal Fire have been tracking live fuel moistures for many years and review of that

18 data offered the opportunity to assign a measurable value for the period of highest risk. After

19 review of the data and associated fire history, SDG&E decided to use a living fuel moisture

20 level14 of 75% or less as the criteria to identify the time of the year considered to be in an

21 elevated fire condition. This is the basis for SDG&E’s “Elevated Fire Condition” with certain

22 operational mitigations being put in effect during this period.

14
Living fuel moisture levels that are monitored for this plan are the measurements made by Cal Fire and the US
Forest Service for new growth Chamise (adenostoma fasciculatum) vegetation, which is a flowering plant native to
California and northern Baja California. This shrub is one of the most widespread plants of the chaparral biome.

#225087 SAY-19
 1 Fire risk generally changes with the season. However, within a given season, fire risk

2 can change significantly from time-to-time depending on specific weather conditions being

3 experienced. The National Weather Service has noted that periodically a dry weather pattern

4 will develop with low humidity, high winds and/or dry lightning. These patterns are known to

5 significantly increase fire risk. By declaring what is known as a “Red Flag Warning” the

6 National Weather Service attempts to predict these conditions and provide advanced warning to

7 local government, fire agencies and the general public that a period of high fire risk is

8 developing. This would serve as notification that fire danger is high and additional care should

9 be taken to minimize opportunities for a fire to start. Given this, SDG&E made the

10 determination to use the National Weather Service Red Flag Warning system as a means to

11 initiate additional operational mitigation measures related to fire prevention and fire

12 preparedness. Operational changes are in effect for the period of time corresponding to the

13 period of time specified in the National Weather Service’s Red Flag Warning declaration. For

14 SDG&E’s Fire Preparedness Plan, this condition is known as the “Red Flag Warning Condition.”

15 SDG&E’s focus is on those Red Flag Warnings that center on the wind component.

16 Wind not only causes structural loading on poles and equipment, but can damage nearby trees

17 and vegetation which may fall or blow into the line. Additionally, winds speeds have a direct

18 correlation to how fast a fire can spread and also to the ability for a fire to be fought. The higher

19 the winds, the worse the situation becomes.

20 In reviewing historical data it appeared that sustained winds of 35 mph and greater during

21 a red flag condition reflected a general wind condition that could lead to a large wildfire that may

22 put the public and the electric grid at risk. Additionally, it was noted that air operation efforts for

23 fire suppression are severely impacted at wind speeds of 35 mph or greater as either the aircraft

24 cannot safely fly close to the ground during those conditions, and/or their suppression drops

25 become ineffective due to dispersion or inability to accurately hit their target drop zones. For

#225087 SAY-20
1 these reasons, SDG&E’s Fire Preparedness Plan incorporates a trigger threshold for sustained

2 wind of 35 mph, indicating extreme conditions are being experienced.

3 A review of structural design criteria and loading effects associated with wind confirmed

4 that wind gusts of 55 mph or greater could lead to loading conditions approaching the design

5 threshold of parts of the electric system. Therefore, SDG&E’s Fire Preparedness Plan

6 incorporates an alternate wind storm trigger threshold for de-energization for wind gusts of 55

7 mph.

8 Acknowledging wind as the greatest contributing factor, SDG&E has set additional

9 criteria that identifies an extreme fire day in totality and eliminates those windy days that have

10 higher levels of moisture or precipitation associated with them (such as a rainstorm) where fire

11 risk may not be extreme. Relative Humidity (RH) is an important factor and measurements are

12 readily available via the RAWS. A value of 20% relative humidity was selected as a trigger

13 signifying extreme conditions for de-energization in the localized areas.

14 The final trigger for de-energization that is included in the extreme condition associated

15 with SDG&E’s Fire Preparedness Plan is the 10-Hour Fine Fuel (Non-Living Fuel) Moisture

16 content. The threshold for this trigger is for measured values of less than six percent and is

17 intended to provide additional confirmation that, in totality, extreme fire conditions exist. Using

18 this trigger and threshold serves to eliminate windy days immediately following heavy rain

19 where the RH might be back down, but the dead fuel moistures are still up, indicating that fuel’s

20 propensity to burn is somewhat diminished compared to a more dry condition. The 10-Hour

21 Fine Fuel (Non-Living Fuel) Moisture content is available from most RAWS locations and can

22 be associated with the SDG&E 2008 Highest Risk Fire Areas identified for de-energization.

