WMP Compliance Report - Colorado Region - Gap Analysis Report
Utility
Sheltera Test Company
0%
Executive Summary
This document outlines the Wildfire Mitigation Plan gap analysis for the Colorado region,
evaluating current readiness against regulatory standards and industry best practices. The current
readiness score stands at 0%. Immediate attention is required for
2 missing elements and
59 elements that need work.
Gap Analysis Overview
The following matrix summarizes the current readiness state across all analyzed compliance
sub-elements.
Sub-Elements That Need Work
59
Sub-Elements with No Formal Protocol
0
Design & Construction
Needs Work
2: Does the utility implement a comprehensive, risk-informed system hardening strategy that includes design, construction, and protection improvements to reduce wildfire ignition risk, and are these programs prioritized, planned, and tracked based on wildfire risk, asset criticality, and engineering standards?
Lacks a complete prioritization framework based on wildfire risk classifications. Missing specific engineering standards alignments and tracking methods in capital planning. No evidence of how these programs are aligned with the overall wildfire mitigation strategy and risk models.
Underground Distribution Lines
Needs Work
2-1: Does your utility underground distribution lines in wildfire risk areas, complete or plan undergrounding projects in those areas, and use defined, risk-informed criteria (e.g., wildfire risk modeling, circuit criticality, ignition history, environmental constraints, and cost-benefit analysis) to determine when undergrounding is selected instead of other hardening measures?
Missing detailed criteria for undergrounding selection and prioritization based on wildfire risk; no evidence of a complete cost-benefit analysis comparing undergrounding to alternative measures; unclear integration into capital planning and tracking systems; lacks specific mention of project prioritization in High Fire Risk Areas. No references to federal or state funding sources utilized for undergrounding are provided, nor explicit adherence to the County Wildfire Hazard Overlay.
Conductor Coverage Programs
Needs Work
2-2: Does your utility deploy covered or insulated primary conductors (e.g., covered conductor, tree wire, or spacer cable) as a wildfire mitigation measure, and are wildfire risk classifications and circuit-specific risk factors primary drivers in determining where these programs are applied?
The WMP lacks specific documented evidence of federal funding applications or awards related to wildfire risk reduction (IIJA/BIL) and does not adequately describe coordination efforts with FEMA regarding hazard mitigation funding. Additionally, the continuous improvement metrics and detailed mapping against county overlay requirements are insufficient.
Non-Expulsion Fuse Conversion
Missing
2-3: Does your utility currently use expulsion fuses on transformers, taps, or lines, and are those devices restricted, replaced, or scheduled for conversion to non-expulsion or current-limiting devices in wildfire risk areas based on defined, risk-informed criteria?
The WMP does not adequately address the structured program for the replacement or restriction of expulsion fuses in wildfire-prone areas. Specifically missing elements include: risk-informed criteria for prioritizing replacements, documentation on tracking expulsion fuses, or integration into capital planning. No clear compliance with established standards like IWUIC 2024, CPUC 4 CCR 723-3, or County Wildfire Hazard Overlay requirements is noted related to fuse conversions.
Circuit Recloser Upgrade
Needs Work
2-4: Does your utility upgrade older reclosers to electronic, vacuum, or microprocessor-controlled units, and implement risk-based protection settings (e.g., fast trip, sensitive ground fault, or modified reclosing sequences) in wildfire risk areas or during elevated fire danger conditions?
The WMP does not provide detailed evidence of upgrading older reclosers to electronic, vacuum, or microprocessor-controlled units; it also lacks explicit coverage on risk-based protection settings being prioritized based on wildfire risk classifications and circuit exposure.
Inter-Phasing Spacing
Needs Work
2-5: Does your utility apply enhanced phase spacing, modified conductor configurations, or spacer cable installations in wildfire risk areas, and use defined, risk-informed criteria (e.g., wind exposure, conductor sway, vegetation interaction, or thermal loading) to prioritize those upgrades?
The WMP does not provide detailed criteria or a structured approach to determining when and how enhanced phase spacing or modified conductor configurations are applied in wildfire-prone areas. The evidence lacks specificity regarding risk-informed criteria like wind exposure, conductor sway, vegetation interaction, or thermal loading. Additionally, there are no documented measurable metrics illustrating a reduction in ignition risk or fault events related to conductor contact. Regulatory standards IWUIC 2024 §101.2, CPUC 4 CCR 723-3, and other relevant compliance obligations are not adequately addressed in the WMP.
Avian & Wildlife Protection Construction Standards
Needs Work
2-6: Does your utility incorporate avian or wildlife protection measures (e.g., insulated covers, animal guards, or perch deterrents) into construction and retrofit standards, and are these measures applied and prioritized in wildfire risk areas in alignment with APLIC or similar industry guidelines?
