Docket No. UE 374 Exhibit PAC/2900 Witness: David M. Lucas ...€¦ · Lucas/3 Reply Testimony of David M. Lucas 1 Q. Please describe the Coastal region. 2 A. The Coastal region is

Docket No. UE 374 Exhibit PAC/2900 Witness: David M. Lucas

BEFORE THE PUBLIC UTILITY COMMISSION

OF OREGON

PACIFICORP

___________________________________________________________

Reply Testimony of David M. Lucas

June 2020

PAC/2900 Lucas/i


TABLE OF CONTENTS

I. PURPOSE ..................................................................................................................... 1

II. VEGETATION DIVERSITY ........................................................................................ 2

III. WILDFIRE MITIGATION ........................................................................................... 5

A. Wildfire Risk ............................................................................................................ 5

B. Wildfire Mitigation Plan ........................................................................................... 6

Location of Wildfire Mitigation Measures .......................................................... 6

Metrics ................................................................................................................. 7

Covered Conductor .............................................................................................. 8

Independent Evaluator ....................................................................................... 11

IV. VEGETATION MANAGEMENT .............................................................................. 12

V. CONCLUSION ........................................................................................................... 24

ATTACHED EXHIBITS

Exhibit PAC/2901—PacifiCorp’s Fire High Consequence Areas and Wildfire Mitigation Measures

Exhibit PAC/2902—Southern California Edison’s Covered Conductor Presentation–California Public Utilities Commission’s February 27, 2019 Workshop

PAC/2900 Lucas/1


Q. Are you the same David M. Lucas who previously provided direct testimony in 1

this case on behalf of PacifiCorp d/b/a Pacific Power (PacifiCorp or the 2

Company)? 3

A. Yes. 4

I. PURPOSE 5

Q. What is the purpose of your reply testimony? 6

A. My testimony responds to wildfire mitigation and vegetation management concerns 7

raised in the opening testimony of Public Utility Commission of Oregon 8

(Commission) Staff witness Mr. Mitchell Moore and the Alliance of Western Energy 9

Consumers’ (AWEC) witness Mr. Bradley G. Mullins. 10

Q. How is your testimony organized? 11

A. My testimony is structured as follows: 12

In Section II, I provide a description of the vegetation diversity within the 13

Company’s service territory. 14

In Section III, 15

I rebut AWEC witness Mr. Mullins’s suggestion that the current 16

wildfire risk discussed in my direct testimony is a “long-standing and 17

well known risk.”1 and describe how, consistent with Oregon 18

Governor Kate Brown’s Executive Order 19-01, the level of risk has 19

increased and the Company must respond in order mitigate the risk of 20

wildfire from its facilities. 21

1 AWEC/100, Mullins/25.

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I respond to Commission Staff witness Mr. Moore’s concerns related 1

the Company’s proposed capital spend for wildfire mitigation 2

activities and the use of metrics to evaluate the efficacy of these 3

measures. I explain how the Company identifies where the 4

investments will be deployed, the benefits of using covered conductor, 5

and how the efficacy of these measures will be evaluated over time as 6

data is gathered. I also address Staff’s recommendation for the use of 7

a third party evaluator for assessing the Company’s wildfire mitigation 8

plan. 9

Finally, in Section IV, I respond to Staff witness Mr. Moore’s concerns 10

related the Company’s vegetation management practices and describe the 11

Company’s strong commitment to improve its vegetation management 12

program. I also describe why the Company has increased the amounts it is 13

requesting for vegetation management operations and maintenance (O&M) 14

costs in this rate case. 15

II. VEGETATION DIVERSITY 16

Q. Please describe the vegetation diversity of PacifiCorp’s Oregon service territory. 17

A. Oregon is a state with great vegetative and climatic diversity. At the macro-level, 18

Oregon can be divided into nine Level III ecoregions; areas of similar climate and 19

vegetation. PacifiCorp’s service territory coarsely aligns with several of these 20

ecoregions and may similarly be divided into geographic regions for discussion as 21

follows: Coastal, Central, Eastern, Northern, Willamette Valley, and Southern. 22

PAC/2900 Lucas/3


Q. Please describe the Coastal region. 1

A. The Coastal region is characterized by mountainous and undulating terrain in and 2

around load centers. High precipitation rates coupled with a moderate local climate 3

promote vegetation growth and less vegetation moisture stress resulting in dense 4

vegetation in this region. The Coastal region provides very favorable conditions for 5

fast growing tree species. Heavy seasonal rains mixed with warm summers provides 6

conditions conducive to increased tree growth. 7

Q. Please describe the Central region. 8

A. The Central region vegetation growth is influenced by the proximity of the Cascades 9

to the west, which results in adequate water availability and relatively high stream 10

density. This promotes growth; however, the area is still susceptible to prolonged 11

drought conditions resulting in stressed trees, tree mortality and hazard tree concerns. 12

Many of the portions of the Company’s territory in the Central region, where 13

vegetation management activities take place, are characterized by high desert 14

rural/urban interface. Irrigated trees growing in expanding urban interfaces combined 15

with ample sunshine results in favorable growing conditions for trees and other 16

vegetation in these areas. 17

Q. Please describe the Eastern region. 18

A. The Eastern region is highlighted by mountain, valley, and plateau complexes. 19

Similar to the Central region, in the populated areas of the Eastern region, irrigated 20

vegetation results in favorable growing conditions for trees and other vegetation in 21

these areas. 22

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Q. Please describe the Northern region. 1

A. The Northern region is a densely populated area coupled with high tree density of 2

moderate to fast growing species where pruning rather than removal is required. 3

Q. Please describe the Willamette Valley region. 4

A. The Willamette Valley region varies from rural to highly urban interfaces. Fertile 5

soils, ample water and sun availability promote vegetation growth in this region. 6

Certain portions of this area have actively farmed tree crops, i.e. nut crops, which 7

influences the manner in which vegetation management is conducted. 8

Q. Please describe the Southern region. 9

A. The Southern region is characterized by drought conditions, high tree density and 10

hazard trees. There is a very high volume of hazard trees (dead or declining trees) 11

resulting from drought-stress and wood-infesting beetles in this area. The urban areas 12

of this region also include irrigated fast growing species. 13

Q. Why is the vegetation diversity of PacifiCorp’s service area important? 14

A. Unlike other electric utilities which may have only one or two Level III ecoregions in 15

their service area, PacifiCorp operates in several ecoregions. Having an 16

understanding of the diversity of the vegetation within the Company’s service area 17

provides valuable context for the Company’s wildfire mitigation activities and 18

vegetation management. 19

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III. WILDFIRE MITIGATION 1

A. Wildfire Risk 2

Q. AWEC witness Mr. Mullins states wildfires are a “long-standing and well known 3

risk” and uses that reasoning to support his recommendation to reject the 4

recovery of capital costs associated with the Company’s wildfire mitigation 5

efforts as outline in the direct testimony of Ms. Etta Lockey. How do you 6

respond? 7

A. I agree with Mr. Mullins that wildfire is a known risk. However, just because 8

something is a “known risk,” does not mean the level of risk is known or that the 9

level of risk today will be the same as tomorrow. 10

Q. Please elaborate. 11

A. As stated in my direct testimony, “the frequency, severity, and costs of catastrophic 12

wildfires are increasing across the West.”2 While wildfire is a known risk, the level 13

of risk has changed. Governor Brown recognized this increased wildfire risk when 14

she issued Executive Order 19-01, stating: 15

Each wildfire season presents new challenges. Changes in 16 climate—including increased temperatures, changing 17 precipitation patterns, decreased winter snowpack, and 18 increasingly prevalent droughts and heat waves—mean that 19 wildfire season is starting earlier, burning hotter, and lasting 20 longer each year. As a result, we must proactively review our 21 systems to determine whether our current models are 22 sustainable, require enhancement, or require a different 23 approach to minimize fire impacts. 24

2 PAC/1100, page 2:19-20.

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B. Wildfire Mitigation Plan 1

Q. Did any witness raise issues related to the Company’s wildfire mitigation plan? 2

A. Yes, Staff witness Mr. Moore. 3

Q. What issues did Mr. Moore raise? 4

A. Mr. Moore noted the following issues in his testimony, which I will address: 5

The Company did not provide a map or other detail to explain where its 6 wildfire mitigation measures will be implemented; 7

There are no metrics to demonstrate the effectiveness of the measures; 8 It is not clear that the benefits of covered conductor outweigh the costs; and 9 An independent evaluator should be engaged to assess the implementation and 10

efficacy of wildfire mitigation measures. 11

Location of Wildfire Mitigation Measures 12

Q. Mr. Moore claims in his testimony that the Company did not provide 13

information related to where the proposed wildfire mitigation measures would 14

be implemented. Is that true? 15

A. No. A map of the service territory with the Fire High Consequence Areas (FHCA) 16

was provided in Exhibit PAC/1101 with my direct testimony. The map identifies the 17

primary area where the wildfire mitigation measures will be implemented, though not 18

with the level of granularity that was requested by staff through discovery. 19

Q. Can the company provide additional insight into how investments will be 20

deployed within FHCAs? 21

A. As mentioned in previous testimony, the Company is in the beginning stages of 22

scoping and design to identify a number of sub-areas within the broader FHCA. See 23

