The Office of Energy Infrastructure Safety on Monday presented the second draft of proposed update requirements for Wildfire Mitigation Plans, explaining substantive clarifications that utilities requested and setting a written-comment deadline of 5 p.m. on Friday, Nov. 21.

Dakota Smith, identified in the workshop as a supervisor in the office’s Electrical Safety Policy division, opened the virtual session and said the draft would be proposed as Chapter 6 of the WMP guidelines. Smith said the office made changes based on joint-utility comments, questions from an earlier Sept. 4 workshop, pre-submitted questions and internal review, and to reflect newly adopted electrical undergrounding regulations.

Tim Tutte, a presenter at the workshop, reviewed the draft’s substantive changes. He said standard data and geospatial files must accompany any WMP update submittal and must be updated from previous versions to match the changes in the update and be submitted to the expected portals. The draft also clarifies exceptions to the general focus on the update year: reporting for new or discontinued programs is required for all years in a WMP cycle, and disaggregation for electrical undergrounding applies whenever it is relevant in the cycle.

The office adjusted several page limits after utility feedback: the "areas for continued improvement" section limit was increased from 20 pages to 30 pages, and the new-and-discontinued-programs section limit was raised from 15 pages to 20 pages. The draft retains an overall section limit rather than separate per-area caps, the office said, to preserve flexibility for lengthy explanations in particular areas.

On risk modeling, the draft consistently uses the term "top 20% circuits" to mean the riskiest 20% of an electrical corporation's circuits. Table 2‑1 was simplified so that the summation of risk values for that top 20% adds to 20% (rather than 100%), which the office said should make the calculations easier to produce and evaluate.

The office narrowed the circumstances under which qualitative-target changes are reportable: only updates that move a qualitative target’s completion date from a prior year into the update year (or move completion into a subsequent year) are reportable. Other interim changes that do not affect completion dates remain non‑reportable.

The second draft adds a requirement to disaggregate undergrounding information between initiatives that derive from an office‑approved Electrical Undergrounding Plan (EUP) and activities not part of such a plan. The draft also states that substantive typos in tables and figures are reportable only if the error would materially affect the office’s evaluation of the update.

Regarding the clean base WMP, the presenters said a clean base plan is not required on initial submission; it is required only after the office issues a decision on an update, and the required clean base WMP must be submitted within 10 days of that decision being received or published.

The presenters opened the floor to public questions but reported no verbal questions. Dakota Smith closed by reminding stakeholders that written comments must be limited to the redline changes in the published second draft, must not exceed 10 pages (attachments excluded), and must be filed to the guidelines docket by 5 p.m. on Friday, Nov. 21. The office said it will post the slides and a recording in the coming days.

The office did not take formal votes at the workshop; the session was an informational presentation and public-comment opportunity. The next procedural step is the written-comment period, after which the office may revise the draft and proceed toward an adoption decision.