The WMP does not clearly demonstrate that wildlife protection measures are prioritized based on wildfire risk classifications. Specific guidelines like APLIC are not referenced, and it lacks outcome metrics to assess the effectiveness of these measures in reducing fault events. Moreover, the detailed mapping of utility structures within WUI areas and their respective compliance status against applicable standards is missing.
Copper Replacement Program
Needs Work
2-7: Does your utility maintain a structured program to replace or upgrade aging conductors, grounding components, and associated hardware to reduce failure and ignition risk, and are these activities prioritized based on wildfire risk, asset condition, and circuit exposure?
The WMP lacks clarity on whether the conductor replacement and upgrade activities are specifically prioritized based on asset condition, failure history, and wildfire risk classifications. It does not confirm if the replacement activities directly contribute to reducing the risk of ignition. Additionally, a comprehensive mapping and documentation of which high-risk assets have been targeted for replacement was not provided. There is no evident integration of the replacement program into capital planning or tracking through a work management system, nor a specific alignment with overall mitigation strategies. There are no measurable metrics that demonstrate a reduction in failure-related ignition risk. Missing evidence includes: - Detailed prioritization criteria for conductor replacements. - Documentation on how often and effectively replacement updates are tracked. - Specific outcome measures that link these upgrades with decreased ignition risk incidents. - Confirmation that updates were targeted consciously in High Fire Risk Areas based on systematic assessment.
Critical Facility Wildfire Hardening
Needs Work
2-8: Does the utility apply ignition-resistant construction practices, Class A roofing, ember-resistant vents, and defensible space requirements—including maintenance of the Immediate Zone around critical facilities such as substations, control buildings, communication facilities, and operations centers—in accordance with applicable wildfire-resistant construction standards, defensible space requirements, or equivalent state, regional, or local WUI regulations?
The WMP does not document the specific ignition-resistant construction practices for utility structures, nor does it provide a comprehensive inventory of utility-owned structures in WUI areas or their compliance statuses per IWUIC 2024 or CWRC 2025. Additionally, the WMP lacks details on defensible space maintenance around critical facilities, the Class A roofing confirmation, ember-resistant vent protection, and other structural hardening details.
Local WUI Code Compliance
Needs Work
2-9: Does the utility identify and comply with applicable locally adopted Wildland-Urban Interface (WUI) codes, wildfire-resistant construction standards, and related state, regional, or local regulations for the construction, alteration, operation, and maintenance of utility-owned buildings and facilities located within wildfire-prone or WUI-designated jurisdictions?
The WMP does not provide evidence demonstrating compliance with specific CWRC standards, including structure ignition hazard assessments (NFPA 1144), county CWRC adoption statuses, or a comprehensive inventory of utility-owned structures in WUI areas with FIC designations. Furthermore, it lacks documentation on permit and inspection coordination processes with local authorities, which are critical aspects of compliance.
Facility Defensible Space & Site Requirements
Needs Work
2-10: Does the utility implement and maintain a comprehensive, risk-based facility defensible space and site compliance program that aligns with applicable wildfire-resistant site standards, defensible space requirements, and state, regional, or local wildfire mitigation regulations, and is the program scaled according to wildfire hazard severity, fire intensity classifications, vegetation conditions, and site-specific wildfire risk?
Missing detailed mapping of defensible space zones and documentation of compliance with IWUIC 2024, NFPA 1 §27, IBHS FORTIFIED Wildfire Standards, and specific Colorado defensive space zones. There's no evidence of actual vegetation clearance practices or adherence to county standards.
Inspection & Maintenance
Needs Work
3: Does the utility implement a comprehensive, risk-informed inspection and maintenance program that identifies, prioritizes, and corrects asset deficiencies across transmission, distribution, and substation systems, and are these activities tracked, managed, and aligned with wildfire risk classifications, asset criticality, and defined standards?
The WMP does not sufficiently document the classification and prioritization of inspection findings or how these lead to systematic maintenance and repair actions. There is insufficient evidence regarding the integration of GIS or asset management systems for risk-based prioritization and no details on advanced tools beyond drone inspections, as mandated by regulatory standards.
GIS Inspection Tracking
Needs Work
3-1: Does your utility document inspection findings, hazards, and corrective actions in a GIS-based asset management system that is integrated with wildfire risk models, supports work management and lifecycle tracking, and enables prioritization, reporting, and decision-making?
The WMP does not fully document GIS-based asset management, nor does it show integration with wildfire risk models or work management systems. Specific evidence for GIS tracking, risk classification linkage, and lifecycle tracking is missing.
