The CPUC, in their hatred for business, delayed PG&E’s efforts to modernize the transmission system.State and Federal governments bear at least as much responsibility as PG&E for their forest mismanagement and bureaucratic obstacles to clearing brush and trees.

Copyright 2019 Tony Lima. All rights reserved.
(There is a downloadable pdf version of this article at the bottom of this page.
But if you only read that you’ll miss the nifty video below.)

Executive Summary

There is plenty of blame to assign for wildfires. This article focuses on California but will also include some national data for the U.S. There are 4 main reasons for the upsurge in wildfires. In roughly the order of importance (my best guess), they are:

1. Failure of state and federal governments to adequately manage forest and brush lands that they own. Years of neglect have allowed dead trees and brush to accumulate as well as creating unhealthy forests. Reinvigorating logging in national forests would help quite a bit. So would more, larger prescribed fires (called “burns” in the business). Prescribed fires are proactive measures, as are logging and brush-clearing. Fire suppression (firefighting) is reactive. The California government needs to pay more attention to homeowners and businesses damaged by fires.
2. The California Public Utilities Commission (CPUC) has consistently opposed many PG&E requests for rate increases. Their objections have often been upheld by the Federal Energy Regulatory Commission (FERC). It takes money to repair and upgrade electricity transmission towers. Perhaps the CPUC could spend less time and energy on encouraging green energy and refocus their attention on their core mission.
3. The California process for obtaining a permit to log an area is excessively burdensome. In one case (discussed in detail below) a company submitted an application to log 32 acres on March 28, 2017. The application has not been approved as of today. The latest objection is that part of the 32 acres is potential nesting grounds for the marbled murrelet. The state has declared this bird an endangered species, but the federal government says it is only threatened. There are currently 17 documents in the application file with a total of 223 pages.
4. The state government and most of the mainstream media continuously slander PG&E. There is talk of the state taking over the utility. After all, the state of California has a demonstrated record of operating productive activities efficiently and with minimal bureaucratic interference. (That’s sarcasm in case you missed it.) Today PG&E is being assigned legal liability for 100 percent of damages from fires. The company is in bankruptcy.

That’s the overview. Read on for the excruciating details.

The Camp Fire Begins

At 6:30 am on November 8, 2018,^[1] a C-hook broke on PG&E electricity transmission Tower :27/222.^[2] This tower was part of the Caribou-Palermo 115 kV Transmission Line. Stressed by strong, dry, gusty winds from the east, the now-unsupported power lines broke under their own weight. The sparks ignited the Camp Fire, the most destructive wildfire in California history. By the time it was contained, it had consumed over 150,000 acres and claimed 86 lives.^[3] The foothill retirement community of Paradise was completely destroyed, leaving 27,000 residents homeless.^[4]

Fires have been part of nature since the earth cooled enough to support vegetation. Forest fires clear underbrush and dead trees. They also reduce the number of unhealthy trees. The question is why recent fires have been so large and intense. A secondary question is the role of governments, the private sector, and nature contributing to these fires.

Measures to control fires can be proactive or reactive. Proactive actions include prescribed fires, logging, and clearing dead trees and brush. The lone reactive activity is fire suppression. In the long run proactive measures are much more cost-effective. But when a wildfire is rapidly approaching your home or business, fire suppression sounds like a pretty good idea.

Blame-casting

After the Camp Fire was controlled, the real fun began: finger-pointing. The state government and most of the media blamed PG&E for not maintaining the tower that failed. PG&E pointed out that CPUC had regularly lobbied against rate increases to cover the cost of maintaining and replacing transmission lines. The company filed a response to a request for information by Judge Hon. William Alsup of the U.S. District Court Northern District Of California, San Francisco Division. The following paragraph is from page 1 (emphasis added).^[5]