Exhibit PAC/2901 for additional details regarding initial scope, sequence and 24

technology to be deployed by PacifiCorp. This process is ongoing and iterative, 25

meaning the Company expects there will be changes to the infrastructure where 26

PAC/2900 Lucas/7


mitigation efforts are planned as more and more information is gathered, and as 1

conditions on the ground change. 2

Metrics 3

Q. Mr. Moore voiced concern with the lack of metrics to quantify the effectiveness 4

of the Company’s proposed wildfire mitigation measures. How do you respond? 5

A. Staff has misinterpreted my testimony. In my testimony I noted that evaluating the 6

efficacy of the measures would need to occur over time as the necessary data is 7

gathered. I address this misinterpretation with respect to covered conductor below, 8

but the misunderstanding appears to stem from two separate concepts. One is the 9

evaluation of what mitigation measures to select, which the Company has gathered 10

information on to determine what investments to make and where. The other concept 11

is determining what tools exist to evaluate the performance of the Company’s chosen 12

measures over time, and this is what staff misinterprets. 13

Q. Did Mr. Moore suggest any metrics to quantify the efficacy of the mitigation 14

measures proposed by the Company? 15

A. No, he did not. 16

Q. Are you aware of any Oregon Administrative Rule or Oregon Revised Statute 17

that identifies specific metrics utilities should use to quantify the efficacy of 18

wildfire mitigation measures they implement? 19

A. No. However, the Company is aware that Commission workshops on wildfire 20

mitigation plans have been proposed and we intend to be active participants and 21

welcome developing reasonable and meaningful metrics to track how effective the 22

measures are. It is in the Company’s interest to consistently measure, analyze and 23

PAC/2900 Lucas/8


revise its wildfire mitigation tools to ensure that future investments are tailored to the 1

best available information at the time. Again, wildfire risk is a dynamic problem that 2

cannot be solved with overly static plans. 3

Covered Conductor 4

Q. Mr. Moore voiced concerns that the benefits of covered conductor may not 5

outweigh the costs. Can you explain your perspective? 6

A. Yes. While there is not yet sufficient Company data available to present metrics on 7

covered conductor, there is good evidence that when used in the right areas, covered 8

conductor can be an effective tool to mitigate wildfire risk. The benefits of covered 9

conductors are not limited to vegetation contacts, it also protects against other types 10

of “incidental contacts.” As is well recognized, incidental contact can be the result of 11

vegetation “blow-in” or “fall-in”, but covered conductor also addresses contact from 12

other objects, such as animals or Mylar balloons. It is also more resilient than bare 13

conductor to the effects of weather that could cause one phase conductor contacting 14

another phase conductor. These are all features of covered conductor that the 15

Company used to evaluate whether and where to use this mitigation measure on its 16

system in Oregon. 17

Q. Are a large percentage of faults associated with these “contacts”? 18

A. Yes. PacifiCorp’s records indicate that 34 percent of outages are related to some form 19

of contact. Of that, approximately 57 percent are associated with vegetation. 20

Q. Does this level of vegetation contact create concerns? 21

A. All types of line contacts cause concern; however, during abnormal weather 22

vegetation contact is not unusual. Wind causes trees to move, sometimes 23

PAC/2900 Lucas/9


dramatically, with branches that are at rest, well within proper clearances. Also, these 1

winds can break branches, resulting in the blow-in risk mentioned previously. 2

Q. Does the Company have any data or information to support covered conductor 3

is an effective wildfire mitigation measure? 4

A. The Company does not have a large historical dataset demonstrating the effectiveness 5

of covered conductor in preventing ignitions. However, numerous studies exist 6

including recent studies by other Western utilities that provide strong evidence 7

covered conductor greatly reduces ignition risk from incidental contact including 8

contact by vegetation. See Exhibit PAC/2902 for an example of a study conducted in 9

California demonstrating the benefits of covered conductor to mitigate ignition risk. 10

Q. Do the distribution system construction alternatives listed on page 26 of 11

Exhibit PAC/2902 represent the Company’s system? 12

A. Yes. It is generally recognized that three alternatives exist for constructing 13

distribution systems. Bare conductor, covered conductor or undergrounding of the 14

system in order of lowest to highest cost. 15

Q. Does the Company anticipate achieving similar fault reduction effectiveness as 16

described on page 27 of Exhibit PAC/2902? 17

A. Yes. Compared to the other alternatives, PacifiCorp anticipates seeing similar 18

incremental benefits relative to bare conductor greatly reducing the probability of 19

ignition sources resulting from contacts. 20

Q. Does the cost comparison of alternatives listed on page 28 of Exhibit PAC/2902 21

reflect the cost of construction on the Company’s system? 22

A. The actual cost per mile, while not exactly the same, is representative of the relative 23

PAC/2900 Lucas/10


differences in construction costs on the Company’s system. Meaning covered 1

conductor has the greatest effectiveness per dollar spent relative to other alternatives 2

in mitigating contact ignition sources. 3

Q. Has the use of covered conductor been approved by other Commissions as a cost 4

effective mitigation strategy in other utility wildfire mitigation plans? 5

A. Yes. All three large investor owned utilities in California include significant 6

investments in covered conductor installation due to its effectiveness in mitigating 7

incidental contact ignition sources. 8

Q. Did Mr. Moore provide any alternatives to installing covered conduit? 9

A. Yes. Mr. Moore suggested that partnering with landowners, such as the U.S. Forest 10

Service and Bureau of Land Management, to address vegetation concerns could be an 11

alternative to installing covered conduit. 12

Q. Do you agree with Mr. Moore that partnering with landowners is important? 13

A. Yes, Mr. Moore is correct. PacifiCorp and all landowners need to be mindful of the 14

risks that vegetation can pose to the electric system, whether the conductor is bare or 15

covered. PacifiCorp has and will continue to work collaboratively with landowners 16

to actively manage this risk. 17

Q. Mr. Moore asserts that partnering with landowners is an alternative to installing 18

covered conductor. Is that a reasonable assertion? 19

A. No. Mr. Moore implies that tree removal is an equivalent alternative to covered 20

conductor and that wildfire risk is limited to where the Company’s assets are located 21

on federal land. Ignition risk from incidental contact is much broader and exists 22

across the entire land ownership continuum that includes, federal, state, municipal 23

PAC/2900 Lucas/11


and private land ownership. Equally if not more important is that mitigating tree fall-1

in risk requires always being able to select the right risk tree, and somehow ensuring 2

that windborne branches that detach from trees do not make contact with lines. As I 3

discuss above, blow-in, fall-in and other contact risks are greatly mitigated by 4

covered conductor. While it is an important element of wildfire mitigation efforts, 5

partnering with the U.S. Forest Service and landowners to remove more danger trees 6

is not a suitable alternative to covered conductor. 7

Independent Evaluator 8

Q. Mr. Moore proposes an independent evaluator for assessing the implementation 9

of PacifiCorp’s wildfire mitigation program. Does the Company agree with this 10

proposal? 11

A. It depends on what the independent evaluator’s scope is. The Company appreciates 12

the suggestion of utilizing an independent evaluator to assess implementation of its 13

wildfire mitigation program, and there may be merit in utilizing one if the scope of 14

their duties is properly focused. Proper scoping is critical, because there is no single 15

independent expert available today that has the necessary skillsets to address the full 16

scope of utility wildfire mitigation planning. Instead, that skill set is still in 17

development. The Company has experience with this issue in California. 18

If an independent evaluator requirement is imposed it should be prospective 19

only to avoid delay of implementation of measures in the near term. Requiring an 20

independent evaluator to review the Company’s nearer term wildfire mitigation 21

efforts may slow those efforts and increase the period of exposure to greater risk to 22

lives, customer property and damage to company facilities that result from wildfires. 23