T&D Inspection Program & Prioritization
Needs Work
3-2: Does your utility maintain a formal T&D inspection program with defined inspection intervals and standards, use a structured hazard or condition rating system with risk-based prioritization and correction timelines, and track identified deficiencies through completion, particularly in wildfire risk areas?
The WMP does not fully meet the requirements around risk-based prioritization, structured hazard rating processes, and lifecycle tracking of deficiencies in wildfire risk areas. Specific gaps include the absence of a formal condition rating system, no mention of correction timelines, and inadequate evidence of a tracking framework through a work management system.
Intrusive Wood Pole Testing
Needs Work
3-3: Does your utility conduct scheduled intrusive inspections of wood poles using defined methods and intervals, and are poles that fail inspection prioritized for repair, reinforcement, or replacement using risk-based criteria and defined timelines based on structural condition and wildfire exposure?
The WMP does not provide evidence of scheduled intrusive inspections or defined methods for testing (e.g., boring, sounding), nor does it prioritize poles based on structural risk factors and wildfire exposure. There is no tracking process for inspection outcomes through a full lifecycle from identification to correction.
Substation Inspection Program
Needs Work
3-4: Does your utility conduct scheduled substation inspections with defined standards and documented equipment evaluations, and are identified deficiencies prioritized and corrected using risk-based criteria and defined timelines, particularly in wildfire risk areas?
While monthly inspections are documented, the WMP does not specify the detailed standards applied during inspections, the criteria for prioritizing deficiencies, or how corrective actions are systematically tracked post-identification. Regulatory standards related to comprehensive inspection protocols (e.g., NFPA 1144 §1.1.1) and Fire Intensity Classification (CWRC §303.2/§303.2.1) are not fully addressed.
Infrared Thermography Program
Needs Work
3-5: Does your utility conduct scheduled infrared thermography inspections on substations and/or distribution assets using defined standards and intervals, and are identified thermal anomalies prioritized and corrected using risk-based criteria, particularly in wildfire risk areas?
While monthly inspections are mentioned, the WMP lacks a structured infrared thermography inspection program with defined standards and intervals. There is no evidence of systematic classification of thermal anomalies or tracking of corrective actions. Additionally, the alignment with regulatory standards for wildfire risk reduction is not fully addressed.
Hazard Identification & Prioritization System
Needs Work
3-6: Does your utility use a formal hazard identification and prioritization system that classifies inspection findings using severity levels and risk scores (e.g., likelihood and consequence), and assigns risk-based correction timelines—particularly accelerating high-risk hazards in wildfire-prone areas—and tracks them through completion?
The WMP does not describe a formal hazard identification and prioritization system that classifies inspection findings using severity levels and risk scores, assigns risk-based correction timelines, or tracks these through completion. Specific elements such as standardized criteria for classification are missing. It lacks references to regulatory standards on hazard maps or assets positioning within Wildfire Hazard Areas.
sUAS / Aerial Inspection Program
Needs Work
3-7: Does your utility use sUAS (drones), LiDAR, or other aerial inspection methods to assess overhead infrastructure, and are these inspections applied using defined standards and integrated with risk-based prioritization and corrective action tracking, particularly in wildfire risk areas?
The WMP lacks comprehensive details on the integration of aerial inspection data with GIS and other asset management systems, as well as the risk-based prioritization criteria for inspections. There is no mention of lifecycle tracking from detection to closeout or how identified issues are mitigated and verified.
Operational Practices
Needs Work
4: Does the utility implement a comprehensive, risk-informed operational framework that adjusts system operations, deploys field resources, and executes emergency actions based on fire weather conditions, wildfire risk classifications, and situational awareness inputs, and are these activities governed by defined escalation levels, consistently applied, documented, and aligned with regulatory and internal standards?
Missing clear documentation of defined escalation levels, structured operational thresholds, and specific actions triggered by fire weather conditions. Coordination with emergency services and external fire restrictions are not explicitly mentioned.
Recloser & Protection Operating Mode Adjustment
Needs Work
4-1: Does your utility implement temporary protection operating mode changes during elevated wildfire risk conditions using defined fire weather and risk-based triggers, and are these changes consistently activated, managed, documented, communicated, and deactivated through established operational procedures?
The WMP lacks clear definitions of triggers for adjustments to protection modes and documentation of how these changes are communicated and tracked. Specifically, there is insufficient detail regarding the communication process to field and system operators, as well as insights into reverting to normal operations post-risk. It also does not adequately illustrate alignment with regulatory requirements such as the Fire Intensity Classification system.
Enhanced Protection & Fast-Trip Settings
Needs Work
4-2: Does your utility apply permanent enhanced protection settings (e.g., fast trip, sensitive ground fault, reduced or disabled reclosing) to circuits in designated wildfire risk areas based on defined criteria, and are these configurations documented, mapped to risk classifications, and periodically reviewed for effectiveness?
