CPUC fire incident reporting: the one question it asks about the tree

Sep 21

15 min read

California's annual fire incident report is the Fire Incident Data Collection Plan approved at Appendix C of CPUC Decision 14-02-015, filed with the Safety and Enforcement Division by April 1 for the prior calendar year. It asks twenty-three fields. One of them can name the tree, and its approved drop-down holds six words.

Row 1058 of the spreadsheet PG&E filed with the CPUC for calendar year 2021 records an ignition on July 13, 2021, at latitude 39.874739 and longitude -121.378188. Material at Origin: Vegetation. Land Use at Origin: Hardwood Forest. Size: greater than 5,000 acres. Suppressed by Cal Fire. Facility Identification 100403909, 12,000 volts, overhead, Conductor - Primary. Suspected Initiating Event: Under Investigation. Contact From Object: N/A.

That is the Dixie Fire, and that row is the whole of what the state's annual fire incident report says about it. Its cells hold the word Vegetation exactly once, in the column that records what burned.

Two years later the Safety and Enforcement Division's own investigation report on the same event quoted CAL FIRE's causation finding: "a 65' tall, damaged and decayed Douglas fir tree when it fell and contacted conductors at approximately 6:48 AM." Both documents are accurate. They are two different kinds of document, and a program built on the first will be built on a file that holds nothing of the second.

The report, and the three-line test that puts a fire in it

The annual fire incident report is the Fire Incident Data Collection Plan approved at Appendix C of Decision 14-02-015, issued February 10, 2014 in Rulemaking 08-11-005. Ordering Paragraph 7 approves the plan. Ordering Paragraph 8 required collection to begin within 120 days. Ordering Paragraph 9 sets the filing:

Pacific Gas and Electric Company, San Diego Gas & Electric Company, and Southern California Edison Company shall submit annual reports in accordance with the Fire Incident Data Collection Plan that is approved by this decision by April 1st of each year beginning in 2015.

Three companies, one date, one recipient: the Safety and Enforcement Division. Principle 6 of the plan fixes the coverage period as the previous calendar year, January through December.

What goes in it is decided by Principle 4:

For the purposes of the Data Collection Proposal, a reportable event is any event where utility facilities are associated with the following conditions: (a) A self-propagating fire of material other than electrical and/or communication facilities, and (b) The resulting fire traveled greater than one linear meter from the ignition point, and (c) The utility has knowledge that the fire occurred.

All three conditions have to hold together. The test turns on travel distance rather than acreage, which is the point of it: a fire that burns three feet of grass under a service drop is a row in the same file as a fire that burns 963,309 acres. Principle 3 says the same about geography, declining to limit reporting to designated fire-threat zones or districts, so the adopted form treats a suburban tap and a Tier 3 ridge line identically.

One exclusion sits in a footnote and is easy to miss. Fires that damaged utility facilities, where the ignition itself is associated with something else, fall outside the requirement. A wildfire that runs through a right of way and burns forty poles stays out of the file.

Twenty-three fields, and the one that asks about the tree

Section B of the plan lists twenty-three field definitions. The first is Utility Name, and the filed spreadsheets group the other twenty-two under six banners:

Banner	Fields
Fire Start	Date, Time
Location	Latitude and longitude of the point of ignition
Fire	Material at Origin, Land Use at Origin, Size, Suppressed by, Suppressing Agency
Utility Facility	Facility Identification, Other Companies, Voltage, Equipment Involved With Ignition, Type
Outage	Was There an Outage, Outage Date, Outage Time
Field Observations	Suspected Initiating Event, Equipment/Facility Failure, Contact From Object, Facility Contacted, Contributing Factor, Notes

Exactly one of those can name the thing that touched the wire:

Contact From Object: The first object that contacted the Communication or Electric Facilities (Only to be used if "Contact from Object" is selected as Suspected Initiating Event)

The template printed at the back of Appendix C shows the choices behind that column. There are six: Animal, Balloons, Other, Vegetation, Vehicle and Unknown.