PAC/2900 Lucas/12


Q. Is the Company willing to assess with Staff the use of third party evaluator(s) for 1

specific elements of the Company’s wildfire mitigation plan? 2

A. Yes. The Company is willing to engage in scoping discussions with the Commission 3

Safety Staff regarding key elements of the plan. I noted above that the Commission is 4

planning wildfire mitigation plan workshops, and these may be the ideal venue to 5

discuss how best to employ an independent evaluator to review utility wildfire 6

mitigation plans. 7

IV. VEGETATION MANAGEMENT 8

Q. What topics will you be addressing in this section? 9

A. In this section of my testimony, I address the Company’s vegetation management 10

program and the increase to vegetation management costs included in the Company’s 11

rebuttal filing. 12

Q. Staff witness Mr. Moore’s testimony states that utilities have an obligation under 13

Oregon law to maintain a robust vegetation management program to prevent 14

contact with electrical conductors and eliminate electrical faults as a source of 15

fire ignition. Do you agree with Mr. Moore that vegetation management is a key 16

component to wildfire risk mitigation? 17

A. Yes. Vegetation contacts with energized conductors can be a source of fire ignition. 18

It is also absolutely true that vegetation management is an important element of any 19

electric utility’s wildfire mitigation efforts, just as it is in the Company’s plan I 20

presented in my direct testimony. While important, there are other important factors 21

that should be considered in wildfire mitigation programs too. Sparks or embers 22

falling into vegetation beneath utility poles can also be a source of ignition and can 23

PAC/2900 Lucas/13


result from third-party damage, foreign objects including Mylar balloons, wildlife and 1

equipment failure. 2

Q. Do you agree with Mr. Moore’s statement that Oregon law imposes an obligation 3

on utilities to maintain robust vegetation management programs? 4

A. Yes. Oregon law imposes specific vegetation management obligations on utilities 5

operating in the state.3 I would note that many of those requirements were developed 6

years ago, and since their development the potential risks and costs of wildfires has 7

grown dramatically. 8

Q. Does PacifiCorp maintain a robust vegetation management program designed to 9

comply with existing Oregon requirements? 10

A. Yes. For many years now, PacifiCorp has maintained a detailed vegetation 11

management program to assist its foresters and vegetation management contractors in 12

achieving compliance to Oregon’s legal standard. However, at the same time, 13

industry practice is changing as it is becoming increasingly apparent that heightened 14

focus on vegetation management activities, especially in higher risk areas, is required 15

in light of greater wildfire risk in the West. 16

Q. Please describe the goals of PacifiCorp’s vegetation management program? 17

A. The program mission is to manage trees and vegetation around PacifiCorp’s 18

transmission and distribution facilities in a professional, cost effective and 19

environmentally conscientious manner to provide safe and reliable service to our 20

customers. PacifiCorp’s goal is to responsibly balance the various elements of its 21

mission. One example of its longtime responsible stewardship is that PacifiCorp has 22

3 OAR 860-024-0016.

PAC/2900 Lucas/14


been a Tree Line USA recipient utility every year since 2002. Tree Line USA is an 1

award from the National Arbor Day Foundation, which recognizes utilities for 2

utilizing practices that protect America’s urban forests. To qualify, utilities must 3

apply scientifically-based tree care, conduct annual worker training, plant trees, and 4

conduct public education, including participating in Arbor Day celebrations. 5

Q. How is PacifiCorp’s vegetation management program designed? 6

A. PacifiCorp’s vegetation management program is structured as a comprehensive effort 7

involving multiple departments and data analysis. The plan is coordinated on an 8

individual circuit basis to address reliability performance and compliance. The 9

execution of the actual tree work is managed by the Vegetation Management 10

department utilizing a staff of International Society of Arboriculture certified arborists 11

and certified utility specialists, contract arborists, and tree pruning and removal 12

contractors. The program covers all distribution and transmission wires, with 13

scheduling occurring on the basis of a circuit-specific cycle and interim based 14

pruning; while in Portland the facilities are organized on a grid basis due to the 15

significant circuit interconnections. 16

There are two key aspects of the program. First, the program includes an 17

established prune cycle to ensure that all circuits are pruned at least once every four 18

years. The Company also uses reliability-based prioritization methods and 19

inspections to identify the need for interim-cycle pruning or other corrective actions 20

on a proactive basis. Second, the Company conducts hazard tree removal through the 21

program, which is coordinated with the cycle-pruning schedule. Hazard trees are 22

identified and targeted for removal subject to obtaining appropriate consents for 23

PAC/2900 Lucas/15


removal in accordance with state or federal law. In addition, “risk” trees are 1

identified on all circuits scheduled for cycle pruning and are targeted for removal. 2

Reliability performance and periodic surveys to evaluate the overall safety of the 3

circuit occur to identify hazard trees on “off-cycle” circuits to mitigate poor 4

performing circuits. 5

The execution of the actual tree work is completed by tree pruning and 6

removal contractors. 7

Q. Earlier in your testimony you described the nine ecoregions in PacifiCorp’s 8

service territory. Are there unique challenges associated with vegetation 9

management in those regions? 10

A. Yes, certainly. 11

Q. Please describe the challenges for each region. 12

A. Each region presents unique challenges associated with vegetation 13

management. 14

Coastal: The features of this environment results in conditions that make it 15

very challenging to manage inventory and address fast growing species throughout 16

the growing season. The Coastal region also has access challenges. For example, 17

many areas cannot be accessed to conduct vegetation management activities during 18

certain times of the year due to the wet conditions and steep and potentially unstable 19

terrain. Additionally, the tourist season creates logistical challenges due to the 20

increased traffic and the increased coordination required to complete the work in and 21

around coastal towns. Further complicating logistical challenges, vegetation work 22

PAC/2900 Lucas/16


along roads and highways may be restricted by regulatory entities to certain times of 1

the year to minimize impacts to travelers. 2

Central: Similar to the tourist season challenges in the Coastal regions, 3

continued population growth in the urban/rural interfaces in the Central region has led 4

to increased traffic control associated with vegetation management work in the area. 5

Eastern: Similar to the Central region, in the populated areas of the Eastern 6

region, irrigated vegetation influences vegetation management activities. Logistical 7

and seasonal changes in this region also present significant challenges. The Eastern 8

region is also spread-out in terms of line miles that need to be addressed. Vegetation 9

management activities are made more difficult due to the winter weather conditions 10

that occur in this region. The winter weather provides a shorter work window 11

compared to other regions. Because the Eastern region is more remote and sparsely 12

populated, acquiring local crew resources to conduct the work in this region is also 13

more difficult. 14

Northern: Logistical challenges in some areas in the City of Portland have 15

become increasingly problematic over the years due to traffic control and parking 16

issues. For example, the Company has experienced more access problems in areas 17

where new apartments have been built without parking for residents. Other 18

challenges in the Northern region relate to its more urbanized characteristics. For 19

example, the Company must address individuals camping underneath the wires and 20

along the rights of ways to access them for vegetation management activities, and the 21

reduction of multilane roads to single lane requires greater traffic control and results 22

in decreased productivity. 23

PAC/2900 Lucas/17


Willamette Valley: Urbanization has resulted in higher population densities, 1

which increases logistical challenges due to increased traffic control needs. Traffic 2

obstruction scrutiny and permit acquisition has increased from local municipalities 3

delaying when vegetation may be addressed from public rights of way. Drought 4

stressed trees in the forested edges of the Willamette Valley region result in a high 5

volume of hazard trees. Environmental factors such as active bird nests also delay 6

vegetation management activities in this region. The additional acreage in recent 7

years devoted to orchards and new urban development projects have increased 8

vegetation volumes in this region. 9

Southern: Drought conditions and increasing fire restrictions pose logistical 10

challenges due to decreased work hours and periodic prohibitions on using certain 11

power tools. The Company supports these necessary measures to prevent wildfires, 12

however, it results in decreased productivity for the vegetation management program. 13

Consequently, a significant portion of vegetation management activities in this area 14

are strongly influenced by seasonal fire restrictions. These challenges are 15

exacerbated by external requests for local tree crew resources to assist local and state 16

fire crews mitigating trees during active fires. These same crews are often called 17

upon after a fire to remove fire damaged trees near facilities, which in turn, delays 18

scheduled work. The Southern region is characterized by its high tree density and 19

hazard trees. The high volume of hazard trees from drought-stress and wood-20

infesting beetles also strains crew productivity, and compromises the effectiveness of 21

previously worked areas. The urban areas of this region include additional challenges 22

such as local permits for traffic control and irrigated fast growing species. 23

PAC/2900 Lucas/18


Q. Are there challenges that impact all regions? 1

A. Yes. In each region requires varying levels of coordination with local, state, and 2

federal authorizing officers to acquire approval to conduct vegetation management 3

activities and coordination timeframes can vary significantly. Also common to all 4

areas are environmental factors that may delay maintenance work, such as active bird 5

nests and other sensitive species concerns, water quality concerns, and varying 6

resource availability constraints. For example, International Brotherhood of 7

Electrical Workers 659 in southern Oregon has experienced an approximate 40 8

percent decline in available journeyman tree trimmers since 2016. 9

Q. Are your descriptions of the unique and increasing challenges that PacifiCorp’s 10

vegetation management program experiences across its service territory in 11

Oregon meant to explain away the increase in vegetation management violations 12

since 2013 that Mr. Moore cites in his testimony? 13

A. Not at all. PacifiCorp recognizes that there are problems that need to be addressed. 14

PacifiCorp has a strong commitment to improving its vegetation management 15

program and over time producing substantially better results. While my direct 16

testimony was more focused on the Company’s plans for enhanced vegetation 17

management activities within the FHCA, the Company is instituting changes across 18

its vegetation management program designed to address past deficiencies in the 19

challenging environments I described above. 20

Q. Please describe the changes the Company is instituting in its vegetation 21

management program. 22

A. The planning and execution of vegetation work across PacifiCorp’s six states has 23

PAC/2900 Lucas/19


historically been completed on a consolidated basis. Beginning January 2020, two 1

distinct vegetation management groups were formed, split between PacifiCorp’s east 2

and west states. Since January 2020, vegetation management activities in Oregon, 3