The WMP does not adequately document or map the enhanced protection settings to specific wildfire risk classifications, nor does it explain how these settings will be reviewed periodically for effectiveness. There is also insufficient evidence showing alignment with formal protection standards and no metrics provided for measuring the impact of these settings on ignition risk reduction.
De-Energization / PSPS Protocol
Needs Work
4-3: Does your utility maintain a documented PSPS or de-energization protocol with defined, risk-based activation criteria (e.g., fire weather, wildfire risk levels, situational awareness), incorporate staged escalation and impact assessments for critical infrastructure and essential services, and include defined processes for notification, implementation, and restoration?
The WMP does not clearly detail a multi-stage escalation process or impact assessments for critical infrastructure and essential services before power shutoff. It also lacks defined processes for customer notifications, coordination with emergency agencies, and lacks procedures for system restoration including post-event inspections.
High Fire Risk Patrols
Needs Work
4-4: Does your utility conduct enhanced or event-driven patrols during elevated wildfire risk conditions (e.g., Red Flag warnings or high wind events), using defined triggers, methods, and coverage criteria, and are findings documented and used to support corrective actions and operational decisions?
The WMP does not adequately define the triggers for enhanced patrols based on wildfire risk, nor does it document the methods, frequencies, or coverage criteria for these patrols. There is a lack of evidence showing how findings from the patrols are documented and used for corrective actions or operational decisions. Key references to applicable standards such as the CWRC Fire Intensity Classification and county Wildfire Hazard Overlay compliance are also missing.
Community Outreach & Pre-Event Notification
Needs Work
4-5: Does your utility maintain a formal communication protocol to notify customers and stakeholders of elevated wildfire risk conditions or operational changes, using defined triggers, multiple communication channels, and coordinated outreach to emergency services, critical infrastructure, and vulnerable populations?
The WMP does not adequately document specific outreach timelines, clear messaging processes, or defined triggers for notifications. Additionally, it lacks details on outreach to critical infrastructure and vulnerable populations as required by the standards.
Fire Season Crew & Contractor Protocols
Needs Work
4-6: Does your utility maintain and enforce documented fire season operating procedures for crews and contractors, including fire prevention measures (e.g., spark arrestors, extinguishers, hot work restrictions), and are these protocols adjusted based on wildfire risk conditions and consistently monitored for compliance?
The WMP does not document comprehensive operating procedures nor detail specific fire prevention measures like spark arrestors and hot work restrictions. Additionally, there is limited discussion on compliance monitoring through defined processes, and situational adjustments based on fire weather conditions and wildfire risk classifications are insufficiently covered.
Compliance with State & Local Fire Restrictions
Needs Work
4-7: Does your utility actively monitor and comply with applicable state, county, and federal fire restrictions, and are these requirements formally incorporated into crew and contractor operating procedures and enforced during elevated wildfire risk conditions?
The WMP lacks specific documentation of how external fire restrictions are formally incorporated into operating procedures for crew and contractor activities. There is insufficient detail on enforcement measures and documentation processes for compliance activities during elevated wildfire risk conditions.
Post-Fault Patrol & Temporary Trip Procedures
Needs Work
4-8: Does your utility require feeder patrols following fault or trip events (e.g., substation trips or recloser operations), particularly in wildfire risk areas, using defined trigger criteria, and are post-fault findings documented, prioritized, and tracked through corrective action before or after re-energization as appropriate?
The WMP does not fully satisfy the requirements for documentation of structured feeder patrols following fault events, defined trigger criteria (e.g., type of fault, fire weather conditions), nor does it provide detailed processes for documenting, prioritizing, and tracking post-fault findings using a work management system.
Wildfire Readiness & Escalation Framework
Needs Work
4-9: Does your utility maintain a documented wildfire readiness or escalation framework with defined operational levels tied to fire weather conditions, wildfire risk classifications, and situational awareness inputs, and are specific operational actions consistently linked, applied, and documented at each level?
The WMP does not fully describe a structured wildfire readiness or escalation framework with defined operational levels tied to fire weather conditions, nor does it detail specific operational actions consistently linked to each level. There is insufficient evidence that escalations are documented and communicated effectively, and it lacks alignment with applicable regulatory requirements.
Performance Metrics and Plan Monitoring
Needs Work
7: Does the utility implement a structured governance and performance management framework that assigns accountability for Wildfire Mitigation Plan actions, tracks implementation using defined metrics and reporting systems, monitors and audits performance for effectiveness, and incorporates results into formal plan approvals, stakeholder coordination, and continuous improvement processes?