23

24

25

#225087 SAY-21
 1 II. Fundamental Aspects of Fire Preparedness

2 Planning for emergency conditions and potential disasters is essential to maintaining

3 public safety. In the Fire Preparedness Plan, as with any major disaster plan, it is essential to

4 plan specific actions that are designed to balance the short-term impacts against the long-term

5 benefits. SDG&E began by examining available data to evaluate fire risks as they relate to the

6 electric system, identifying the most susceptible fire risk locations and then working to develop

7 methods for mitigating and monitoring the highest fire risks during extreme weather periods.

8 This process identified specific areas in SDG&E’s service territory that were particularly

9 susceptible to large scale wildland fires

10 A. Elements that contribute to fire risks across the service territory

11 SDG&E has taken additional steps to “harden” its system in fire prone areas to reduce

12 fire risks. However, under extreme fire-related weather conditions in the Highest Risk Fire

13 Areas, the only way to completely eliminate fire risks with the electrical system is to de-energize

14 exposed facilities.

15 B. Identification of highest risk fire areas in proximity of electric system

16 SDG&E began developing its base maps of fire hazards by accessing existing Cal Fire

17 data within the Fire and Resource Assessment Program (FRAP ). This was the initial data source

18 used to identify areas of fire hazard and risk within SDG&E service territory.

19 1. SDG&E Wildland Fire Area

20 The Cal Fire Hazard Severity Zone (FHSZ) map delineates fire hazards based on relevant

21 factors, such as fuels, terrain, and weather. After review of the FHSZ information, it was

22 determined SDG&E would group all moderate, high, and very high areas within the service

23 territory as identified by Cal Fire FHSZ into what would be identified as the Wildland Fire Area

24 (see Attachment B, Map 1). The basis for this decision to group all subcategories into one area

25 was that the “very high,” “high,” and the “moderate” areas each represent a legitimate fire

#225087 SAY-22
1 concern. Also, the linear nature of power lines makes it difficult to operate the electric system

2 differently as the lines pass in and out of these small distinct areas.

3 2. High Fuel Areas

4 A major component of fire risk is the amount of fuel available. Data is available from

5 Cal Fire which ranks fuel on a geographical basis. Since this data is only updated periodically,

6 SDG&E used this data as a starting point, and then modified it to exclude those areas where fires

7 burned within the last 5 years. Fires reduced the available fuel in the burn area for a period of

8 time until the vegetation grows back. Therefore, areas that have recently burned are not

9 considered to have high fuel levels. The combination of this information provides a detailed map

10 of one critical fire risk element (fuel) to help identify the higher risk areas of the “Wildland Fire

11 Area. ”

12 3. “Highest Risk Fire Areas”

13 Because the SDG&E Wildland Fire Area occupies such a large portion of the service

14 territory, and conditions vary within and across the service territory, SDG&E sought to further

15 identify a subset of the Wildland Fire Area that it considers the Highest Risk Fire Areas. This is

16 consistent with SDG&E’s objective of employing a stepped response commensurate with the

17 hazard level. These areas would be subject to the most conservative operations commensurate

18 with their potential hazard level, up to and including proactive de-energization, should conditions

19 be extreme.

20 Areas identified as 2008 Highest Risk Fire Areas (see Attachment B, Map 1) used Cal

21 Fire Fuel Rank data as the starting point for this determination. The Fuel Rank is heavily

22 weighted on the vegetation component, but includes some consideration for slope and aspect as

23 well. Using the assumption that wind is the greatest contributor associated with fire risk related

24 to utility overhead equipment, a wind corridor layer was developed. The wind corridor layer was

#225087 SAY-23
 1 based primarily on topography by identifying drainages and canyons where winds are generally

2 higher.

