Reading between the lines with PG&E’s filing with Judge Alsup

With PG&E’s Monday filing to Judge Alsup regarding its role in starting the Fly and Dixie Fires, it is key to pay attention to what the filing doesn’t say. Nowhere in the filing does PG&E claim ever performing enhanced vegetation management on the spans of distribution circuit suspected to be involved in starting the Dixie or Fly Fire. Not in 2019, 2020, or 2021. Both received one enhanced equipment inspection–in 2019 for Dixie and 2021 for Fly–but neither received enhanced vegetation inspections.  Only routine vegetation management.

The difference between routine vegetation inspections and enhanced vegetation inspections is critical, especially for distribution lines in wildfire prone locations. And both spans of circuit are in high wildfire prone locations.

To evaluate which equipment is most at-risk for igniting a wildfire, PG&E starts by identifying circuits that are located in Tier 2 or 3 High Fire Threat Districts (“HFTDs”). HFTDs are geographic districts that are at elevated risk for wildfires generally due to historic fire patterns, geographic and weather conditions, etc. After all Tier 2 and 3 circuits have been identified, PG&E uses an internal risk model to rank smaller segments of each circuit within those districts by which spans are at greatest risk for igniting wildfires.

PG&E’s filing reveals that the span of circuit where the Dixie Fire is believed to have started is “ranked 11 out of 3,635 circuit sections” for potentially igniting a fire due to equipment failure. And more importantly, it is “ranked 568 out of 3,074” for tree contact leading to a fire, “as apparently happened here” says PG&E. This means it was in the top 20% out of all of PG&E’s distribution assets in Tier 2 and Tier 3 HFTD’s for igniting a wildfire by means of tree contact with line. And yet, PG&E did not perform enhanced vegetation management on the line.

Noticeably absent from PG&E’s filing is the wildfire risk ranking of the span of circuit involved in the Fly Fire. But PG&E’s GIS data, which it files with the CPUC, reveals it is in a Tier 2 HFTD, which is the second highest threat for wildfires after Tier 3. But PG&E failed to perform enhanced vegetation management there as well.

So what is the difference between enhanced vegetation management and the routine vegetation patrols and CEMA patrols that PG&E claims to have actually performed in the filing? According to another recent court filing by PG&E, routine vegetation management patrols just “identify and prescribe work necessary to maintain compliance with regulatory requirements”. CEMA patrols “identify and prescribe the removal or trimming of dead, dying or diseased trees.”

But routine patrols and CEMA patrols were not cutting it in the past to prevent wildfires. That is why PG&E is supposed to target its wildfire prone assets for enhanced inspections.

PG&E’s website explains that enhanced vegetation management is “[i]n response to the growing risk of wildfire in our state”, and “[o]ur focus will be on addressing vegetation that poses a higher potential for wildfire risk in high fire-threat areas”. “This work is one of many additional precautionary measures implemented following the 2017 and 2018 wildfires as part of our comprehensive Community Wildfire Safety Program.”

Plus, the “Enhanced Vegetation Management (EVM) program involves multiple steps to help further reduce the risk of trees, limbs and branches from coming into contact with power lines in high fire-threat areas”, including “overhanging limbs and branches directly above and around the lines”, as well as “the condition of trees that may need to be addressed if they are tall enough to strike the lines.”

According to PG&E’s 2019 Wildfire Mitigation Plan, “over the last five years the maximum number of trees removed by PG&E’s drought and tree mortality CEMA program was approximately 225,000 trees”, but “in 2019, the EVM [or Enhanced Vegetation Management] program is anticipating trimming or removing approximately 305,000 trees while the CEMA program will still be in effect and is forecast to work approximately 70,000 trees.”

The PG&E website provide this helpful graphic for the public to understand the difference in scope between routine inspections and enhanced inspections:

While it is unclear at this time which exact trees failed and made contact with each span of line that resulted in the Dixie and Fly Fires, it is clear that if PG&E took wildfire safety seriously, it would have performed enhanced vegetation management on both spans. That is the promise its website, ads, and wildfire mitigation plans make. But it keeps falling short of that promise. All while other people’s homes and livelihoods are being destroyed.

PG&E provided August 2019 drone photographs in its filing of where it believes the Dixie Fire started, saying the tree fell “between the pole supporting Fuse 17733 and the next pole … downhill from Fuse 17733.” Several of the photos clearly show a huge dead tree within striking distance of the line. And yet PG&E claims the photo was taken only one month after one of their contractors had performed routine “tree work” at the scene. No later drone photographs were provided so it is unknown whether that dead tree was still there at the time of the Dixie Fire. But this is a perfect example of why PG&E’s routine vegetation inspections just aren’t cutting it.

Alison Cordova is a retired attorney who was part of lead counsel that took on PG&E for the 2015 Butte Fire, 2017 North Bay Fires, and 2018 Camp Fire.