The WMP does not provide explicit outcome metrics or a structured governance and performance management framework. It lacks detailed evidence regarding regular audits, performance reviews, and specific plans for documenting and incorporating lessons learned from stakeholders or audit findings.
Plan Accountability
Needs Work
7-1: Does your utility assign, document, and track responsibility for implementing Wildfire Mitigation Plan actions using defined ownership, timelines, and tracking systems, and are these responsibilities monitored through oversight and reporting processes?
While the WMP assigns the Manager of Operations responsibility, there is no structured system for tracking timelines, deliverables, or performance expectations for all actions. Oversight mechanisms require further documentation and review scheduling. Missing explicit details on how actions are monitored and reported, as well as detailed roles for other organizational levels.
Monitoring & Auditing WMP
Needs Work
7-2: Does your utility monitor and periodically audit Wildfire Mitigation Plan implementation using defined metrics and reporting systems, including internal and/or independent audits that verify completion, compliance, and effectiveness, and are findings documented and tracked through corrective action?
The WMP lacks explicit mention of a structured monitoring and auditing program, including defined metrics, reporting systems, and documentation of findings through corrective actions. There are no references to periodic internal or external audits that verify compliance or effectiveness of WMP activities.
Plan Approval Process
Needs Work
7-3: Does your utility maintain a documented and structured process for reviewing, approving, and updating the Wildfire Mitigation Plan, including defined governance roles, version control, and formal documentation of approvals and revisions?
The WMP does not clearly define governance roles, lacks documentation for approval processes, and does not provide an effective version control system. Additionally, there is no mention of how updates are informed by performance results, audit findings, or changing wildfire risk conditions.
Community Coordination & Outreach
Needs Work
7-4: Does your utility maintain a structured and ongoing community outreach program that communicates wildfire risk, mitigation activities, and safety information, and incorporates stakeholder feedback into planning and mitigation efforts?
Missing documentation of named CWPPs, coordination details, and specific stakeholder engagements as required by HFRA 2003 §101(d), USFS CWPP Guidance, and County CWPP Coordination.
Future Plans
Needs Work
7-5: Does your utility maintain a structured process to identify, prioritize, and implement future wildfire mitigation improvements based on monitoring results, audit findings, lessons learned, and changing wildfire risk conditions?
The WMP lacks a formalized process for documenting and integrating future mitigation improvements into capital planning. There is no evidence of a structured feedback loop or a formal mechanism for identifying and prioritizing gaps based on systematic analyses of monitoring results or lessons learned. Additionally, dedicated references to federal funding utilization, coordination with FEMA, and alignment with state and county standards are missing.
Introduction, Objectives & Purpose
Needs Work
0-1: A mature WMP introduction should include: (1) a formally labeled chapter with numbered, measurable objectives tied to risk reduction outcomes; (2) a purpose statement referencing state legislation, commission rules, and applicable wildfire code; (3) a defined plan scope by asset type and geography; (4) a plan structure overview (how chapters are organized); (5) version control and governing body adoption documentation; and (6) a brief characterization of the utility's wildfire risk environment that contextualizes the plan's priorities.
The report does not include clearly numbered, measurable objectives tied to risk reduction outcomes, lacks an explicit purpose statement that references state legislation, commission rules, and applicable wildfire code, and does not define the scope by asset type and geography. A clear structure overview is also missing.
Utility Profile & Infrastructure Overview
Needs Work
0-2: A mature utility profile should include: (1) an asset summary table with OH/UG miles, substations, circuits, poles, and customers — broken down by fire risk zone where applicable; (2) a service territory map with WUI overlay; (3) infrastructure age profile for high-risk asset categories; (4) a clear description of the utility type (IOU, cooperative, municipal) and the regulatory framework that applies; and (5) a summary of how the infrastructure overview informs the risk analysis and mitigation prioritization in subsequent elements.
The WMP is missing specific elements including: (1) a structured asset summary table breaking down assets by fire risk zone; (2) a clear service territory map with WUI overlay; (3) an infrastructure age profile; (4) a detailed description of the utility type and its regulatory framework; (5) a summary explaining how the infrastructure informs risk analysis and mitigation prioritization. It only partially complies with the specified requirements.
Service Territory Overview
Needs Work
0-3: A mature service territory overview should include: (1) counties and jurisdictions served; (2) terrain description with elevation range and WUI designation areas; (3) fuel model classification or vegetation type characterization; (4) climate summary — fire season timing, prevailing winds, drought/RH patterns, average Red Flag Warning days per year; (5) fire history summary — significant fires in or near the service territory in the past 10–15 years; and (6) explicit linkage to state-adopted wildfire hazard designations (e.g., HFTD zones, WHP tiers, FIC maps) applicable in the service territory.