3 Areas where large fires had occurred less than 5 years ago were excluded from the

4 Highest Risk Fire Areas due to the limited amount of time for the vegetation to re-establish and

5 reach a critical hazard level. It was recognized that maps of the Highest Risk Fire Areas would

6 be dynamic and require updating on an annual basis to keep this vegetation and fire hazard

7 information current.

8 Certain areas with high fuel levels were excluded from being considered among the

9 SDG&E Highest Risk Fire Areas if they met one or more of the following criteria: small in size,

10 isolated, not contiguous, no history of high winds, or are located where SDG&E had no

11 significant overhead facilities. The above information was distilled down to identify two basic

12 zones of concern (the SDG&E Wildland Fire Area and subsets of that area called the Highest

13 Risk Fire Areas). They are the foundational component of SDG&E’s Fire Preparedness Plan,

14 including the already-implemented measures as well as the proposed element of proactive de-

15 energization.

16 4. Data available from weather and wind stations

17 SDG&E has chosen to monitor conditions across its service territory using a combination

18 of available instrumentation. In areas within or near the Highest Risk Fire Areas of SDG&E’s

19 service territory, Cal Fire, United States Forest Service, and Bureau of Land Management

20 operate approximately 15 Remote Automated Weather Stations (RAWS) which are distributed

21 across the rural parts of San Diego and southern Orange counties (see Attachment C, Map 2).

22 These weather stations monitor a number of factors that are critical to SDG&E’s Fire

23 Preparedness Plan. These stations are automatic and report weather data on an hourly basis, 24

#225087 SAY-24
1 hours per day, 365 days per year. Information is accessible and available to the public free of

2 charge.15

3 Specific measurements of interest as part of SDG&E’s Fire Preparedness Plan and

4 criteria for proactive de-energization include sustained wind speed, maximum wind gust speed,

5 fine fuel (non-living fuel) moisture as well as relative humidity. These parameters of interest are

6 defined below:

8 • Sustained wind speed- the average wind speed over a ten-minute period taken the last ten

9 minutes of the reporting period.

10 • Maximum gust speed- the maximum wind speed recorded over a six-second period since

11 the previous hourly report was transmitted.

12 • 10 hour fine fuel moisture- the amount of water in non-living fuel (approx. ¼ - 1” in

13 diameter) expressed as a percent of the oven dry weight of that fuel.

14 • Relative humidity- is the ratio of the amount of moisture in a given volume of air at a

15 given temperature compared to the total amount of moisture that volume of air could hold

16 at saturation, usually expressed in percent.

17 In addition to the above parameters, SDG&E is also interested in monitoring live fuel

18 moisture. The definition of live fuel moisture is as follows:

19

20 • Live fuel moisture-The amount of moisture, expressed as a percentage of weight in a

21 given living fuel sample compared to that fuel sample when oven dry.

22

15
To keep SDG&E’s customers fully-informed during critical fire conditions, SDG&E’s public Internet web site
includes a fire preparedness area at www.sdge.com/safety/fireprep, which can be easily accessed from SDG&E’s
main web site www.sdge.com. Customers may monitor weather station data and other information by using that
web site.

#225087 SAY-25
1 For SDG&E’s Fire Preparedness Plan, the live fuel moisture reading is determined by

2 taking the average of multiple live fuel moisture readings from different sources across the rural

3 parts of SDG&E’s service territory. Live fuel moisture readings are available from Cal Fire and

4 the U.S. Forest Service. Live fuel moisture readings are similar across large landscapes and

5 trend up or down slowly as plants react to seasonal precipitation or lack thereof. Measurements

6 are typically the highest toward the end of the rainy season and slowly drift lower through

7 summer and fall, typically reaching the lowest readings during late fall. The non-living fuel (10

8 hour fine fuel) moisture level is measured at the RAWS and hourly information is available.

9 SDG&E has installed 11 additional automated wind monitoring stations on existing

10 electric facilities. Preliminary data from these additional monitoring stations is currently

11 available to the weather forecasters to supplement the RAWS data. Once these additional

12 stations are calibrated and the data verified, the data collected from these additional stations will

13 be available to provide additional input for making electric system operating decisions.

