2018 Camp fire and Pacific Gas and Electronics (PG&E)
Imran Hasan Siddiquee, MISAM
Concordia university of Edmonton
Edmonton AB
isiddiqu@student.concordia.ab.ca
Abstract: This paper examines 2018
campfire caused by Pacific Gas and
Electric (PG&E) company & how they
performed in the context of contingency
planning. The various components of
Contingency planning and how PG&E
company performed under this
framework. The importance of disaster
recovery and business continuity plan are
also discussed.
Keywords – IRP, DRP, BIA, BC, CPUC
Ⅰ. INTORDUCTION
A company's response to an unforeseen
circumstance that jeopardizes operations, is
to implement the contingency plan. The
suitable reaction included in the plan varies
according to the occurrence. The role of
contingency planning management team is
to identify potential threats to the company
and develop plan to reduce their effects and
resume business operations.
Electrical transmission lines belonging to
Pacific Gas & Electric, a San Franciscobased utility company caused the Camp Fire
of 2018, California’s deadliest wildfire. The
fire, which started on Nov. 8 near the city of
Paradise, Butte County, California killed 85
people and destroyed nearly 19,000 homes,
businesses and other buildings. The
California Department of Forestry and Fire
Protection investigated the incident and
determined electrical transmission lines
owned and operated by PG&E caused the
fire and later PG&E admitted the same.
Following the event PG&E, the state’s
largest electricity utility, filed for
bankruptcy protection, saying that it faced
an estimated $30 billion in wildfire
liabilities. In a filing to securities regulators,
the company estimated it would have $10.5
billion in liabilities for damage caused by
the Camp Fire. [1]
Investigators have confirmed that it
originated from PG&E-controlled electrical
transmission lines near the community of
Pulga, located nearly 100 miles north of
Sacramento. Dry vegetation, strong winds
and low humidity strengthened the fire,
causing extreme rates of spread that ravaged
the nearby communities of Concow,
Paradise and Magalia. Investigators said a
second fire started after vegetation blew into
electrical distribution lines owned by PG&E.
That blaze was overrun by the fire
originating near Pulga. [2]
ⅠⅠ. What went wrong?
When PG&E bought Great Western Power
Company in 1930, it also acquired the
Caribou-Palermo transmission line that was
in place at the time of the accident, the
transmission line was 97 years old because it
was first constructed in 1921. Even though
PG&E owned the line for nearly a century, a
large portion of the original hardware was
never updated. In 2018, hardware from the
early 20th century was still in use on the
line, and hardly any records were made or
maintained!
Investigators found that prior to the incident,
cost cutting was endemic as far as inspection
and maintenance was concerned to increase
profitability with little regards to possible
consequences of equipment failure. PG&E
had been resisting upgrades to its electrical
equipment’s. It was also found that dozens
of such pushbacks: for example, the
company fought a proposal by California
Public Utilities Commission (CPUC), the
regulatory body that oversee all services and
utilities in California to report every fire its
equipment caused, mentioning that such
measures as an unnecessary cost of time and
resources in a 2010 filing. [3]
more, PG&E resisted, calling the concept
"misplaced" for a number of reasons: It was
categorized under the wrong legal
framework, repeated existing plans, and
made the erroneous assumption that
"utilities (or anybody else) can predict
wildfires started by power. [3]
ⅠⅠⅠ. Contingency Planning
A contingency plan is employed to
anticipate, respond to and recover from
events that threaten the organization’s
security of information and assets, as well as
to restore the organization to normal modes
of operation. We will discuss the 2018 camp
fire caused by PG&E in light of contingency
planning and see where it went wrong.
The following year, responding to another
proposal by CPUC, its attorneys wrote that
PG&E did not agree that, it is necessary to
require a formal plan specific to fire
prevention. The Northern California
company argued to regulators that it
shouldn’t be held to the same standards as
its Southern California counterparts, saying
wind-driven fire risk in its territory was
significantly lower than in Southern
California. PG&E could have upgraded its
systems and passed along those costs to its
consumers as rate increases. [3]
Contingency planning typically consists of
four components:
Another CPUC proposal would mandate
electricity providers to develop backup plans
for the severe winds that can spark swiftly
spreading, catastrophic wildfires. After
determining which equipment would be at
risk from windstorms, the utilities could take
additional safety precautions like power
shutoffs or fortify the equipment. Once
A. Business impact analysis (BIA)
It’s an investigation and assessment of the
impact that attacks can have on the
organization. BIA provides in details of
potential impact from identified threats.