The WMP does not fully describe terrain characteristics, predominant vegetation types, climate summary, fire history, and linkage to state-adopted wildfire hazard designations.
Risk Analysis & Fire Risk Drivers
Missing
0-4: A mature risk analysis should include: (1) fire risk drivers categorized by construction, operational, and service area risk — with supporting data; (2) a risk map showing infrastructure exposure by fire hazard designation (HFTD tier, WHP tier, FIC zone, or equivalent); (3) wildfire history within or adjacent to the service territory; (4) fire risk outlook — climate and fuel trends; (5) a documented risk methodology with cited data sources and analytical tools; and (6) explicit cross-references linking identified risks to mitigation programs in subsequent plan elements.
The WMP does not address critical elements of the risk analysis chapter, including: (1) categorized fire risk drivers, (2) risk mapping against fire hazard designations, (3) wildfire history within the service territory, (4) fire risk outlook based on climate and fuel trends, (5) documented risk methodology, and (6) cross-references linking risks to mitigation programs.
Fire Threat Assessment Mapping & Asset Table
Needs Work
0-5: A mature fire threat assessment should include: (1) a documented mapping methodology with data sources and GIS approach; (2) a map showing infrastructure overlaid on fire hazard/risk zone designations; (3) a structured asset table with miles of line, poles, substations, and circuits per risk tier; (4) an update methodology — when and how the mapping is revised; and (5) explicit linkage showing how the asset-by-zone table drives investment priorities in vegetation management, system hardening, and inspection programs.
The WMP lacks a comprehensive documented mapping methodology, an explicit asset table detailing miles of line, poles, substations, and circuits per risk tier, and does not sufficiently explain the update methodology for maintaining the mapping. It also fails to clearly link the asset-table to investment priorities in vegetation management and other programs.
Response & Recovery
Needs Work
6: Does the utility implement a structured response and recovery framework that ensures safe system restoration, coordinated communication, and customer support following wildfire events, and are restoration decisions based on defined criteria, documented field verification, and alignment with regulatory and internal standards?
The WMP does not fully satisfy the requirements of the Stafford Act or Colorado CPUC 4 CCR 723-3, particularly regarding the documentation of FEMA coordination and detailed emergency response protocols. Evidence supporting defined criteria for restoration decisions and post-event recovery efforts is incomplete.
Critical Event Messaging
Needs Work
6-1: Does your utility maintain a structured process for issuing timely, accurate, and multi-channel public communications during wildfire-related outages, de-energization events, or other emergency conditions, and are these communications triggered, updated, and coordinated based on defined protocols?
While GCEA has identified multiple communication channels, it does not specify defined protocols or timelines for messaging triggers during wildfire events. There is no documented coordination with local fire protection districts or emergency agencies as required by local standards.
Line Patrols Prior to Re-Energization
Needs Work
6-2: Does your utility require and document line patrols or inspections prior to re-energizing circuits following wildfire events, faults, or extended outages based on defined criteria, and are restoration decisions contingent on field verification of safe conditions?
The WMP partially addresses line patrols but lacks detailed procedures showing how inspections are documented, evaluated, and how they inform restoration decisions. The criteria for triggering line patrols based on specific risks such as wildfire exposure or outage duration are not clear. There is no explicit mention of coordination with local emergency services or the documentation processes that would substantiate the decision-making for re-energization.
Post-Disaster Customer Assistance
Needs Work
6-3: Does your utility maintain a documented process for providing post-disaster customer assistance, including ongoing restoration communications, targeted support for vulnerable or impacted customers, and coordination with agencies or community organizations?
The WMP does not document specific protocols for collaborating with local agencies for recovery efforts nor does it explicitly outline targeted support mechanisms for vulnerable customers. It also fails to mention the integration of FEMA funding or compliance with specific regulatory standards like 4 CCR 723-3.
Situational Awareness
Needs Work
5: Does the utility implement an integrated situational awareness capability that monitors fire weather, wildfire risk conditions, and operational indicators in real time, and uses defined thresholds, data integration, and coordination processes to support timely operational decision-making and response?
The WMP does not provide clear evidence of defined thresholds or escalation triggers for operational responses. It lacks comprehensive integration into centralized systems that align situational awareness outputs with operational actions and external responders.
Coordination with Emergency Services
Needs Work
5-1: Does your utility maintain formal coordination protocols with public safety agencies—including defined roles, communication channels, and escalation pathways—and does it share wildfire risk information and operational actions in a timely manner during planning and active wildfire events?
The WMP does not adequately define formal coordination protocols, including specific roles and communication channels with public safety agencies. There is also insufficient documentation regarding timeliness and consistency of shared wildfire risk information and operational actions as required under standards like NFPA 1 §27 / IFC §49 and local fire district IFC requirements.