So the complete vegetation record of a vegetation-caused ignition, as filed with the Commission, is the word Vegetation. Everything below sits outside the twenty-three fields, optional column included:

species, or any botanical identification at all
height, diameter, or condition of the stem
distance from the conductor, or which phase it reached
whether the stem stood inside or outside the right of way
the failure mode: grow-in, fall-in, branch failure, or whole-tree failure
the date of the last inspection or the last trim on that span
the clearance achieved at that trim

The adjacent field is broader still. Facility Contacted, which records what the object hit, offers three values in the approved template: Communication Facility, Electric Facility and Pole. A tree that reaches the primary and a tree that reaches a guy wire are the same row.

In calendar year 2024 the three utilities named in Ordering Paragraph 9 filed 741 ignitions between them: 532 by PG&E, 178 by SCE and 31 by SDG&E. Of those, 123 carry Vegetation in the Contact From Object column. That is 123 separate pieces of vegetation described to the state regulator by one word each.

Two fields say vegetation and they answer different questions

Material at Origin is defined as "Material involved in the initial fueling of the fire." Contact From Object is the object that touched the facility. Both can hold the value Vegetation, and they measure different things.

What happened	Material at Origin	Contact From Object
Limb contacts primary, grass beneath ignites	Vegetation	Vegetation
Limb contacts primary, a shed beneath ignites	Building	Vegetation
Connector fails, sparks drop into annual grass	Vegetation	N/A
Vehicle strikes pole, brush at the base ignites	Vegetation	Vehicle

Row three is the common case and the one that most often gets miscounted. In SDG&E's calendar year 2024 file every one of the 31 ignitions carries Material at Origin: Vegetation, because in San Diego County almost everything that burns is brush. Three of those 31 carry Contact From Object: Vegetation. Reading the first column as a vegetation-cause count would overstate SDG&E's vegetation ignitions by a factor of ten.

A program that reports its vegetation ignition rate should state which column it counted, every time.

The size column stops at 5,000 acres

The Size field takes one of nine bands. From the template at Appendix C, the smallest is "Less than three (3) meters of linear travel" and the largest is "Greater than 5000 Acres."

That band is the ceiling. The Dixie Fire at 963,309 acres and a 5,001-acre fire on the same circuit produce the identical cell. PG&E's calendar year 2021 file contains 479 rows, and exactly one of them is in that top band.

This matters for anything built on the file. Acreage resists summing, consequence resists weighting, and the most destructive ignition in the set sorts alongside a 5,001-acre grass fire. The acreage number exists, in CAL FIRE's incident record and in the Safety and Enforcement Division's own investigation report. It lives everywhere except the annual report the Commission collects for the purpose of trend analysis.

The plan said drop-downs, and the filed columns are free text

Principle 2 of the plan is explicit about consistency:

Data should be consistent. Most fields will have either default formats or will be limited to drop down choices so that errors in data entry will be minimized.

Its footnote names the four fields excluded from a standard format: Notes, Facility Identification, Other Companies and Suppressing Entity. Land Use at Origin and Facility Contacted sit inside the rule, and footnote 9 ties Land Use at Origin tighter still, saying that Rural and Urban "shall be the same definitions as those contained in General Order 165."

Filings since 2015 have gone in a different direction. In the calendar year 2024 reports:

Column	Appendix C template	PG&E	SCE	SDG&E
Land Use at Origin	Rural, Urban	12 values, including Herbaceous, Conifer Forest, Desert Shrub, Wetland	Urban, Rural, Highly Rural, Unknown	Urban, Rural
Facility Contacted	Communication Facility, Electric Facility, Pole	24 values, including Conductor - Primary, Conductor - Transmission, Jumper, Riser	Electric Facility, Pole, and three stray entries	Electric Facility
HFTD tier	no such column	not reported	reported as Tier 2, Tier 3 or non-HFTD	not reported

PG&E's land-use column has become a fuel-type column. SCE volunteered the tier that Principle 3 deliberately left out, and its Contributing Factor column holds External Force, External force and Uknown as separate strings. SDG&E stayed on the template exactly, which is why its file, alone of the three, can be read against the 2014 vocabulary without a translation table.