In its filings with the Federal Energy Regulatory Commission (“FERC”), PG&E has sought and continues to seek authorization to set the rates it charges for electric transmission services at levels sufficient to support, among other things, replacement of aging equipment over time. When PG&E files its transmission revenue requirement requests with FERC, the other participants in those proceedings, including the California Public Utilities Commission (“CPUC”), PG&E’s wholesale transmission customers, and FERC Trial Staff review the filings while also conducting discovery related to PG&E’s requests. In the past, those participants have questioned PG&E’s proposed level of spending on transmission assets. For example, in a 2017 ratemaking proceeding, the CPUC stated, “While the CPUC recognizes that repair and replacement are necessary components of a utility’s operation, the amount that PG&E has been spending on what appears primarily to be replacement of transmission facilities is staggering and potentially unjustified.” (Ex. A, Initial Br. of the CPUC, Pacific Gas and Electric Co., Dkt. No. ER16-2320-002 (Mar. 15, 2018) at 8.) The CPUC also stated there was reason to believe that PG&E was “‘gold plating’ the system” and “unreasonably burden[ing] ratepayers with unnecessary costs.” (Id. at 2-3.) This ratemaking process has resulted in settlements at amounts less than what PG&E initially requested. Going forward, PG&E hopes to work with all relevant stakeholders to re-calibrate the level of investment in transmission asset replacement that will be supported in light of the unprecedented wildfire risk California is now facing.

In summary, PG&E said they wanted to replace and repair transmission towers but the California Public Utilities Commission (CPUC) recommended allowing lower rate increases that did not cover the cost of the projects. The phrase “’gold plating’ the system” is especially incendiary (sorry).^[6]

Technical Issues^[7]

These transmission towers are not wooden poles. They are the large steel structures that support many heavy lines. PG&E was replacing some towers following the recommendations of the North American Electric Reliability Corporation (“NERC”). The reason for the work was to increase the distance between transmission line conductors as well as the distance from the ground. In other words the replacement towers were taller, wider, and further apart than the originals. PG&E reported that they had dealt with 10,000 of the 11,500 conductor clearance issues in their system.

Ironically, however, Tower :27/222 was not scheduled for replacement. Whether the tower had been inspected remains unresolved. In any case, questions remain about the allocation of responsibility between the company and CPUC.

Weather and Vegetation

In October and November, western California is buffeted by strong, gusty winds from the east. In the southern part of the state, these winds are called Santa Ana’s, named after the Santa Ana Canyon in Orange County.^[8] In northern California their given name is Diablo Winds, after Mt. Diablo in Contra Costa County (northern Livermore Valley). Gusts of 40 to 50 miles per hour are common.^[9] Over the past two years the strongest gusts have been between 60 and 90 miles per hour.

People who do not live on the west coast often overlook one important fact. There is virtually no rain between April and November. By October, trees and underbrush are very dry. This vegetation is blasted by hot winds and very low humidity. The dry vegetation becomes parched. It can ignite if a single ember falls onto it.^[10] Once that happens, a new fire flares up, creating a new batch of embers. Keep in mind that these sparks are being carried by heavy winds. Roads, highways, and even professional firebreaks can be and sometimes are breached.

Forest Mismanagement

President Trump has blamed forest management policies for exacerbating the wildfires. Speaking as someone who has hiked extensively in California, I can personally affirm this opinion. Dead and fallen trees are common. Underbrush is allowed to grow, as are grasses. The brush is largely tolerant of dry conditions. The grasses are not. They die in the late summer and provide fodder for flames.

But Mr. Trump may be incorrect about casting all the blame at the state government. As of 2013 the Federal government owned 45.8 percent of all the land in California (45,864,800 out of 100,206,720 acres).^[11] The state owns 4 percent, leaving about half the land in private hands. The Federal government owns 57 percent of the forested acreage in the state.^[12]

In one of the rare instances where the California government tried to implement proactive, preventive procedures, the state legislature was stymied by then-governor Jerry Brown.^[13] In 2016 a bill passed both houses of the legislature on unanimous votes.

SB 1463 had been introduced in last year’s legislative session by Sen. John Moorlach, R-Costa Mesa. The bill would have required the state to identify the places most at risk for wildfires and would have required the CPUC to beef up plans to prevent fires sparked by power lines — including moving lines underground if necessary.