NWS & Weather Monitoring
Needs Work
5-2: Does your utility monitor National Weather Service alerts and other relevant meteorological data (e.g., wind, humidity, temperature), and are these inputs integrated into wildfire risk models and operational decision-making processes using defined thresholds or triggers?
The WMP lacks detailed information on the integration of weather data into wildfire risk models and operational decision-making processes. There are also no clearly defined thresholds or triggers for escalation and operational actions. Furthermore, the continuous management and documentation of weather monitoring activities are not sufficiently supported.
Metric Monitoring
Needs Work
5-3: Does your utility track and analyze wildfire-relevant operational metrics (including leading and lagging indicators), and are these metrics used to identify risk trends and inform mitigation planning, prioritization, and operational decision-making?
The WMP lacks comprehensive tracking of both leading and lagging indicators, does not provide evidence of a dashboard or reporting systems, and does not clearly articulate how metrics inform decision-making processes. There is no mention of specific patterns or high-risk areas identified based on the tracked metrics.
Emergency Operations Center (EOC) Coordination
Needs Work
5-4: Does your utility maintain formal coordination with Emergency Operations Centers during wildfire events, including designated representatives, defined roles and communication protocols, and real-time information sharing to support unified response?
Missing clarity on real-time coordination during active events, specific roles of designated representatives in EOC interactions, and established communication protocols aligned with emergency management frameworks. No documentation of 24/7 availability during high-risk periods is presented.
State Wildfire Hazard Map Integration
Needs Work
5-5: Does the utility integrate official wildfire hazard maps, wildfire risk classifications, and fire intensity or severity designations into its GIS, wildfire risk modeling, asset prioritization, inspection planning, and operational decision-making processes to support risk-informed wildfire mitigation activities?
The WMP does not fully demonstrate the integration of official wildfire hazard maps into operational workflows and inspection planning. Specifically missing are detailed mappings of infrastructure against WHAs, references to risk classification systems adopted by the state, and documentation of compliance with WUI standards as per IWUIC 2024 and CWRC 2025.
Community Risk Assessment & POD Integration
Needs Work
5-6: Does the utility incorporate Community Wildfire Protection Plan (CWPP) risk assessments, operational planning zones such as Potential Operational Delineations (PODs), wildfire decision-support tools, and related community or regional wildfire planning outputs into its wildfire risk models, situational awareness platforms, mitigation prioritization processes, and pre-incident planning activities?
The WMP lacks a comprehensive list of identified CWPPs, lacks mapping showing utility assets in relation to CWPP priority areas, and does not document participation in CWPPs. There is insufficient detail regarding alignment with state-adopted hazard maps and failure to demonstrate coordination with relevant emergency response and community wildfire planning groups.
CWPP Action Plan Alignment
Needs Work
5-7: Does the utility incorporate vegetation management projects, treatment priority corridors, operational planning boundaries such as Potential Operational Delineations (PODs), fuel treatment priorities, and infrastructure hardening recommendations identified in applicable Community Wildfire Protection Plans (CWPPs) or related regional wildfire mitigation plans into its long-term grid hardening, vegetation management, fuel reduction, and wildfire mitigation work programs?
The WMP does not sufficiently demonstrate documented coordination with CWPP priorities, lack of named CWPPs covering the service area, and no clear evidence of alignment with fuel treatment strategies. It also fails to show participation in multi-stakeholder coordination groups or joint projects that utilize CWPP data effectively.
Vegetation Management
Needs Work
1: Does the utility implement a comprehensive, risk-based vegetation management program that includes structured inspection processes, defined clearance and vegetation treatment practices, hazard tree identification and mitigation (including dead, dying, or diseased trees both within and outside the right-of-way), enhanced requirements in high fire risk areas, and supporting systems for work tracking, quality assurance, and performance monitoring aligned with wildfire risk reduction objectives?
The WMP does not fully address the documentation of Community Wildfire Protection Plans (CWPPs) coordination, and lacks specifics about enhanced vegetation management requirements in high fire risk areas. Additionally, there is no information regarding the use of advanced technologies such as aerial inspections, LiDAR, or remote sensing. Performance metrics and details on the work tracking systems mentioned are incomplete or missing.
ROW Maintenance
Needs Work
1-1: Does the utility follow defined and compliant clearance standards and trimming specifications for transmission and distribution ROWs that account for vegetation growth, conductor sag, voltage class, and environmental conditions, and are these standards consistently applied, adjusted for wildfire-prone or high fire risk areas, and verified through inspection, work tracking, and quality assurance processes?