Washington, and California are now managed locally under a newly created position 4

reporting directly to me. This new position is responsible for the coordination and 5

direction of all vegetation management activities for the Pacific Power service 6

territory. Four utility forestry arborist were added to this group to provide increased 7

work management and auditing capacity. 8

Q. Are any other initiatives underway to improve the program’s performance? 9

A. Yes. The Company is employing data analytics to better “inventory” the vegetation 10

environment along each of its circuits. PacifiCorp continues to evaluate additional 11

technologies that will help it quantify the effectiveness of the work performed during 12

and in-between prune cycles on its circuits. 13

Q. How is the Company using data analytics to improve program performance? 14

A. The Company has begun using publicly available habitat data, augmented with its 15

legacy vegetation management database, called PVM, to begin establishing tree 16

density information for each circuit’s segments in order to place a higher priority on 17

segments where the data indicates greater tree density. PacifiCorp only recently 18

completed the preliminary work product, and will leverage this information to 19

optimize work delivered for those higher priority areas. This new tool will support 20

better timing and work organization for the vegetation management team. In 21

addition, as climate change impacts continue to be studied, PacifiCorp expects this 22

PAC/2900 Lucas/20


foundational data will help it to alter aspects of the program to address a variety of 1

climate change scenarios. 2

Q. What new technologies is the Company evaluating or planning to evaluate to 3

continue to improve and modernize its vegetation management program? 4

A. The Company recognizes technology is a critical ingredient to evolve its vegetation 5

management program to address an increasingly complex vegetation management 6

environment. In addition to the data analytics work described above, PacifiCorp 7

launched plans to replace its vegetation management workforce management tools, 8

develop more mobile support tools, and leverage photogrammetry to inform the 9

workflow process and ensure program effectiveness. To that end it implemented a 10

pilot program in 2019 using mobile Light Imaging Detection and Ranging (LiDAR) 11

units to patrol and inspect utility assets, including both distribution primary and 12

transmission circuits. Using LiDAR as a pre-inspect tool, foresters should be able to 13

more precisely quantify the amount of work required to be performed on a 14

circuit. While still in the pilot phase, the Company hopes this pre-inspect tool will 15

help to inform its stage of circuits to be worked, fine-tune the scheduling of the prune 16

cycles, help confirm whether cycles for given circuits have been appropriately set, 17

and provide work scoping to better set and manage cost expectations. In addition, the 18

Company anticipates that using the LiDAR technology after a prune cycle has been 19

completed could be used to confirm that work performed is sufficient to ensure 20

vegetation compliance through the next cycle. 21

PAC/2900 Lucas/21


Q. Do you believe the current cost recovery model, where the Company is allocated 1

a budgeted amount through a rate case until its next rate case, is appropriate 2

given the changing vegetation management environment? 3

A. No. As I described above, in Oregon the Company is obligated to address a 4

constantly shifting vegetation management environment, across an extremely varied 5

ecological landscape. As the impacts of climate change increase, the variation in 6

weather patterns are driving related variations in vegetation, and these variations 7

impact each of Oregon’s regions differently. A very wet year may drive up growth 8

patterns, and increase access issues. Whereas drought conditions increase the number 9

of danger trees and fire restrictions. Moreover, the increased risk associated with 10

catastrophic wildfires has resulted in increased demand across the west for tree 11

pruning services, and increased the liability risk for the contractors that provide these 12

services, both have significant impacts on program costs. There is a mismatch 13

between the fixed amount allocated to vegetation management in the traditional rate 14

case model, and the more extreme variances in the costs that the Company has 15

recently experienced, and that mismatch is likely to become greater over time. This is 16

concerning given that vegetation management is so critical to the safety and reliability 17

of the Company’s system. 18

Q. Does Mr. Moore propose any potential solutions to the mismatch between 19

traditional rate setting and the potentially extreme variations in costs associated 20

with vegetation management under current and anticipated future 21

environmental conditions? 22

A. Yes. Mr. Moore recommends that the Company’s vegetation management and its 23

PAC/2900 Lucas/22


other wildfire mitigation costs be put into a deferral with prudence of expenditures 1

later determined when the regulatory asset created is moved into rates. Mr. Moore’s 2

testimony, therefore, appears to recognize the mismatch problem I describe above. 3

Q. Do you have any concerns with the deferral mechanism that Mr. Moore proposes 4

in his opening testimony? 5

A. Yes. While I certainly appreciate the fact that Mr. Moore appears to understand some 6

of the problems with the current approach to cost recovery for the Company’s 7

vegetation management program, I have a few concerns. First, a deferral between 8

rate cases could introduce substantial lag in the recovery of vegetation management 9

costs. Given the size of the Company’s program in Oregon, this would have 10

enormous cash flow impacts to the Company that may not be sustainable. Similarly 11

the potential delay of prudence reviews could lead the Company to make investments 12

in its programs for several years before it learns that the Commission ultimately finds 13

that those investments were imprudent. 14

Q. Does PacifiCorp have an alternative proposal to the deferral recommended by 15

Mr. Moore? 16

A. Yes. Company witness Mr. Michael G. Wilding’s reply testimony includes a 17

modified recovery mechanism that includes both incremental wildfire mitigation and 18

incremental vegetation management program costs. The mechanism Mr. Wilding 19

proposes addresses the timing concerns with Mr. Moore’s proposed deferral, and 20

would more fully address the mismatch between traditional rate setting and the 21

environmentally driven variances in costs experienced in PacifiCorp’s vegetation 22

management program. Additionally, the mechanism the Company proposes provides 23

PAC/2900 Lucas/23


ongoing opportunity for Staff and interested party review, so that utility spending is 1

controlled, and ongoing program performance may be assessed. 2

Q. Why is the Company seeking to increase its O&M amounts for vegetation 3

management in the reply testimony? 4

A. As I describe at length in the testimony above, ensuring the vegetation management 5

program is performing according to plan is a dynamic process. At the time this rate 6

case was filed, my team was in the process of evaluating vegetation management 7

program needs. Ultimately it was determined that a higher O&M budget was 8

necessary to meet the program requirements, but this information was not finalized in 9

time for it to be included in the Company’s initial filings. Fortunately, I understand 10

that other adjustments were made that enable the higher vegetation management 11

expense to be included in the Company’s reply, without increasing the overall 12

revenue requirement that was initially filed. Company witness Ms. Shelley E. 13

McCoy discusses the additional O&M amounts included in reply. 14

Q. What is driving the increased O&M amounts for vegetation management? 15

A. There are a variety of factors driving the increase in O&M amounts for vegetation 16

management including an increase in volume of trees or pruning points due to natural 17

growth, increase in tree volume due to extension of or the addition of assets to the 18

system, an increase to the volume of hazard or off right of way trees affected by 19

climate change, drought or insect infestation, and finally overall inflationary pressures 20

since the 2013 general rate case. 21

PAC/2900 Lucas/24


V. CONCLUSION 1

Q. What are your recommendations for the Commission? 2

A. I recommend the Commission reject AWEC’s recommendation, reject Mr. Moore’s 3

covered conductor recommendation based on misinterpretation, modify the cost 4

recovery mechanism for vegetation management as proposed by Mr. Wilding, and 5

approve the additional vegetation O&M expense. 6

Q. Does this conclude your reply testimony? 7

A. Yes. 8



OF OREGON

PACIFICORP

___________________________________________________________

Exhibit Accompanying Reply Testimony of David M. Lucas

PacifiCorp’s Fire High Consequence Areas and Wildfire Mitigation Measures

June 2020

PacifiCorp’s Fire High Consequence Areas (FHCA)

PacifiCorp conducted wildfire risk modeling across the service territory and identified specific Fire High Consequence Areas which are candidates for wildfire mitigation project investments. The map below shows the location and names of the identified FHCA within PacifiCorp’s Oregon service territory that have been targeted for wildfire mitigation.