But Brown said the bill was unnecessary. “Since May of last year, the Commission and CalFire have been doing just that through the existing proceeding on fire-threat maps and fire-safety regulations,” he said in his veto message. “This deliberative process should continue and the issues this bill seeks to address should be raised in that forum.”

But the senator isn’t buying it.

“Up until my bill those guys were doing nothing,” Moorlach said Wednesday. “I think you got some false information.”

He said his bill would’ve sped up what had become a cumbersome process and given local communities more of a voice by clarifying how fire risk is defined.

Had the governor signed his bill into law, he added, “I think it would have changed things. … I think it would’ve given Cal Fire a whole different set of priorities.”^[14]

While SB 1463 might have improved the situation, it remains a fact that the state only owns 4 percent of the land in California. Cal FIRE is also responsible for fighting fires on privately owned land, putting the state in charge of 54.2 percent of property within its borders. What about the 45.8% owned by the federal government?

Bureaucratic Obstacles

One issue is bureaucratic obstacles to private landowners removing brush and dead trees from their property. In 1990 the Environmental Protection Agency added the Northern Spotted Owl to the endangered species list. Because of this a vast swath of the northern California timber industry was eliminated. The results are as one would expect.

Consider U.S. National Forests. Signs in these parks call them “Land of Many Uses.”

In the now-distant past logging was actively encouraged in these forests. The U.S. government sold leases on specific tracts, including the right to build roads to haul the timber out of the forest. These roads were also firebreaks. Under pressure from environmentalists, President Clinton limited the construction of new roads on 49 million acres of national forest. Without roads to remove the timber, there is little point in logging a forest and a valuable fire containment tool is lost. ^[15]

The data shows what happened. Timber harvesting from the National Forests peaked at 12.7 trillion board feet in 1987. In 2002, the harvest was 1.7 trillion board feet, a decrease of 86 percent. Figure 3 shows the history and magnitude of this decline.^[16]

What happens to forests that are not logged? Trees sprout everywhere while older plants die. The result is a combination of sickly and dead trees with mounds of dead underbrush. The forest has effectively become a heap of very large matchsticks.

​Former Representative Tom McClintock put it best in a press release supporting the Resilient Federal Forests Act in 2015.^[17]

Excess timber comes out of the forest one way or the other.  It is either carried out or it is burned out.

When we carried it out, we had healthy forests and a thriving economy.

We managed our National Forests according to well-established and time-tested forest management practices that prevented vegetation and wildlife from overgrowing the ability of the land to support it.  Revenues from the sale of excess timber provided for prosperous local economies and a steady stream of revenues to the treasury which could, in turn, be used to further improve the public lands.

But 40 years ago, in the name of saving the environment, we consigned our national forests to a policy of benign neglect.

The results are all around us today: impoverished mountain communities and a devastated environment.

But the bureaucratic burden can be almost as bad as the overt policies. In order to harvest trees on private land in California, property owners must first submit a Timber Harvesting Plan (THP). How hard can that be? Here’s a short video that scrolls through the entire review process. Feel free to stop it at any time to read the details.^[18]

But what, exactly, goes into such a plan? First, you need to know that there is an entirely separate bureaucracy that evaluates THP applications: CalTrees.ca.gov. Visit https://caltreesplans.resources.ca.gov/Caltrees/Report/ShowReport.aspx?module=TH_Document&reportID=492&reportType=LINK_REPORT_LIST and click on any application link. Start to browse the pdf documents listed below the basic information.

I took a look at the first application on the list, THP 1-17-030-HUM. This application was filed March 28, 2017. The applicants want to log 32 acres of timber in Humboldt County. The last document in the file is dated May 3, 2019. It’s a summary of the likely impact of the project on potential nesting grounds for the marbled murrelet. The state lists this bird as endangered, but the federal government calls it threatened. There are a number of mitigation measures required, many of which seem to reduce the acreage available for logging.

There are 17 documents in the application file totaling 223 pages. The sheer amount of time put into this application is astonishing. And all this for a chance to log 32 acres, a very small stand of forest.

It’s now mid-November, fully six months after the last document was filed. I have asked the company for additional information about the status of this application.