The WMP does not explicitly document ROW clearance standards adjusted for voltage classes and does not sufficiently detail the full lifecycle management process for ROW maintenance. It lacks specific inspection results or data trends that inform ROW activities and requires a more structured mapping of compliance with applicable standards (IWUIC 2024, 36 CFR 251.56, §502.1, §503.3).
Needs Work
1-2: Does the utility implement a defined vegetation management strategy—such as cycle-based, risk-based, or hybrid—that schedules and prioritizes ROW maintenance activities based on inspection findings, vegetation growth patterns, wildfire risk assessments, circuit criticality, and environmental conditions, and are maintenance activities adjusted for wildfire-prone or high fire risk areas to ensure timely mitigation of vegetation-related risks?
The WMP does not provide sufficient evidence or detailed descriptions of a formal planning process for vegetation management in high fire risk areas, compliance with federal ROW conditions under 36 CFR 251.56, or detailed performance metrics to evaluate the effectiveness of the plan. Additionally, there’s no documentation demonstrating alignment with county standards for defensible space requirements.
Pole Clearing
Needs Work
1-3: Does the utility implement and maintain a pole clearing program that meets regulatory and internal clearance standards, includes removal of flammable and hazardous vegetation (including dead or dying material), and applies enhanced requirements, tracking, and quality control practices in high fire risk areas?
The WMP does not sufficiently address enhanced pole clearing requirements for wildfire-prone areas or demonstrate compliance with specific regulatory standards for fire mitigation around utility structures. There is no evidence showing tracking or quality assurance protocols related to the pole clearing practice, nor does it adequately confirm adherence to CWRC 2025 or IWUIC 2024 guidelines detailed in the standards section.
Fuel Removal
Needs Work
1-4: Does the utility implement and maintain a comprehensive, risk-based fuel removal program that identifies, prioritizes, and removes combustible ground and ladder fuels in the ROW—such as pine needles, leaf litter, dead wood, downed trees, woody brush, and debris—beyond standard vegetation management practices, with enhanced requirements in high fire risk areas and supported by defined procedures, tracking, and quality assurance processes?
The WMP fails to establish a comprehensive fuel removal program that identifies and prioritizes fuel removal based on wildfire risk. The absence of defined methods for tracking and quality assurance processes, as well as the lack of measurable effectiveness metrics, means it does not meet the requirements of HFRA §101(d) regarding coordination with CWPPs and IIJA §40803 regarding federal funding pursuits. There's no documentation of enhanced treatment in high fire risk areas and limited information on managing ladder fuels and horizontal/vertical fuel continuity.
Hazardous and Incompatible Vegetation
Needs Work
1-5: Does the utility implement a comprehensive, risk-based program to identify, assess, and mitigate hazardous trees—including those outside the right-of-way—and incompatible vegetation species, using defined criteria, inspection processes, and prioritized treatment actions supported by tracking and quality assurance systems?
The WMP does not explicitly mention methods for systematic inspections that identify hazardous trees located outside the right-of-way. Further, there is no documented evidence or criteria for assessing incompatible vegetation species and their management through species-specific guidance. Additionally, there is insufficient information regarding routine tracking of hazard conditions and a lack of clarity on integration with quality assurance processes.
Vegetation Inspection and Remote Sensing
Needs Work
1-6: Does the utility implement a comprehensive vegetation inspection program that includes defined inspection types (e.g., patrol, detailed, aerial), risk-based inspection frequencies, and the use of remote sensing technologies (e.g., LiDAR, drones, satellite imagery), with inspection results integrated into work management and quality assurance processes?
The WMP lacks specific documentation on risk-based inspection frequencies for vegetation management, insufficient detail on how inspection results are integrated into work management processes, and missing QA/QC protocols for vegetation inspection. Key performance metrics and response to high-risk conditions are unclear. Regulatory standards related to vegetation management protocols are not fully addressed.
CWPP Coordination & Cross-Boundary Projects
Needs Work
1-7: Does the utility actively coordinate with local Community Wildfire Protection Plans (CWPPs), shared stewardship councils, and land management agencies to align vegetation management priorities, share risk data, and jointly implement cross‑boundary fuel reduction projects?
The WMP does not identify specific CWPPs by name or document participation as stakeholders. It lacks detailed coordination documentation with CWPPs, including maps showing utility assets versus CWPP priority areas, and relevant stakeholder correspondence. It does not mention alignment with state, federal, or county guidance or hazard maps.
Work Management, QA/QC & Performance Metrics
Needs Work
1-8: Does the WMP describe the enterprise systems used to track vegetation management work orders, backlog, and completion? Does it include quality assurance and auditing processes, contractor management standards, and measurable performance metrics to ensure work effectiveness?
Details on QA/QC audit processes, contractor management, performance metrics, and work order tracking are insufficiently addressed.