14 SDG&E also monitors the U.S. National Weather Service for “red flag” weather alerts.

15 Red flag conditions are generally understood to be associated with conditions that present the

16 highest fire risk and therefore diligence and caution need to be employed to minimize chances

17 that a fire could be inadvertently ignited. A Red Flag Weather Warning is declared by the

18 National Weather Service when any of the following conditions are forecasted:

19

20 • Relative Humidity is equal to or less than 15%, with sustained winds equal to or greater

21 than 25 mph and/or frequent gusts equal to or greater than 35 mph (for duration equal to

22 or greater than 6 hours).

23 OR

24 • Relative Humidity is equal to or less than 10% (duration equal to or greater than 10

25 hours) with no associated wind criteria.

#225087 SAY-26
 1 OR

2 • Dry lightning event that is not accompanied by enough precipitation to significantly wet

3 fuels that have been identified as critically dry (the dry lightning criterion does not

4 initiate any action under the SDG&E Fire Preparedness Plan).

5
6 5. Associate circuits to weather stations for monitoring and evaluating
7 conditions in given area
8 SDG&E plotted the locations of the RAWS, using its Geographical Information System

9 (GIS) on maps of the areas SDG&E determined to be the Highest Risk Fire Areas. The electric

10 distribution system and the 69 kV circuits were also layered onto this map. And finally, the

11 weather zones used by the National Weather Service to describe the areas associated with their

12 red flag warnings were added to the map. All of this information together provided a visual

13 representation that depicts the geographical interrelationship of these foundational elements.

14 SDG&E recognizes that weather conditions can vary across its service territory. The fact

15 that the RAWS are dispersed across the rural areas of SDG&E’s service territory allows

16 monitoring of the local conditions and taking the appropriate level of action to correspond to the

17 measured conditions. This is especially important for the Highest Risk Fire Areas to ensure that

18 proper actions are taken with operation of the electric system that are commensurate with local

19 conditions.

20 SDG&E reviewed locations of the 69kV and distribution circuits in the Highest Risk Fire

21 Areas relative to the RAWS locations. Circuits in the general area of the RAWS facility were

22 linked to that facility. Operating plans were developed to take action on the specific circuits

23 associated with that weather station. If extreme weather conditions were to develop and all the

24 trigger levels were met or exceeded, then SDG&E would de-energize those circuits associated

25 with that weather station until conditions improved and the circuit could be inspected.

#225087 SAY-27
1 It should be noted that because of the fact that sectionalizing devices do not necessarily exist at

2 the boundaries of the Highest Risk Fire Areas, or for circuits that extend beyond the Highest

3 Risk Fire Areas, some customers who reside outside of the Highest Risk Fire Area will also

4 experience an outage due to proactive de-energization. A map of the areas subject to proactive

5 de-energization (see Attachment C, Map 2) and customer lists are developed based on the

6 potentially impacted circuits. Currently the Potential De-energization Areas are divided into 15

7 discrete geographic areas, each monitored by one of the 15 RAWS for the de-energization

8 triggers. It is anticipated that eventually the 11 SDG&E wind monitoring stations will allow

9 further subdivision of the discrete geographic areas to minimize the number of customers

10 impacted when the de-energization triggers are met or exceed in a specific area. This

11 information will be developed for each fire season on an annual basis as conditions change.

12 For the same reasons it is not possible to exclude customers that are served from the

13 portions of circuits that are subject to proactive de-energization. To provide service to any

14 customer would require keeping the entire portion of the circuit energized. Under an Extreme

15 Fire Condition, when all five weather triggers are met or exceeded, it would be detrimental to

16 overall public safety to keep a circuit energized in the Highest Risk Fire Areas.