In this case of PG&E, we know that the
company was aware of the risk of 97 years
old power lines running through the wild
fire prone areas but never understood the
impact it might have on their business. [4]
PG&E’s 2015 Corporate Risk Register first
included the threat of wildfires as a
significant risk. However, the company’s
2017 CERP, finalized less than two months
before the November wildfires, did not
include the terms ‘fire’ nor ‘wildfire.’ [5]
The culture in the company was to
pushback, resisting reforms in this matter
and describing the measures as unnecessary
cost. So, planning and preparation of such a
threat was limited.
But PG&E had insurance coverage taken for
wildfire and recorded $1.38 billion for
probable insurance recoveries in connection
with the 2018 camp fire [6], which covers a
tiny part of the total liability of $10.5 billion
in liabilities for damage caused by the Camp
Fire.
B. Incident response plan (IRP)
The actions an organization are expected to
take while an incident is in progress are
defined in the IRP document. It also
describes how do we respond & recover
from an incident.
Since 2005, units of government and private
sector owners of critical infrastructure which
received federal funding are required to fully
implement the Incident Command System
(ICS) for emergency response operations.
After-Action Reports on the Camp Fire
indicate that PG&E management did not
follow the ICS reporting structure in the
company’s emergency operations center in
preparation for, and during, the incident. [5]
PG&E had acted before 2018 wildfire to
implement incident command system (ICS)
but review of the documents and interview
with PG&E emergency management official
identified that the company had not fully
implemented ICS before the fire. [5]
PG&E also admits that there was no crisis
management plan in place for the year 2018
that made full use of the senior management
team's oversight throughout planning and
reaction actions. [5]
C. Disaster recovery plan (DRP)
DPR is the strategy employed to recover
from a disaster. It may include plan to limit
loss before and during a disaster. DRP is
fully deployed when the disaster has
stopped. It can be seen as an extension of
IRP.
D. Business continuity Plan (BCP)
BCP describes how an organization will
continue to operate during a disaster and
afterwards while the DRP is implemented to
restore the primary site. It is the most
strategic and long term of the 3 plans in
contingency planning. BCP is employed
when the scope or scale of a disaster exceeds
the ability of the DRP to quickly restore
operations. A related tool in contingency
planning is business resumption plan which
is used to merge DRP and BC together.
Following the 2018 wildfire, PG&E took
many initiatives to recover from the disaster
and continue their business:
To help those affected by the fire,
particularly those who are uninsured or
require assistance with alternative living
expenses or other urgent requirements,
PG&E established a $105 million "wildfire
assistance fund" funded by shareholders. [7]
Additionally, PG&E has promised to
underground power distribution lines in the
Camp Fire zone, including in the Town of
Paradise. PG&E has so far spent over $100
million rebuilding the gas and electricity
infrastructure in the Paradise area. [7]
In order to complete the job safely and
effectively, the company created a dedicated
rebuild Team with over 400 employees as
well as an officer steering committee. The
company also actively supporting customers
with them rebuild efforts by guiding them
through the service planning process, which
is unfamiliar to many customers. [7]
Customers who rebuild using energy-saving
techniques, switch to solar power, or go
entirely electric can now take advantage of
greater incentives from PG&E. For
consumers who receive building permits this
year to replace a home lost in a recent big
catastrophe like the Carr or Camp fires,
PG&E's Advanced Energy Rebuild project
program was extended beyond 2020 in
January. In homes rebuilt following a
wildfire, customers can get up to $12,500 in
rebuild incentives by using energy-efficient
construction techniques. This applies even if
the home is constructed outside of PG&E's
service area. [7]
In order to reduce the risk of wildfire in its
service area, PG&E has significantly
increased safety and is still investing in
technology and infrastructure:
Over 700,000 transmission, distribution, and
substation assets of its electric infrastructure
in high-risk locations for fires underwent
improved and expedited inspections in
2019.All of the highest-priority issues
discovered during inspections of its
transmission, distribution, and substation
assets have been fixed or made safe. [7]
To improve situational awareness PG&E
installed 1030 weather stations, installed 346
high-definition cameras by the end of 2020.
NOAA satellite data being added into
PG&E’s detection and alert system.
Upgraded wildfire safety operation center to
operate 24/7 and monitor fire threats. [7]
To harden the electric system and improve
readiness, 241-line miles have been
hardened. Selected, strategic
undergrounding of distribution where key
lengths of line serving isolated communities
pass through high fire risk areas, installed
298 sectionalizing devices in 2019. System
automation – continue to enable Supervisory
Control and Data Acquisition (SCADA)
devices and reclosers to prevent
reenergization after a fault. [7]
Conducting enhanced vegetation
management: 2,498-line miles cleared using
enhanced procedures to meet important
State standards on clearances; targeting
1,800 distribution line miles in 2020 (400
completed) [7]
Wildfire victims’ settlements reached: A $1
billion settlement with cities, counties, and
other public entities, of which over $500
million will go to Butte County entities.