Figure 1: Fire High Consequence Areas and Public Safety Power Shutoff Areas by Name

Wildfire Mitigation Measures by FHCA

Exhibit PAC/2901 Lucas/1

Table 1 below describes the wildfire mitigation efforts that PacifiCorp anticipates accomplishing from 2019 to 2026 by location and mitigation activity.

Table 1: Wildfire Mitigation Efforts by Area and Activity

FHCA Name Miles of Covered

Conductor

Poles to Replace

Poles to Fire Wrap

Install Recloser

Install Relay

Install Weather Station

Cave Junction 455 111 728 10 3 5 Glendale 304 93 633 6 2 2 Jerome Prairie 167 96 486 6 2 2 Merlin 299 143 762 8 6 2 South Rogue River 162 88 526 1 8 2 Fielder Creek 187 52 323 2 2 1 Shady Cove 106 89 542 6 3 1 Lost Creek Lake 54 19 139 1 1 Siskiyou National Monument 106 232 540 6 2 3 Riddle Myrtle Creek 2 53 337 8 8 2 Winchester 4 4 34

Hood River Rural 22 60 163 1 5 2 Hood River Urban 5 2 27 2 1 Grand Total 1,873 1,042 5,240 56 42 24




OF OREGON

PACIFICORP

___________________________________________________________

Exhibit Accompanying Reply Testimony of David M. Lucas

Southern California Edison’s Covered Conductor Presentation–California Public Utilities Commission’s February 27, 2019 Workshop

June 2020

Feb

ruary

27, 2019

CPU

C C

ove

red

Co

nd

uct

or

Wo

rksh

op


Ove

rvie

w &

Ob

ject

ives

•H

isto

ry &

Evo

luti

on

of

Co

vere

d C

on

du

cto

r D

esi

gn

•Te

stin

g a

nd

An

aly

sis

•Ig

nit

ion

& E

lect

rocu

tio

n R

isk

•Serv

ice L

ife &

Du

rab

ilit

y

•U

se b

y o

ther

Uti

liti

es

•Typ

ical C

on

stru

ctio

n C

on

fig

ura

tio

ns

•R

isk A

naly

sis

& A

ltern

ati

ves

Co

mp

ari

son

2Exhibit PAC/2902 Lucas/2

A B

rief

His

tory

•C

overe

d C

on

du

cto

r h

as

been

use

d b

y u

tiliti

es

sin

ce t

he 1

970s

in E

uro

pe

an

d t

he U

.S.

•K

ey d

river:

reliab

ilit

y im

pro

vem

en

t in

den

se v

eg

eta

tio

n a

reas,

su

ch a

s fo

rest

s in

Sca

nd

inavia

, th

e U

.K.,

New

En

gla

nd

, etc

.

•O

ther

dri

vers

exp

an

d t

he u

se o

f co

vere

d c

on

du

cto

rs:

•To

kyo

, Ja

pan

: p

ub

lic

safe

ty in

den

se p

op

ula

tio

n

•So

uth

east

Asi

a (

Th

ailan

d, M

ala

ysi

a): a

nim

al p

rote

ctio

n (

snakes,

mo

nkeys,

ro

den

ts), a

nd

d

en

se v

eg

eta

tio

n, als

o p

ub

lic

safe

ty in

do

wn

tow

n B

an

gko

k

•R

ed

uct

ion

of

“bu

shfi

res”

has

beco

me a

key d

river

for

rep

laci

ng

bare

wit

h

covere

d c

on

du

cto

r in

Au

stra

lia

•O

ver

the y

ears

, si

gn

ific

an

t d

evelo

pm

en

t in

th

e c

overe

d c

on

du

cto

r d

esi

gn

le

d t

o im

pro

ved

perf

orm

an

ce a

nd

ext

en

ded

lif

e


No

mencl

atu

re o

f C

ove

red

Co

nd

uct

or

•C

overe

d c

on

du

cto

r: in

sula

tin

g m

ate

rials

, d

isti

ng

uis

hed

fro

m b

are

co

nd

uct

or

•C

overe

d c

on

du

cto

r in

th

e U

.S.:

•C

overe

d c

on

du

cto

r in

lie

u o

f “i

nsu

late

d c

on

du

cto

r”, w

hic

h is

rese

rved

fo

r g

rou

nd

ed

overh

ead

cab

le

•Tr

ee w

ire: w

idely

use

d in

th

e U

.S. in

1970’s

, ty

pic

ally o

ne-l

ayer

covere

d, o

n c

ross

-arm

co

nst

ruct

ion

•Sp

ace

r ca

ble

: 2 o

r 3 layers

of

coveri

ng

, su

pp

ort

by m

ess

en

ger

an

d t

rap

ezo

idal in

sula

ted

bra

ckets

•A

eri

al b

un

dle

d c

ab

le (

AB

C): u

nd

erg

rou

nd

cab

le o

n p

ole

s w

ith

ben

efi

ts o

f b

ein

g g

rou

nd

ed

•C

overe

d c

on

du

cto

r in

th

e o

ther

part

s in

th

e w

orl

d:

•co

vere

d c

on

du

cto

r, in

sula

ted

co

nd

uct

or, c

oate

d c

on

du

cto

r in

terc

han

geab

ly•

Sca

nd

inavia

co

un

trie

s: S

AX

, PA

S/B

LX

, B

LX

-T, ty

pic

ally in

stalled

in

fo

rest

s•

Au

stra

lia, Fa

r East

co

un

trie

s: C

C/C

CT; C

CT w

ith

th

icker

insu

lati

on

•C

overe

d C

on

du

cto

r at

SC

E:

•In

tro

du

ced

sta

nd

ard

s in

Q1, 2018

•SC

E h

as

pre

vio

us

exp

eri

en

ce in

aeri

al ca

ble

, an

d “

tree w

ires”

•C

urr

en

t SC

E s

peci

fica

tio

n o

f co

vere

d c

on

du

cto

r is

mo

re r

ob

ust

th

an

CC

T (

e.g

. b

ett

er

UV

pro

tect

ion

)


Evo

lutio

n o

f C

ove

red

Co

nd

uct

or

Sin

gle

Laye

r

•P

rote

ctio

n o

n

inci

den

tal c

on

tact

s

•Le

ss p

rote

ctio

n o

n

lon

g te

rm c

on

tact

w

ith

ob

ject

s

•M

ore

su

scep

tib

le t

o

lon

g te

rm U

V

de

grad

atio

n (

30

+ ye

ars)

Two

Lay

er

•Th

icke

r o

vera

ll in

sula

tio

n

•Im

pro

vem

en

t o

n

insu

lati

on

•To

ugh

er

ou

ter

laye

r fo

r ab

rasi

on

p

rote

ctio

n

•Im

pro

vem

en

t o

n

UV

Thre

e La

yer

(Cu

rren

t St

and

ard

)

•C

apab

le o

f w

ith

stan

d lo

ng-

term

co

nta

ct (

sem

i-co

nd

uct

ive

shie

ld)

•H

igh

er c

on

du

cto

r ra

tin

g (c

ross

-lin

kin

g)

•A

bra

sio

n

imp

rove

me

nt

•Im

pro

ved

UV

an

d

trac

kin

g re

sist

ant

(Tit

aniu

m d

ioxi

de

)


SC

E C

ove

red

Co

nd

uct

or

Desi

gn

•Th

ree L

ayer

Co

vere

d C

on

du

cto

r•

Co

nd

uct

or

•A

lum

inu

m C

on

du

cto

r Ste

el-

Rein

forc

ed

(A

CSR

)

•H

ard

Dra

wn

Co

pp

er

(HD

CU

)

•C

on

du

cto

r Sh

ield

•Sem

ico

nd

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ing

Th

erm

ose

t Po

lym

er

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ed

uce

s st

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, tr

an

sfo

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stra

nd

s in

to a

sin

gle

un

ifo

rm c

ylin

der

•Ext

en

d s

erv

ice life o

f th

e c

overe

d c

on

du

cto

r in

case

of

con

tact

s

•In

ner

Insu

lati

on

Layer

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ross

lin

ked

Lo

w D

en

sity

Po

lyeth

yle

ne: m

ore

fle

xib

le

•H

igh

im

pu

lse s

tren

gth

: p

rote

ct f

rom

ph

ase

-to

-ph

ase

an

d p

hase

-to

-gro

un

d c

on

tact

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ross

lin

kin

g: re

tain

its

str

en

gth

an

d s

hap

e e

ven

wh

en

heate

d

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ute

r La

yer

•C

ross

lin

ked

Hig

h D

en

sity

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lyeth

yle

ne: A

bra

sio

n a

nd

Im

pact

Resi

stan

t; S

tress

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ck R

esi

stan

t

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an

ium

Dio

xid

e: th

e m

ost

eff

ect

ive U

V in

hib

ito

r, a

nd

pro

vid

ing

th

e b

est

tra

ck r

esi

stan

t

6

Flu

x lin

es w

ith

out

a c

on

ducto

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ld

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x lin

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on

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r shie

ld


Co

vere

d C

ond

uct

or

Inst

alla

tio

n O

ptio

ns

7

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ss-a

rm C

on

stru

ctio

n

(aka T

ree W

ire)