#225087 SAY-28
 Attachment A

Fire Preparedness Summary Plan

#225087

Normal Operating Condition
Geographic Area
All SDG&E Service Territory
Including Wildland Fire Area
Weather Triggers
Live Fuel Moisture > 75% as
identified by Cal-Fire
Expected 6- 8 months per year
Differences in Operating
Procedures
Multiple recloser operation
cycles permitted.
Inspection only required if re-
energization attempts fail.
These guidelines and procedures are applicable to overhead electric facilities located in SDG&E's Wildland Fire Areas operated at 69,000 volts and below.
12/18/08
Elevated Fire Condition
Geographic Area
SDG&E
Highest Risk Fire Areas
Weather Triggers
Live Fuel Moisture ≤ 75%
as identified by Cal-Fire
Expected 4-6 months per year
Differences in Operating
Procedures
Recloser operation modified in
Highest Risk Fire Areas to allow
only one automatic recloser
operation cycle. Once a line
trips, the recloser is turned off
until the line is inspected and
determined to be safe. (If initial
automatic reclosing attempt fails,
the line remains de-energized
until after the line has been
inspected.)
Fire Preparedness Plan Summary
Red Flag Warning Condition
Geographic Area
SDG&E Wildland Fire Area (Which includes SDG&E
Highest Risk Fire Areas)
Weather Triggers
Live Fuel Moisture < 75%
NWS declares Red Flag Warning (for high winds or low
humidity)
Expected 15-20 days per year
Differences in Operating Procedures
All reclosers in the portion(s) of the Wildland Fire Area, in
the weather zone(s) where the Red Flag Warning is
declared, are turned off so that no automatic reclosing
attempts will be made. If a line trips, the line will remain de- have been met or exceeded.
energized until the line has been inspected and
determined safe to re-energize.
Activate EOC
Stage Crews, Helicopters and Pole Protection Vehicles
Extreme Fire Condition (Initiate proactive de-energization if all 5
weather triggers met)
Geographic Area
SDG&E Highest Risk Areas
(Limited to discrete predefined areas associated with specific Remote Automated
Weather Station)
Weather Triggers
Live Fuel Moisture ≤ 75%
NWS declares Red Flag Warning (for high winds or low humidity)
Relative Humidity < 20%
Non-Living Fuel Moisture < 6%
(Wind Spd. Sustained ≥ 35 mph) OR (Wind gusts ≥ 55 mph
accompanied with 30 mph sustained winds)
Localized exposure, Expected 0-3 days per year
Differences in Operating Procedures
Lists of customers impacted by proactive de-energization of overhead
facilities will be associated with a specific Remote Automated Weather
Station for identification of weather trigger conditions.
Proactive de-energization of Overhead electric facilities will only be
initiated in the specific discrete area(s) where all Five weather triggers
Once overhead facilities have been de-energized, they will remain de-
energized until sustained wind speeds drop below 25 mph, the overhead
facilities have been inspected, and determined safe to re-energize.
Activate EOC
Initiate customer notification procedures in the discrete Highest Risk Fire
Area(s) when it is forecast that all 5 weather triggers will be met and
proactive de-energization may occur.
Stage Crews, Helicopters, Wash Trucks & Pole Protection Vehicles
Attachment A
Page 1 of 3
 GLOSSARY FOR SDG&E'S FIRE PREPAREDNESS PLAN SUMMARY

TERMS DESCRIPTIONS
Operating Conditions A set of parameters used to define the relative Fire Risk levels at various
times throughout the year.
Normal Operating An indication that Fire Risk is at the typical, minimally expected, level for
Condition southern California; anticipated to occur 6 to 8 months a year
Elevated Fire Condition Defined as the period of time when the Live Fuel Moisture level is less than
or equal to 75%; expected to occur seasonally for 4 to 6 months a year.

Red Flag Warning Defined as the period of time when the Live Fuel Moisture level is less than
Condition or equal to 75% and the NWS has declared a Red Flag Warning for low
humidity and high wind or very low relative humidity (items 1 or 2 under Red
Flag Warning below); expected to occur for 15 to 20 days a year.

Extreme Fire Condition Defined as the period of time when the Live Fuel Moisture level is less than
or equal to 75%, the NWS has declared a Red Flag Warning for low
humidity and high wind or very low relative humidity (items 1 or 2 under Red
Flag Warning below), and winds are forecast to be greater than or equal to
35 mph sustained or 55 mph gusts (accompanied with sustained winds
greater than or equal to 30 mph); expected to occur for 0 to 3 days a year.
This is when the proactive de-energization of some circuits might occur.

