Wildfire Risk & Defensibility: When Risk Becomes Liability

By Bob Urban, Senior Account Manager, ACRT Services

Every wildfire season raises the same question for utilities: Are we prepared?

As wildfire frequency, intensity, and public, investor, and insurer scrutiny continue to increase, utilities face growing pressure to demonstrate not only that they managed vegetation risks, but that they made informed, defensible decisions before an ignition ever occurred.

Preparation is no longer measured solely by miles trimmed or inspections completed. Increasingly, it is measured by documentation, consistency, risk prioritization, and the ability to show regulators, customers, stakeholders, and ensure that the right work was performed in the right places at the right time.

Wildfire resilience starts long before fire season begins. It starts with a defensible program.

Why Utility Wildfire Risk Management Goes Beyond Compliance

Regulatory compliance establishes a reliability baseline. Defensibility goes further.

A defensible wildfire mitigation program (WMP) demonstrates that a utility has identified risk, applied sound decision-making, prioritized and documented its actions, and continuously improved its approach based on changing conditions.

When incidents occur, utilities may be asked to explain:

• How circuits were prioritized
• Why certain vegetation work was performed
• Why other work was deferred
• What inspection criteria were used
• How risks were documented and tracked
• Whether work was completed according to established standards

The ability to answer those questions with confidence often depends on the quality of the program long before an event takes place.

Wildfire Risk Is Constantly Changing

Wildfire risk is constantly changing.

Vegetation growth, drought conditions, severe weather, insect damage, disease, evolving fuel loads, and expanding development into natural wildfire landscapes all influence the level of risk across a service territory.

Programs that rely solely on cyclical maintenance can struggle to keep pace with these changing conditions.

Instead, many utilities are strengthening their programs by incorporating:

• Risk-based inspection strategies
• Hazard tree assessments and mitigation
• Geographic information systems (GIS)
• Remote sensing and field verification
• Asset condition assessments
• Data-driven work prioritization
• Contingencies for changing conditions

These tools help utilities focus resources where they can have the greatest impact while providing documentation that supports operational decisions.

Building Consistency Across Utility Vegetation Programs

A wildfire mitigation program is only as strong as its execution and funding.

Consistent inspection methods, standardized documentation, qualified field personnel, and independent quality assurance help ensure that work is performed uniformly across large service territories.

Independent audits and work verification provide another layer of accountability by confirming that completed work aligns with utility standards and regulatory expectations.

This consistency not only improves program performance but also strengthens confidence among regulators, customers, and utility leadership.

Documentation Creates Defensible Decisions

If a wildfire investigation occurs months or even years after vegetation work was completed, records become just as important as the work itself.

Utilities increasingly rely on comprehensive documentation that captures:

• Inspection findings
• Risk classifications
• Completed work
• Photographs and field observations
• Geographic locations
• Dates and timelines
• Quality assurance reviews

Strong documentation supports operational decision-making, simplifies reporting, and provides valuable evidence that reasonable actions were taken to reduce risk. Documentation will also be used when making the case for funding support either through rate cases or board proposals.

Strengthening Utility Wildfire Resilience

No utility can eliminate wildfire risk entirely.

However, utilities can significantly improve their ability to manage that risk through proactive planning, consistent execution, and continuous program evaluation.

An effective wildfire strategy combines experienced field personnel with objective assessments, actionable data, and disciplined program management. Together, these elements create a stronger foundation for operational resilience while helping utilities demonstrate that they are making informed decisions to protect their infrastructure, customers, and the communities they serve.

As wildfire seasons continue to evolve, the question is no longer whether utilities are managing vegetation. It is whether they can clearly demonstrate how those decisions were made, how risks were prioritized, and how their programs continue to adapt to an increasingly complex operating environment.

That is what makes a program truly defensible.

Partnering for Long-Term Wildfire Preparedness

Utilities need more than field resources during wildfire season. They need trusted, flexible partners who can help evaluate risk, strengthen program consistency, verify work quality, and provide the independent expertise needed to support long-term resilience.

For more than 40 years, ACRT has partnered with utilities to improve vegetation management programs through independent consulting, utility forestry expertise, inspections, quality assurance, risk assessments, and data-driven program support. Whether helping utilities prepare for wildfire season, implementing their WMP’s or strengthening year-round operations, our employee-owners are committed to helping customers build safer, more resilient electric systems.