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mp

act

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nst

ruct

ion

(aka S

pace

r C

ab

le)

Som

e in

stal

lati

on

s w

ill b

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pac

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(e

.g. r

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f tr

ee a

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hm

en

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st o

f SC

E in

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lati

on

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n C

ross

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(SC

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ses

grey

to

red

uce

th

e im

pac

t o

f su

n

ligh

t h

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acit

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Co

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ncl

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at

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vere

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t ca

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at

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is r

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pre

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nit

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ps

for

less

in

2 s

eco

nd

s w

ou

ld n

ot

ign

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8

Sim

ula

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n M

eth

od

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nd

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or

Typ

e

Cu

rre

nt

in

Bra

nch

Re

sist

ance

of

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we

r in

to

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nch

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0 m

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Co

mp

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& F

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ase

s

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om

pu

ter

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sis

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cal so

ftw

are

(P

SC

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, C

DEG

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mo

delin

g

con

tact

s o

n c

on

du

cto

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or

fau

lt c

urr

en

t an

d e

nerg

y

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ld t

est

ing

was

perf

orm

ed

at

SC

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est

Faci

lity

in

West

min

ster

to

valid

ate

th

e c

om

pu

ter

mo

del st

ud

y

•A

naly

sis

an

d t

est

case

s:•

Tree/V

eg

eta

tio

n p

hase

-to

-ph

ase

co

nta

ct

•C

on

du

cto

r Sla

pp

ing

•W

ild

life

ph

ase

-to

-ph

ase

co

nta

ct

•M

eta

llic

Ballo

on

ph

ase

-to

-ph

ase

co

nta

ct


Tree B

ranch

co

nta

ct•

En

erg

ized

at

12 k

V

•O

bse

rvati

on

s

•N

o a

rcin

g

•N

o d

am

ag

e t

o t

he c

overe

d c

on

du

cto

r

•N

o d

am

ag

e t

o t

he t

ree b

ran

ch

10Exhibit PAC/2902

Lucas/10

11

Co

nd

uct

or

Sla

pp

ing

Sim

ula

ting

Anim

al

Myl

ar

Ballo

on

Test

ing

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er

Co

nta

cts:

No

Arc

ing

and

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ag

e t

o C

ove

red

Co

nd

uct

ors


Co

mp

ute

r A

naly

sis

and

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ld T

est

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pu

ter

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an

d f

ield

test

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valid

ate

d t

hat

covere

d c

on

du

cto

r w

ill p

reven

t fa

ult

s an

d p

reven

t ig

nit

ion

du

e t

o in

cid

en

tal co

nta

ct

12

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ula

ted

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st S

ub

ject

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t w

ith

Tes

t

Sub

ject

(mA

)

Emp

iric

al

Cu

rren

t w

ith

Tes

t

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(mA

)

Pow

er -

Sim

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(Wat

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Pow

er –

Emp

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(Wat

ts)

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ter

and

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ld t

est

resu

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sho

wed

co

nta

ct c

urr

ent

in t

he

ran

ge m

illia

mp

s. A

n A

ust

ralia

n s

tud

ies

sho

wed

tes

tin

g o

f 0

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mp

s o

r le

ss in

2 s

eco

nd

s d

oes

no

t ig

nit

e


Und

ers

tand

ing

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ow

n

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overe

d c

on

du

cto

rs s

ho

uld

exp

eri

en

ce s

ign

ific

an

tly f

ew

er

wir

e-d

ow

n e

ven

ts

com

pare

d t

o b

are

co

nd

uct

ors

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ire d

ow

n r

isk c

om

pari

son

of

bare

vs.

co

vere

d c

on

du

cto

rs•

Bare

co

nd

uct

or

fallin

g o

n t

he g

rou

nd

(in

tact

or

bro

ken

) p

ose

s ri

sk o

f ig

nit

ion

an

d t

o p

ub

lic

safe

ty

•C

overe

d c

on

du

cto

r fa

llin

g o

n t

he g

rou

nd

(in

tact

or

bro

ken

) p

ose

s m

uch

less

ris

k o

f ig

nit

ion

an

d t

o p

ub

lic

safe

ty

•W

ire d

ow

n d

ete

ctio

n•

Trad

itio

nal p

rote

ctio

n a

ctiv

ate

s u

nd

er

hig

h c

urr

en

t (f

au

lt)

vs

no

rmal cu

rren

t (lo

ad

)

•W

ire-d

ow

n f

au

lt c

urr

en

t ca

n o

ften

be lo

w (

called

hig

h im

ped

an

ce f

au

lts)

•

Typ

ically o

ccu

rs w

hen

wir

e lan

ds

on

su

rface

s su

ch a

s asp

halt

, co

ncr

ete

, sa

nd

, an

d d

ry s

oil

•Tr

ad

itio

nal p

rote

ctio

n s

chem

es

have lo

w p

rob

ab

ilit

y o

f d

ete

ctin

g h

igh

im

ped

an

ce f

au

lts

•A

dva

nce

d W

ire-d

ow

n d

ete

ctio

n:

•Fo

r th

is r

easo

n, th

e in

du

stry

is

invest

igati

ng

alt

ern

ati

ve p

rote

ctio

n s

chem

es

•Fo

r exa

mp

le, SC

E im

ple

men

tin

g M

ete

r A

larm

ing

Do

wn

ed

En

erg

ized

Co

nd

uct

or

(MA

DEC

) sy

stem

, w

hic

h u

ses

cust

om

er

mete

r vo

ltag

e a

nd

mach

ine learn

ing

alg

ori

thm

s fo

r d

ete

ctin

g

wir

e-d

ow

n e

ven

ts13Exhibit PAC/2902

Lucas/13

NEETR

AC

Test

ing

–Energ

ized

Do

wned

Co

nd

uct

or

•Th

e f

ollo

win

g a

re t

est

case

s o

f en

erg

ized

wir

e d

ow

n s

cen

ari

os

that

were

sim

ula

ted

an

d e

mp

iric

ally

test

ed

by N

EETR

AC

•Pers

on

ho

ldin

g b

roken

co

vere

d

co

nd

ucto

r o

n l

ine s

ide

•Pers

on

ho

ldin

g b

roken

co

vere

d

co

nd

ucto

r o

n l

oad

sid

e

•Pers

on

ho

ldin

g b

roken

bare

co

nd

ucto

r o

n l

ine s

ide

•Pers

on

ho

ldin

g b

roken

bare

co

nd

ucto

r o

n l

oad

sid

e

*No

te t

hat

bare

co

nd

uct

or

test

case

s w

ere

no

t p

erf

orm

ed

in

th

e lab

ora

tory

.

14Exhibit PAC/2902

Lucas/14

NEETR

AC

Test

ing

Sum

mary

•Te

st In

form

ati

on

:

•C

on

du

cto

r: 1

/0 C

overe

d C

on

du

cto

r

•So

urc

e: 12.4

47 k

V

•Te

st R

esu

lts:

Hu

man

co

nta

ct c

urr

en

t m

easu

red

•C

on

clu

sio

n:

•C

overe

d C

on

du

cto

r To

uch

Cu

rren

t:

Gen

era

lly N

ot

Perc

ep

tib

le (

belo

w

1m

A)

•O

vera

ll, co

vere

d c

on

du

cto

rs c

an

p

ote

nti

ally p

rovid

e p

ub

lic

safe

ty

ben

efi

ts d

uri

ng

wir

e d

ow

n e

ven

ts

15

Co

vere

d C

on

du

cto

rB

are

Co

nd

uct

or

Sim

ula

tio

n R

esu

lts

(Th

eore

tica

l Val

ue)

Lab

Tes

t R

esu

lts

(Act

ual

Val

ues

)

Sim

ula

tio

n R

esu

lts

(Th

eore

tica

l Val

ue)

Lin

e S

ide

0.2

20

mA

0.2

27

mA

5,3

00

mA

Load

Sid

e

0.2

18

mA

0.2

27

mA

34

.2 m

A

Cu

rre

nt

Effe

ct

Bel

ow

1 m

AG

ener

ally

no

t Pe

rcep

tib

le

1 m

AFa

int

Tin

gle

5 m

ASl

igh

t Sh

ock

; No

t p

ain

ful b

ut

dis

turb

ing.