Prescribed Fires

The best method for managing forests is controlled (prescribed) burning.^[19] But for decades the National Forest Service has diverted resources from prescribed fires to fire suppression. In 1995 the California Department of Forestry and Fire Protection (CDFFP) stated, “Land and fire management have in many cases increased fire hazard. In some shrub types, fire suppression appears to have shifted the fire regime away from more, smaller fires toward fewer, larger fire.”^[20] 

And, of course, the California Air Resources Board is reluctant to approve burning of, well, practically anything.^[21]

The National Interagency Fire Center compiles data on various aspects of wildfires. One interesting statistic is the number and size of prescribed fires.^[22] Interestingly both the number of fires and acres burned have increased sharply since 2014. Figure 5 shows prescribed acres burned, Figure 6 shows the number of prescribed fires, and Figure 7 shows the average size of each prescribed burn. Again, starting in 2014 the average prescribed fire got smaller and smaller. In 2014 the average size of a prescribed fire was 140.21 acres. By 2018 that had shrunk to 14.12 acres, about 10 percent the size of the average fire in 2014. The reason for this remains a mystery.^[23]

For better or worse (likely the latter), a draft 2018 update to the 1995 CDFFP plan uses the word “prescribed” exactly once in a seven page document. Much of the focus there is on fire suppression. That word appears 11 times. Climate change is also blamed.^[24]

Fire Suppression of Wildfires

Fire suppression is the opposite of prescribed fires. Suppression is what you see on the news when firefighters and other first responders are backlit by walls of flames. Unlike prescribed fires, fire suppression is very dangerous. The fires themselves can, of course, be very destructive. It almost goes without saying that prescribed fires are superior to fire suppression. Yet funds are regularly diverted from the former to the latter. The reason, of course, is that a wildfire is very immediate and an emergency. Prescribed fires are economically superior and will be far more beneficial in the long run. But they do not solve the problem of immediacy that a wildfire conveys.

Between 1985 and 2018 federal spending on fire suppression rose by 8.1 percent per year.^[25] Figure 8 shows how this spending has grown since 1985.

The number and size of wildfires is heavily dependent on weather. In California, if the winter rains begin in October, there will be fewer, smaller fires. As of mid-November 2019 there has been virtually no rain. But cooler temperatures also help, as do the moisture-laden winds that usually blow in from the Pacific.

Conclusion

But one thing is for sure. The CPUC, in their hatred for business, delayed PG&E’s efforts to modernize the transmission system. For this alone they should be ashamed. California’s state government and the Federal government bear at least as much responsibility as PG&E for their forest mismanagement and bureaucratic obstacles to clearing brush and trees. Finally the state government and mainstream media have engaged in a long-term campaign to demonize the utility. This is reprehensible.