All of it is on the public record. The three spreadsheets are posted on the Commission's own wildfire page, and the body that would decide whether the drift is acceptable is the Safety and Enforcement Division, which receives the files. What it means practically is that a multi-utility query against the published set has to be written per utility and per year, and a benchmark that treats the three files as one schema will be wrong in the columns that matter most.

Under Investigation is a tenth value, and Principle 5 is why

Return to row 1058. Its Suspected Initiating Event reads Under Investigation, which is a tenth value. The approved list runs to nine:

Contact Between Third Party Facility on Pole and Supply Lines
Contact From Object
Contamination
Equipment/Facility Failure
Normal Operation
Other
Unknown
Vandalism/Theft
Wire-Wire Contact

PG&E added the tenth, and its Notes cell explains the reasoning: the ignition was included because it met the separate electric incident report criteria, and "PG&E has not formed a conclusion about the origin or cause of this particular ignition."

Principle 5 of the plan is the reason that is a defensible entry rather than an evasion:

The information reported shall be objective and factual to the best of the utility's knowledge and shall not include speculation or attribution of fault or blame.

A reporter still waiting on a cause is barred from guessing at one. The form offers Unknown, which reads as a closed finding, and PG&E chose a word that reads as an open one.

Two dates sit either side of the entry, and they are worth holding together. CAL FIRE announced its causation determination on January 4, 2022. Ordering Paragraph 9 put the calendar year 2021 report in the Commission's hands by April 1, 2022. The file the Commission publishes still reads Under Investigation. The plan treats a filed row as final and keeps no version history, so the annual report is a snapshot of what was known on the filing date and stays that way.

The timing gap in the row itself shows the same thing from the other side. The row records the fire start as 09:36. CAL FIRE's summary puts the tree's contact with the conductors at approximately 6:48 AM, with the high-impedance fault heating a receptive fuel bed "over the course of 10 hours." Those are two different instants, and only one of them has a field.

The report that does describe the tree is a different report

The narrative account of the Dixie Fire tree exists, and it is in the electric incident report, not the fire incident report. Those are two filings on two triggers, and a program that conflates them will miss one of the two deadlines.

Electric incident reporting now runs on Resolution ESRB-12, adopted December 19, 2024, which rewrote Appendix B of Resolution E-4184. An incident is reportable if it meets any one of four criteria:

fatality or personal injury requiring medical attention at a hospital or other medical facility, attributable or allegedly attributable to utility-owned facilities
significant public attention or media coverage, at outlets with a minimum daily circulation or following of 25,000
damage to property, utility-owned or not, estimated to equal or exceed $200,000, up from $50,000 before ESRB-12
an incident that "prompted a government entity to investigate whether the infrastructure owned or operated by the utility caused a wildfire"

That fourth criterion is new in ESRB-12 and it is the fire one. It applies at any acreage, from the moment the agency opens the question; PG&E, SCE and SDG&E all argued against it, and SCE proposed that a report be required only after an agency concluded that utility facilities caused the fire. The Commission declined. Notice is due within two hours during working hours or four outside them, and a written report within twenty business days.

The nine categories that written report must contain cover the incident, the injuries, the damage, the agencies notified, the evidence, the witnesses and the response. The tree gets described under category (a), "a detailed description of the nature of the incident, and its cause," which is a free-text field. That is where this sentence lived in July 2021:

There he observed two of three fuses blown and what appeared to him to be a healthy green tree leaning into the Bucks Creek 1101 12 kV conductor, which was still intact and suspended on the poles.

A healthy green tree. The same stem that CAL FIRE's investigation would later describe as damaged and decayed, and that an arborist report prepared for that investigation addressed. The difference is not a contradiction. It is a troubleman's observation from the ground on the day, written into the one field that accepts prose, and it is the most specific vegetation description the regulatory record contained for six months.

PG&E filed it under the media criterion. Under ESRB-12 the same facts would now trigger criterion four as well, on the day CAL FIRE began collecting equipment.