Geographic Areas
SDG&E Service Territory The area of southern California where SDG&E provides electrical service.
This area includes all of San Diego and a portion of southern Orange
counties.
Wildland Fire Area Those areas within the SDG&E Service Territory designated as having a
fire Hazard Severity Zone ranking of Moderate, High and Very High as
identified by Cal Fire - Fire Hazard Severity Zone data.
Highest Risk Fire Areas Those discrete areas of the Wildland Fire Area, that have a combination of
overhead electric facilities, high fuel rank based on Cal Fire data, and
potential high winds. These areas will be re-evaluated and adjusted on a
year to year basis as fuel data becomes available.

Weather Triggers Threshold levels of monitored weather (fire risk related) conditions that
trigger certain operational actions.
Live Fuel Moisture The amount of moisture, expressed as a percentage of weight in a given
fuel sample compared to that fuel sample when oven dry. Live fuel
moisture readings are available from Cal Fire and the U.S. Forest Service.
Live fuel moisture readings are similar across large landscapes and trend
up or down slowly as plants react to seasonal precipitation.
NWS National Weather Service
Red Flag Warning A weather condition declared by the National Weather Service if (1) the
relative humidity is less than or equal to 15% accompanied by sustained
winds greater to or equal to 25 mph and/or gusts equal to or greater than 35
mph (for a duration of 6 hours or greater), (2) relative humidity is less than
or equal to 10% (for a duration equal to or greater than 10 hours, OR (3)
Dry Lightning event that is not accompanied by enough precipitation to
significantly wet fuels that have been identified as critically dry.

Attachment A
12/18/08 Page 2 of 3
 GLOSSARY FOR SDG&E'S FIRE PREPAREDNESS PLAN SUMMARY

TERMS DESCRIPTIONS
Weather Triggers (Continued)
Non-living Fuel Moisture The amount of moisture in non-living fuel (small twigs and braches)
or 10 Hour Fine Fuel expressed as a percentage of the oven dry weight of that fuel. The Non-
Moisture Living Fuel Moisture is monitored at the Remote Automated Weather
Stations.
Sustained Wind Speed The average wind speed over a ten minute period taken the last ten
minutes of the reporting period. Transmitted from Remote Automated
Weather Station.
Relative Humidity (RH) Relative Humidity is the ratio of the amount of moisture in a given volume of
air at a given temperature as compared to the total amount of moisture that
volume of air could hold at saturation usually expressed as a percentage.
The RH is monitored at the Remote Automated Weather Stations.

Wind Gusts The maximum wind speed recorded over a six second period since the
previous hourly report was transmitted from the Remote Automated
Weather Station.
Remote Automated Remote weather stations operated by Cal Fire, US Forest Service, or the
Weather Stations Bureau of Land Management located in or near Highest Risk Fire Areas
(RAWS) that automatically report hourly weather data electronically.

Differences in Operating Highlights the more conservative practices that are used to progressively
Procedures address the increased fire risks brought about by environmental changes.

Reclosers Devices used to automatically control electrical switches. They operate

automatically attempting to re-energize electric lines that were de-energized
automatically (tripped) due to unusually high power flow. Reclosers are
critical in maintaining system reliability and minimizing outages to large
numbers of customers when the high power flow is only temporary or when
individual components of a circuit fail and are automatically disconnected
from the circuit.

EOC SDG&E's Emergency Operations Center is a special facility with advanced

communication facilities where representatives from SDG&E's Operating,
Maintenance, Engineering, Customer Service, Communications and
Regulatory areas meet to coordinate operations and communicate with
external public safety organizations during emergencies.

Inspection Physical inspection (by ground or air) of the entire overhead facility to
determine that the line is safe to energize and assure that there is no
damage that needs to be repaired.

Attachment A
12/18/08 Page 3 of 3
 Attachment B

Map 1, 2008 Wildland Fire Area

#225087
 Attachment C

Map 2, 2008 Potential De-energization Area

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