Ave

rage

ind

ivid

ual

can

let

go

6-2

5 m

A (

wo

men

)

9-3

0 m

A (

men

)

Pain

ful s

ho

ck, l

oss

of

mu

scu

lar

con

tro

l. Th

e fr

eezi

ng

curr

ent

or

"let

-go

" ra

nge

. In

div

idu

al c

ann

ot

let

go, b

ut

can

be

thro

wn

aw

ay f

rom

th

e ci

rcu

it if

ext

enso

r m

usc

les

are

stim

ula

ted

50

-15

0 m

AEx

trem

e p

ain

, res

pir

ato

ry a

rres

t (b

reat

hin

g st

op

s),

seve

re m

usc

ula

r co

ntr

acti

on

s. D

eath

is p

oss

ible

Effe

cts

of

Elec

tric

al C

urr

ent

on

th

e H

um

an

Bo

dy

(So

urc

e: C

DC

)


Serv

ice L

ife f

or

Co

vere

d C

ond

uct

ors

•Exp

ect

ed

serv

ice lif

e o

f 4

5 y

ears

(eq

uiv

ale

nt

to b

are

co

nd

uct

or)

•B

are

an

d c

overe

d c

on

du

cto

r ca

n o

pera

te a

nd

perf

orm

as

desi

gn

ed

past

th

e45 y

rs

•B

eyo

nd

its

serv

ice lif

e, SC

E b

elieves

the c

overi

ng

will co

nti

nu

e t

o p

rovid

e p

art

ial

pro

tect

ion

•Fa

cto

rs s

up

po

rtin

g s

erv

ice lif

e a

nd

perf

orm

an

ce:

•A

dva

nce

men

t o

f co

mp

ou

nd

tech

no

log

y a

nd

up

gra

de o

f m

an

ufa

ctu

rin

geq

uip

men

t

•K

no

wn

serv

ice lif

e o

f cr

oss

-lin

ked

po

lyeth

ely

ne

(XLP

E)

is 4

0 y

ears

min

imu

m

•R

igo

rou

s m

an

ufa

ctu

rer

qu

alifi

cati

on

an

d p

rod

uct

ion

test

ing

•H

isto

rica

l re

cord

s w

ith

syst

em

s in

stalled

sin

ce 1

951 a

re s

till in

op

era

tio

nan

d

perf

orm

ing

as

desi

gn

ed

67 y

ears

ag

o

16Exhibit PAC/2902

Lucas/16

Qualif

icatio

n &

Pro

duct

ion T

est

ing

: Ensu

re L

ong

Serv

ice L

ife

for

Co

vere

d C

ond

uct

or

•Q

ualifi

cati

on

Test

ing

per

Insu

late

d C

ab

le E

ng

ineers

Ass

oci

ati

on

(IC

EA

)S-1

21-7

33-2

016

Sta

nd

ard

, fo

r exa

mp

les:

•Su

nlig

ht

resi

stan

ce (

UV

) te

stin

g (

valid

ate

s p

rote

ctio

n a

gain

st s

un

lig

ht,

mo

istu

re, h

eat)

•Tr

ack

resi

stan

ce t

est

ing

(va

lid

ate

s in

sula

tio

n p

erf

orm

an

ce in

real life

co

nd

itio

n)

•M

axi

mu

m d

iele

ctri

c co

nst

an

t (e

nsu

res

insu

lati

on

str

en

gth

of

the c

overi

ng

)

•R

ou

tin

e p

rod

uct

ion

test

ing

•D

C r

esi

stan

ce (

valid

ate

s ele

ctri

cal p

rop

ert

ies)

•U

nag

ed

an

d a

ged

ten

sile

an

d e

lon

gati

on

(en

sure

mech

an

ical st

ren

gth

of

the c

overi

ng

)

•H

ot

Cre

ep

(va

lid

ate

cro

ss-l

inkin

g t

o t

herm

ose

t m

ate

rials

)

•Sp

ark

Test

(va

lid

ate

no

pin

ho

les/

fau

lts

on

th

e in

sula

tio

n)

•Pass

ing

qu

alifi

cati

on

an

d p

rod

uct

ion

test

s en

sure

s h

igh

qu

ality

of

covere

d c

on

du

cto

r an

d

45 y

ears

of

op

era

tin

g lif

e

17Exhibit PAC/2902

Lucas/17

Kno

wn F

ailu

re M

od

es

•C

overe

d c

on

du

cto

r co

uld

have b

urn

do

wn

if

no

t ad

eq

uate

ly d

esi

gn

ed

or

inst

alled

•Th

e f

ollo

win

g k

no

wn

iss

ues

are

ad

dre

ssed

eit

her

by d

esi

gn

cri

teri

a o

r in

stallati

on

gu

idelin

e

•Ele

ctri

cal tr

ack

ing

on

su

rface

of

covers

SC

E’s

co

vere

d c

on

du

cto

r d

esi

gn

will in

clu

de a

tra

ck r

esi

stan

t X

LP

E o

ute

r la

yer. A

dd

itio

nally,

SC

E w

ill m

itig

ate

tra

ckin

g b

y u

sin

g p

oly

meri

c in

sula

tors

, u

sin

g c

rim

ped

co

nn

ect

ors

, an

d

usi

ng

a lo

w c

arb

on

co

nte

nt

sheath

.

•A

rc g

en

era

ted

fro

m lig

htn

ing

str

ikes

Su

rge a

rrest

ers

will b

e in

stalled

at

all o

verh

ead

eq

uip

men

t lo

cati

on

s an

d a

t U

G D

ips.

•A

eo

lian

(W

ind

-In

du

ced

) V

ibra

tio

n

Sag

an

d T

en

sio

ns

for

the c

overe

d c

on

du

cto

r w

ill ta

ke in

to a

cco

un

t th

e t

err

ain

. Th

ere

will b

e

two

sep

ara

te t

ab

les

for

lig

ht

an

d h

eavy lo

ad

ing

. Th

e lo

ad

ing

lim

its

acc

ou

nt

for

win

d a

nd

ic

e.

•P

rem

atu

re In

sula

tio

n B

reakd

ow

n

SC

E’s

Co

vere

d C

on

du

cto

r d

esi

gn

use

s a C

ross

-lin

ked

Hig

h-D

en

sity

Po

lyeth

yle

ne layer

to

help

resi

st a

bra

sio

n. A

dd

itio

nally,

co

vere

d c

on

du

cto

r m

ust

be h

an

dle

d w

ith

care

in

ord

er

to

pre

ven

t d

am

ag

e t

o t

he c

overi

ng

.

D

iscu

ssio

n w

ith

oth

er

uti

liti

es

ind

icate

d t

hat

old

er

covere

d c

on

du

cto

r d

esi

gn

perf

orm

ed

as

inte

nd

ed

even

aft

er

50 y

ears

18Exhibit PAC/2902

Lucas/18

Bench

mark

ing

•G

lob

al lite

ratu

re r

ese

arc

h: Eu

rop

e, A

sia, A

ust

ralia, U

.S.

•Su

rveyin

g u

tiliti

es:

NEETR

AC

, W

UC

, Fir

st Q

uart

ile

•B

en

chm

ark

ing

: K

EP

CO

, V

icto

rian

uti

liti

es,

No

rth

east

uti

liti

es,

Un

ited

Po

wer

•So

me k

ey t

akeaw

ays:

•M

ost

uti

liti

es

in t

he U

.S. u

se b

are

co

nd

uct

ors

•Su

ccess

sto

ries

on

co

vere

d c

on

du

cto

r p

reven

tin

g ig

nit

ion

s

•Less

on

s le

arn

ed

of

challen

ges

an

d im

pro

vem

en

t

•C

ollab

ora

tio

n h

elp

ed

SC

E t

o p

rep

are

sp

eci

fica

tio

n, st

an

dard

s an

d d

ep

loym

en

t fa

ster

19Exhibit PAC/2902

Lucas/19

Ro

und

Tab

le B

ench

mark

with N

ort

heast

Utilit

ies

•C

on

du

cted

an

in

-pers

on

dis

cuss

ion

on

co

vere

d c

on

du

cto

r exp

eri

en

ce w

ith

th

e N

ort

heast

uti

liti

es:

•H

en

dri

x (m

an

ufa

ctu

rer)

,Lib

ert

y U

tiliti

es

(New

Ham

psh

ire),

Gro

vela

nd

Lig

ht

(Mass

ach

use

tts)

,H

oly

oke

(Mass

ach

use

tts)

,M

idd

leto

n (

Mass

ach

use

tts)

.