Energy Safety gets the same word on a different clock

A third notification runs to the Office of Energy Infrastructure Safety, and its deadlines are the tightest in the stack. 14 CCR 29300 sets two of them:

(a) A regulated entity must notify the Office within one business day of observing, with respect to a fire requiring a response from a fire suppression agency, that: (1) a fault, outage, or other anomaly has occurred on infrastructure that it owns or operates within six hours of the start of the fire; and (2) the infrastructure with the fault, outage, or anomaly is within one mile of either the origin of the fire or perimeter of the fire at the time of the notification, whichever is known and closest.

Subdivision (b) adds a four-hour clock once the entity receives notice that its infrastructure might have caused such a fire, or that a government entity is investigating whether it did. That trigger is a near-twin of ESRB-12 criterion four, on a different deadline, to a different agency.

The companion section is gone. 14 CCR 29301, titled Incident Report, was the 30-day investigation report. It was filed as an emergency regulation in September 2021, refiled twice in 2022, and then "Repealed by operation of Government Code section 11346.1(g) (Register 2023, No.

1)." Section 29300 became permanent effective January 3, 2023, and 29301 lapsed. Anyone working from a 2022 compliance matrix is carrying a 30-day state deliverable whose regulation has lapsed, and Energy Safety's live enforcement hook is the approved wildfire mitigation plan rather than this article of the code.

Ignition data still reaches Energy Safety quarterly, through the GIS Data Reporting Standard. PG&E's own procedure reproduces that schema and gives its submission dates: May 1, August 1, November 1, and the fourth quarter with the wildfire mitigation plan.

The schema is richer than the CPUC's in weather and geography, carrying red flag warning status, fire weather watch status, high wind warning status, nearest weather station and HFTD tier. On vegetation it is the same single word. ObjectContact offers Vegetation as one of nine values, and the one extra vegetation question it asks, FuelBedDescription, is about what burned rather than what touched the wire: fire-resistive, grass, brush or timber fuel model.

Where the ignition report stops and the clearance record starts

The fire incident report points at a coordinate pair and a piece of equipment, and stops there. Facility Identification is a free-text field, defined as "Utility's description of the pole and/or equipment involved," and in the published files it holds pole numbers, meter numbers, street addresses and phrases like "2 POLES SS 0F 5877." Row 1058 carries 100403909. The Safety and Enforcement Division's investigation establishes that the tree stood between Pole 100403908 and Pole 100403909, which is the span, and that second number comes from the investigation.

So the join a vegetation program most wants has to be built by hand. To ask whether the spans that produced ignitions last year were inspected on cycle, somebody has to match a latitude and longitude against a circuit map, then against the inspection and trim records the utility keeps for its own program. No regulator requires that join, and every field that would carry it lives in the utility's own systems.

What the Dixie investigation found on the vegetation side came out of that second file. The Safety and Enforcement Division reviewed five inspection cycles on the Bucks Creek 1101 circuit, and its vegetation findings were about records:

an index map signed November 11, 2020, for a patrol performed December 3, 2020
the 2019 index map labeled AT112-C, missing from the inspection file
an internal procedure appendix still carrying superseded Rule 35 clearances

It found PG&E in violation of GO 95 Rule 31.1 for failing to identify the tree as a hazard tree, and in violation of Rule 18.B on the records.

All of that came out of the inspection file. The ignition report is a count, and it was designed as one. The Commission adopted it because, as the Safety and Enforcement Division argued in the proceeding, no data set then existed that collected data for all fires started by overhead power-line facilities. It closed that gap and left the tree to its own file.

What the record has to name

A vegetation ignition is the one moment when a span gets examined by somebody with a reason to look closely, and almost everything that person can see falls outside the form. These are the facts worth capturing on the day, in the utility's own record, keyed so they can be joined later.

Which of the three filings this event triggered, and on what date each was sent. Annual fire incident report, electric incident report under ESRB-12, Energy Safety notification under 29300. One event can trigger all three on three different clocks, and the only place that list exists is wherever somebody writes it down.