1. Kurtis Alexander, Lizzie Johnson, Gwendolyn Wu, and Erin Allday (November 9, 2018). “Camp Fire devastates Paradise near Chico — businesses, church, numerous homes burn.” SFGate.com. Available at https://www.sfgate.com/california-wildfires/article/Evacuations-ordered-across-Butte-County-as-Camp-13374840.php. Accessed October 12, 2019. ↑
2. PG&E (July 31, 2019). “PACIFIC GAS AND ELECTRIC COMPANY’S RESPONSE TO REQUEST FOR INFORMATION.” Judge: Hon. William Alsup, Case 3:14-cr-00175-WHA Document 1078 Filed 07/31/19. Available at http://s1.q4cdn.com/880135780/files/doc_downloads/wildfire_updates/1078.pdf. Accessed October 10, 2019. ↑
3. Dowd, Katie (August 11, 2019). “Nine months after it burned, the Camp Fire takes its 86th victim.” SFGate.com. Available at https://www.sfgate.com/california-wildfires/article/camp-fire-victims-death-toll-14296018.php. Accessed October 12, 2019. ↑
4. Kurtis Alexander, et. al. (2018). Op. cit. ↑
5. PG&E (July 31, 2019). Op. cit. ↑
6. For those unfamiliar with this phrase, it is usually a pejorative. It refers to the habit of some wealthy individuals gratuitously putting their riches on public display. One technique sometimes used is to gold plate objects commonly carried such as canes and money clips. ↑
7. Material in this section is from PG&E (July 31, 2019). ↑
8. Santa Ana winds. https://en.wikipedia.org/wiki/Santa_Ana_winds#Etymology. Accessed October 29, 2019. ↑
9. Simon, Matt (November 9, 2018). “The Terrifying Science Behind California’s Massive Camp Fire.” Wired. Available at https://www.wired.com/story/the-terrifying-science-behind-californias-massive-camp-fire/, Accessed October 12, 2019. ↑
10. Ibid. ↑
11. Ballotpedia (2013) “Federal land ownership by state.” https://ballotpedia.org/Federal_land_ownership_by_state. Accessed October 30, 2019. ↑
12. Skurk, Krystina (November 16, 2018). “How Misguided Environmentalism Is To Blame For California’s Wildfires.” The Federalist. Available at https://thefederalist.com/2018/11/16/misguided-environmentalism-blame-californias-wildfires/. Accessed October 29, 2019. ↑
13. Matthias Gafni and Emily DeRuy (October 12, 2017) Bay Area News Group. “Wine Country fires: Gov. Brown vetoed 2016 bill aimed at power line, wildfire safety.” Available at https://www.mercurynews.com/2017/10/11/wine-country-fires-gov-brown-vetoed-2016-bill-aimed-at-power-line-wildfire-safety/. Accessed October 31, 2019. ↑
14. Ibid. ↑
15. Much of the material in this section is from Skurk (2018). Op. cit. ↑
16. U.S. Forest Service (2017). “Forest Products Cut and Sold from the National Forests and Grasslands.” https://www.fs.fed.us/forestmanagement/products/cut-sold/index.shtml. Accessed November 14, 2019. ↑
17. McClintock, Tom (July 9, 2015). Press release in support of the Resilient Federal Forests Act. Available at https://mcclintock.house.gov/newsroom/press-releases/resilient-forests-act. Accessed November 10, 2019. ↑
18. CalFIRE Timber Harvesting Plan Review Process (2019). Available at https://www.fire.ca.gov/programs/resource-management/forest-practice/timber-harvesting/timber-harvesting-plan-thp/. Accessed November 10, 2019. ↑
19. California Environmental Protection Agency (February 7, 2003). “Prescribed Burning and Smoke Management.” Available at https://www.arb.ca.gov/smp/progdev/pubeduc/pbfs.pdf?fbclid=IwAR39NlS2B8Nw6dnBGGirdhMSXtMmU_hWnJAVZ4lKbLmthc0J-MIyyWAQz4w . Accessed October 30, 2019. ↑
20. California Department of Forestry and Fire Protection (August 28, 1995). “Fire Management for California Ecosystems.” Available at https://frap.fire.ca.gov/media/2138/fire_management_for_california_ecosystems.pdf. Accessed October 30, 2019. ↑
21. Thanks to Jeff Bennett (@lyakmon) for making this point to me on Twitter.
22. National Interagency Fire Center (2019). “Prescribed Burns and Acres by Agency.” Available at https://www.nifc.gov/fireInfo/fireInfo_stats_prescribed.html. Accessed October 30, 2019. ↑
23. Email inquiries with the relevant agencies produced nothing useful. ↑
24. California Department of Forestry and Fire Protection (2018). “Chapter 0340 – Fire Protection 0341‐0342.4.1, 0342.6‐0342.6.2. 2018 Revisions.” Available at https://bof.fire.ca.gov/media/7736/rpc-2-board-fire-protection-policies.pdf. Accessed October 30, 2019. ↑
25. National Interagency Fire Center (2019). “Prescribed Burns and Acres by Agency.” Available at https://www.nifc.gov/fireInfo/fireInfo_stats_prescribed.html. Accessed October 30, 2019. Plus author’s calculations. I looked at the figures corrected for inflation. The patterns of the real and nominal spending are close to identical. Nominal spending averaged 2.3 percentage points higher than real spending over this time interval. ↑