•Past

sta

nd

ard

s en

gin

eer

of

Evers

ou

rce

att

en

ded

as

well

•C

overe

d C

on

du

cto

r Syst

em

s

•N

ew

En

gla

nd

overa

ll is

ap

pro

xim

ate

ly 8

0%

Co

vere

d C

on

du

cto

r an

d 2

0%

Bare

•En

d o

f life

•C

overe

d c

on

du

cto

r st

ill lo

oks

an

d p

erf

orm

s th

e s

am

e a

fter

50+

years

of

serv

ice

•Is

sues

•M

an

ufa

ctu

rin

g p

rob

lem

s d

ue t

o r

ing

cu

ts w

as

exp

eri

en

ced

in

th

e late

70s

befo

re c

lean

roo

ms

•C

oro

na is

main

failu

re m

od

e (

ph

ase

to

gro

un

d t

hro

ug

h t

ree), b

ut

it t

akes

years

to

fail

•N

on

e h

as

exp

eri

en

ced

Aeo

lian

vib

rati

on

iss

ues

•N

on

e h

as

en

cou

nte

red

wate

r in

gre

ss

•Lig

htn

ing

•B

urn

do

wn

hap

pen

s at

stri

pp

ed

po

rtio

n

•A

dd

lig

htn

ing

arr

est

ors

at

eq

uip

men

t, t

ran

siti

on

s to

bare

, an

d d

ead

-en

ds

•H

ad

en

ou

gh

in

cid

en

ts t

o d

eci

de t

o in

stall lig

htn

ing

arr

est

ers

at

en

d o

f lin

e

•A

ll a

dvis

e n

ot

to in

stall lig

htn

ing

arr

est

ers

at

every

1000 f

t.A

vo

id s

trip

pin

g a

s m

uch

as

po

ssib

le.

20Exhibit PAC/2902

Lucas/20

Ausn

et–

Co

vere

d C

ond

uct

or

Ignitio

n M

itig

atio

n

21

•A

acy

pre

ss t

ree b

lew

on

to c

overe

d c

on

du

cto

r d

uri

ng

a s

torm

in

Dece

mb

er

2015

•A

usn

et

pers

on

nel re

spo

nd

ed

th

ree d

ays

aft

er

the

sto

rm a

nd

fo

un

d t

he t

ree o

n c

on

du

cto

rs

•N

o b

roken

co

nd

uct

or, n

o s

erv

ice in

terr

up

tio

n, n

o

ign

itio

n.

•Th

e s

pace

rs w

ere

kn

ock

ed

off

an

d t

he c

on

du

cto

rs

wra

pp

ed

up

.

•In

sula

tio

n t

hic

kn

ess

desi

gn

on

each

co

vere

d

con

du

cto

r p

reven

ted

a p

hase

-to

-ph

ase

fau

lt.

•p

ow

er

shu

tdo

wn

to

un

wra

p t

he c

on

du

cto

rs a

nd

rein

stall t

he s

pace

rs.


An U

nited

Po

wer

Exp

erience

•W

e a

lso

learn

ed

so

me s

ucc

ess

sto

ries

of

covere

d c

on

du

cto

r th

at

pre

ven

ted

w

ild

fire

ig

nit

ion

s fr

om

Un

ited

Po

wer

in C

olo

rad

o

•U

nit

ed

Po

wer

has

exp

eri

en

ced

wild

fire

s in

years

past

in

th

e f

ore

sted

are

a, ty

pic

ally

in h

igh

ele

vati

on

of

Co

lora

do

.

•To

mit

igate

th

is iss

ue, U

nit

ed

Po

wer

inst

alled

co

vere

d c

on

du

cto

r o

n s

pace

r co

nfi

gu

rati

on

du

e t

o c

om

pact

rig

ht-

of-

way.

•U

nit

ed

Po

wer

rece

ived

a n

oti

fica

tio

n f

rom

th

e f

ore

st s

erv

ices

tree f

all o

n lin

e a

fter

a w

ind

sto

rm o

n F

all 2

018

•U

nit

ed

resp

on

ded

to

th

e s

ite a

nd

rem

oved

th

e t

ree, fo

un

d t

he c

overe

d c

on

du

cto

r in

tact

, w

ith

no

in

terr

up

tio

n o

r w

ild

fire

ig

nit

ion

.

•Th

e m

an

ag

er

at

Un

tied

Po

wer

refl

ect

ed

th

at

this

win

d s

torm

even

t w

ou

ld h

ave

resu

lted

in

a w

ire d

ow

n e

ven

t, a

nd

po

ssib

ly a

wild

fire

ig

nit

ion

if

the t

ree f

ell o

n

bare

co

nd

uct

or

span

.

22Exhibit PAC/2902

Lucas/22

Thre

e-w

ire D

ead

-end

Co

nst

ruct

ion

Intr

od

uce

new

sta

nd

ard

s fo

r d

ead

-end

co

ver,

com

po

site

po

le a

nd

cro

ss-a

rm

23

Sam

e c

on

cep

tfo

rfo

ur-

wir

e an

d t

wo

-wir

e co

nst

ruct

ion

s

•C

ove

red

Co

nd

uct

ors

ne

ed t

o

be

str

ipp

ed a

t th

e d

ead

-en

d•

Use

Dea

d-e

nd

Co

vers

to

p

rote

ct e

xpo

sed

are

as


Tang

ent

2 W

ire w

ith T

ransf

orm

er

Co

nst

ruct

ion

24

Sam

e c

on

cep

tfo

rco

nn

ect

ing

to o

the

r e

qu

ipm

ent:

cap

acit

or,

sw

itch

, re

mo

te a

uto

mat

ic r

ecl

ose

r, e

tc.

•U

se S

urg

e A

rre

ster

s at

all

Ove

rhe

ad

Equ

ipm

en

t •

Trea

t C

ove

red

Co

nd

uct

or

syst

ems

like

hig

h li

ghtn

ing

area

•

Co

veri

ng

pre

ven

ts t

he

arc

fro

m

mo

vin

g•

Use

Bo

lte

d W

ed

ge C

on

ne

cto

r•

Co

ver

afte

r in

stal

lati

on

•U

se P

rote

cte

d G

rou

nd

Wir

e•

Co

nn

ecti

on

s to

eq

uip

men

t w

ill

be

cove

red

•W

ildlif

e p

rote

ctio

n o

n e

qu

ipm

en

t•

Co

ver

Ligh

tnin

g A

rres

ter,

Tr

ansf

orm

er B

ush

ing,

an

d F

use


SC

E H

isto

rica

l Fi

re C

ause

s

25

2015-2

017

Co

vere

d C

on

du

cto

r m

itig

ate

s ~

60%

of

dri

vers

cau

sin

g

his

tori

cal ig

nit

ion

s


Altern

ative

s C

onsi

dere

d

•W

ild

fire

Mit

igati

on

Op

tio

ns

•C

overe

d C

on

du

cto

r

•R

ep

lace

exi

stin

g c

on

du

cto

r w

ith

new

, ap

pro

pri

ate

ly s

ized

, co

vere

d c

on

du

cto

r

•B

are

Co

nd

uct

or

•R

ep

lace

exi

stin

g c

on

du

cto

r w

ith

new

, ap

pro

pri

ate

ly s

ized

, b

are

co

nd

uct

or

•U

nd

erg

rou

nd

Relo

cati

on

•R

elo

cate

exi

stin

g o

verh

ead

pri

mary

vo

ltag

es

to u

nd

erg

rou

nd

•See S

CE’s

GSR

P a

nd

RA

MP

filin

gs

for

ad

dit

ion

al d

eta

ils

26Exhibit PAC/2902

Lucas/26

Altern

ative

s M

itig

atio

n E

ffect

iveness

Analy

sis

27Exhibit PAC/2902

Lucas/27

Co

mp

ariso

n o

f A

ltern

ative

s

•C

overe

d C

on

du

cto

r h

as

the g

reate

st m

itig

ati

on

eff

ect

iven

ess

per

do

llar

spen

t an

d is

85%

le

ss t

han

th

e c

ost

of

Un

derg

rou

nd

Relo

cati

on

•SC

E’s

RA

MP

an

aly

sis

sho

ws

covere

d c

on

du

cto

r h

as

the g

reate

st r

isk-s

pen

d e

ffic

ien

cy (

RSE)

•~

3.4

x g

reate

r th

an

Bare

Co

nd

uct

or

•~

4x g

reate

r th

an

Un

derg

rou

nd

Relo

cati

on

•Sp

eed

of

Co

vere

d C

on

du

cto

r d

ep

loym

en

t is

mu

ch f

ast

er

than

Un

derg

rou

nd

Relo

cati

on

Alt

ern

ativ

eD

rive

rs

Mit

igat

ed

Co

stp

er

Mile

($ m

illio

n)

GSR

P M

itig

atio

nC

ost

Rat

io

Co

vere

d C

on

du

cto

r6

0%

0.4

31

.40

Bar

e C

on

du

cto

r1

5%

0.3

00

.50

Un

der

gro

un

d R

elo

cati

on

10

0%

3.0

0.3

3

28Exhibit PAC/2902

Lucas/28

Documents

Docket No. UE 374 Exhibit PAC/2900 Witness: David M. Lucas ...€¦ · Lucas/3 Reply Testimony of David M. Lucas 1 Q. Please describe the Coastal region. 2 A. The Coastal region is