Energy Safety details changes in second draft of WMP update requirements; written comments due Nov. 21

The Office of Energy Infrastructure Safety on Nov. 17 presented a second draft of proposed changes to its Wildfire Mitigation Plan (WMP) update requirements, outlining clarifications for data submissions, reporting thresholds and page limits ahead of a comment deadline.

Dakota Smith, Supervisor, Electrical Safety Policy Division, said the workshop reviewed "the second draft of the WMP update requirements chapter, which we are proposing to be chapter 6 of the WMP guidelines," and invited stakeholders to submit written comments by 5 p.m. Friday, Nov. 21. "Written comments must not exceed 10 pages," Smith said during the virtual session.

The presentation, delivered in part by Tim Tutte, listed substantive modifications Energy Safety made in response to utility comments and questions from a Sept. 4 workshop. Tutte said the second draft clarifies that "the standard data and geospatial files are required" for update submissions and that those files must be updated from previous versions to reflect changes in the WMP update and submitted to the expected portals.

Key clarifications and changes in the second draft include:

- Reportability and exceptions: The draft reiterates that reportable updates generally focus on the update year but lists exceptions, including new or discontinued program reporting required for all years in the WMP cycle, and that new electrical undergrounding plan disaggregation applies for any year for which it is relevant. Downstream impacts of reportable updates remain required for subsequent years.

- Page limits: Energy Safety increased the overall page limit for the "areas for continued improvement" section from 20 pages to 30 pages to allow flexibility for topics that require more detail. The page limit for new and discontinued program reporting was raised from 15 pages to 20 pages.

- Risk-model reporting: The draft standardizes use of the phrase "top 20% circuits" to mean the riskiest 20% of a utility's circuits when modified by a reportable risk-model update. In Table 2-1, the summation of risk for the top 20% is now simplified to add up to 20% rather than 100% to ease calculation and evaluation.

- Qualitative targets: Energy Safety narrowed the circumstances when qualitative target updates are reportable. Only changes that move a completion date into the update year (from a prior year) are reportable; other timing shifts that remain within the update year or occur fully outside it are not reportable.

- Electrical undergrounding disaggregation: To align with newly adopted electrical undergrounding plan guidelines, the draft requires undergrounding information be disaggregated between initiatives and activities that derive from an Energy Safety-approved Electrical Undergrounding Plan (EUP) and those that do not.

- Approved-targets tables and substantive typos: The required format for approved-targets tables should match corresponding tables in the previously approved base WMP. Substantive typos in tables and figures are reportable only when the error would materially affect Energy Safety's evaluation of the update.

- Clean base WMP timing: The draft clarifies that a clean base WMP is not required at initial update submission but is required after an Energy Safety decision; the clean base WMP must be submitted within 10 days of that decision.

Tutte emphasized these are changes in the second draft and part of the public-comment process rather than final agency decisions. "We will be highlighting the notable changes from the first draft," he said during the presentation.

The webinar included instructions for verbal questions and chat participation; the presenters paused for questions but reported none were offered during the session. Smith said slides and a recording would be posted in the days following the workshop.

Next steps: stakeholders may file written comments limited to the red-line changes in the second draft and not to exceed 10 pages (attachments excluded) by 5 p.m. Friday, Nov. 21, to the guidelines docket referenced in the workshop materials.