An approximately $13.5 billion settlement
resolving claims by individual victims
relating to the 2015 Butte Fire, 2017
Northern California Wildfires (including the
2017 Tubbs Fire), and the 2018 Camp Fire
and an $11 billion agreement with insurance
companies and other entities that paid claims
by individuals and businesses related to the
wildfires. [7]
Pacific Gas & Electric Company amended
their wildfire safety plan in February 2019
where they have overhauled their old
wildfire safety plan describing the new
enhanced, accelerated program will
aggressively continue to implement to
prevent wild fire. PG&E submits this Plan to
prepare plans on constructing, maintaining,
and operating their electrical lines and
equipment to minimize the risk of
catastrophic wildfire. California Public
Utilities Commission established a schedule
for submission and review of the initial
wildfire mitigation plans, and a process for
review and implementation of plans to be
filed in future years.
iv. Conclusion
Before the 2018 campfire, on several
occasion PG&E were responsible for wide
spread wild fires but it seems they did not
learn much from those incidents and put the
whole company in jeopardy to minimize
cost and increase profit. The fact that the
original transmission line was nearly century
old gives a clear idea that they would not
replace anything before it breaks down gives
a strong indication the company is heading
towards a disaster given the terrain it
operates is highly vulnerable to wild fires. It
seems from Business impact analysis point
of view, PG&E had very little understand of
what can happen in case of big wild fires
caused by them like 2018 campfire. They
seemed very ill prepared for incident
response and PG&E management was found
not follow the ICS reporting structure during
2018 campfire. Even on many occasions
they push back the suggestion made by their
regulatory body, CPUC to take action in this
regard. All those discussed above gives a
clear indication that PG&E management had
a very poor approach towards contingency
planning before the incident.
It took a disaster of epic proportions and a
sweeping change in state law to force PG&E
to finally create a rigorous, enforceable fire
protection plan. In 2019 PG&E published a
separate wild fire safety plan which isvery
detail in nature and require significant
investments. Since the event of campfire
PG&E have acted to overhaul the old
transmission line, taking lines underground,
conducting enhance vegetation management
etc. to avoid further disaster.
It’s imperative that management of a
company should be very much aware of
environment it’s operating, the risk which
might affect the company and have good
contingency plan to tackle in case any of the
risk materializes.
V. Works Cited
[1] Peter Eavis and Ivan Penn, “California Says
PG&E Power Lines Caused Camp Fire That Killed
85” May 15,2020 (online)
Available:https://www.nytimes.com/2019/05/15/busi
ness/pge-fire.html [Accessed 21 October 2023]
[2] Michael Brice-Saddler, “PG&E power lines to
blame for California’s deadliest wildfire ever,
officials say”, The Washington
post(online).Available:
https://www.washingtonpost.com/nation/2019/05/15/
camp-fire-caused-by-electrical-lines-owned-operatedby-pge-authorities-say/ [Accessed 21 October 2023]
[3] Katie Worth, Karen Pinchin, Lucie Sullivan
“Deflect, Delay, Defer”: Decade of Pacific Gas &
Electric Wildfire Safety Pushback Preceded
Disasters. August 18, 2020. (online) Available:
https:// www.pbs.org/wgbh/frontline/article/pgecalifornia-wildfire-safety-pushback/ [Accessed 22
October 2023]
[4] Lewin Day, “Closely examining how a PG&E
transmission line claimed 85 lives in the 2018 camp
fire” Septem17,2020 (Online) Available:
https://hackaday.com/2020/09/17/closely-examininghow-a-pge-transmission-line-claimed-85-lives-in-the2018-camp-fire/ [Accessed 23 October 2023]
[5] Envista Forensics, Inc. & Subcontractor Witt
O’Brien’s, “Root Cause Analyses: Root Cause
Analyses of the 2017-18 Wildfires found to have
been ignited by PG&E & Corrective Action Report.”
July 6,2022. (online) Available:
https://www.cpuc.ca.gov/-/media/cpucwebsite/divisions/safety-policy-division/reports/rootcause-analyses-of-the-2017-18-wildfires_070622.pdf
[Accessed 23 October 2023]
[6] Wildfire related contingencies
September 30,2020. (Online) Available:
https://www.sec.gov/Archives/edgar/data/1004980/0
00100498020000058/R19.htm [Accessed 24 October
2023]
[7] PG&E actions since the 2018 camp fire
(Online) Available:
https://www.pge.com/en_US/safety/emergencypreparedness/natural-disaster/wildfires/pgeactions.page [Accessed 24 October 2023]