The span, as an ordered pair of structures. The Facility Identification cell takes one string, and the investigation two years later will want two.

The stem, as an arborist would describe it. Species, height, diameter at the point of failure, condition, lean, and where it stood relative to the documented edge of the corridor. On the Dixie Fire the difference between "healthy green tree" and "damaged and decayed Douglas fir" was six months and an outside arborist's report.

The failure mode. Grow-in, branch failure, whole-tree failure from inside the corridor, or failure from outside it. The Contact From Object cell cannot express the difference and the four outcomes carry different obligations.

Which column you counted. Material at Origin and Contact From Object both take the value Vegetation and they are different facts. Any internal metric built on either should name it.

The last inspection and the last trim on that span, with dates and the clearance achieved. This is the only material that turns an ignition into evidence about the program rather than a row in a count.

What the cause determination was on the filing date, and what it became afterward. The annual report freezes on April 1 and is never amended. If the utility's own record does not carry the later determination and the date it arrived, the published file becomes the only surviving answer, and on the largest fire in the set it reads Under Investigation.

Assembled in the utility's own file rather than on any of the three forms, the same ignition reads as something a second person can test two years later:

July 13, 2021, approximately 06:48. Bucks Creek 1101 12 kV, span 100403908 to 100403909, 39.8746 / -121.3789. Douglas fir, approximately 65 feet, damaged and decayed; whole-tree failure; fell and contacted the conductors. Filed as Material at Origin: Vegetation, Contact From Object: pending. Last routine vegetation patrol of record: index map signed November 11, 2020, work performed December 3, 2020

Electric incident report July 18, 2021 under the media criterion; 20-day report August 13, 2021; annual fire incident report row filed for CY 2021 with Suspected Initiating Event as Under Investigation. Cause determination by CAL FIRE January 4, 2022, received after the row was written and never carried back into it.*

Every fact in that line was recoverable on the day, and most of them stop being recoverable within a season. The three reports require none of them.

Frequently asked questions

What makes a fire reportable to the CPUC?

Three conditions, all of them, under Principle 4 of the Fire Incident Data Collection Plan at Appendix C of D.14-02-015. The fire has to be a self-propagating fire of material other than electrical or communication facilities. It has to have traveled greater than one linear meter from the ignition point. The utility has to have knowledge that the fire occurred. There is no acreage floor and no location test, so a fire that burns four feet of grass under a 12 kV tap in a non-HFTD suburb is in the same file as a fire that burns 900,000 acres.

When is the annual fire incident report due?

April 1 for the prior calendar year. Ordering Paragraph 9 of D.14-02-015 requires PG&E, SDG&E and SCE to submit annual reports under the plan by April 1st of each year beginning in 2015, and Principle 6 of the plan itself says the report covers the previous calendar year, January through December.

Does the fire incident report ask what species the tree was?

One field can name vegetation at all, Contact From Object, and the approved template behind it offers six choices: Animal, Balloons, Other, Vegetation, Vehicle and Unknown. There is no field for species, height, diameter, distance from the conductor, whether the stem stood inside or outside the right of way, when the span was last inspected, or what clearance was achieved.

Is an ignition report the same as an electric incident report?

They are two filings on two triggers with two deadlines. The fire incident report under D.14-02-015 is annual, covers every ignition over one linear meter, and is a data row. The electric incident report under Resolution ESRB-12 is triggered within two hours by injury, media coverage, $200,000 in property damage or a government agency investigating whether the utility's infrastructure caused a wildfire, and produces a written account within twenty business days. A single fire routinely generates both.

Does a publicly owned utility file a fire incident report with the CPUC?

The ordering paragraphs of D.14-02-015 name three companies: Pacific Gas and Electric Company, San Diego Gas & Electric Company and Southern California Edison Company. The Commission's public fire incident data page currently posts files for those three from 2014 onward and for PacifiCorp beginning with calendar year 2025. No publicly owned utility appears in the set.

Utility Line Clearance

Pre-Inspection

Emergency Services

QA/QC

LiDAR

Planning

Field Apps

Mobile Mapping

Careers

Blog