Purpose and scope
This publication provides information on how responsible businesses need to meet their obligations to operate and maintain their electricity networks to minimise bushfire risk. This publication also outlines Energy Safe Victoria’s oversight and regulatory activities specific to identified controls using bow-tie methodology. It supports responsible parties to better understand bushfire risk, and may also be of interest to members of the public.
This document provides an overview of obligations under the energy safety legislation, however it is not a complete statement of the legislative requirements or what is required to meet those requirements. This document does not affect the operation of the Electricity Safety Act or the Regulations made under that Act. Persons with obligations under the legislation should consider their own specific circumstances.
Background
Victoria has a history of electricity assets causing bushfires and is identified as one of the world’s areas most prone to bushfire. In 1969 and 1977 the failure of electricity assets—including the clashing of conductors, conductors contacting trees, and inefficient fuses—caused major bushfires. This history was repeated on 7 February 2009, when five of the 11 major fires that began that day were caused by failed electricity assets; among the fires was that at Kilmore East, which resulted in the death of 119 people. Part of our purpose is to promote the prevention and mitigation of powerline bushfire danger to ensure the likelihood and consequences of such events are minimised.
It is appropriate that our discussion of harms begins with bushfires, given that among all the areas that we regulate, bushfires pose grave risk to the public — multiple fatalities and injuries, loss of property and livestock, economic impacts and costs of recovery.
It is important we are transparent with our stakeholders and the community about how we ensure the responsible businesses meet their obligations to operate and maintain their electricity networks to minimise as far as practicable the bushfire risk. We have developed a bowtie diagram (see below) to help communicate the threats from electricity networks that could result in a bushfire, and the controls to manage these.
As the safety regulator, our role is not to manage the risks that may occur when operating electricity networks. Energy Safe Victoria’s objectives and functions with respect to electricity networks is outlined in sections 6 and 7 of the ESA. The functions of Energy Safe include encouraging and monitoring the use of ESMSs and regulating, monitoring and enforcing the prevention and mitigation of bushfires.
It is therefore important to note that our bow-ties show industry risk controls; the corresponding Energy Safe regulatory assurance activities are listed separately (table 1).
Energy Safe applies a safety assurance focus and regulates, monitors and enforces industry safety and compliance with regard to risks that arise from industry activities. We accept /approve ESMSs, BMPs and ELCMPs (plans) which describe how the responsible party will manage bushfire risk. Energy Safe monitors compliance against submitted plans through audit and inspection activities. Bow-ties help Energy Safe understand the controls industry has in place in managing bushfire risk, in order to target audit and inspection activities. In the case of an ESMS, Energy Safe may require that a bow-tie developed by the responsible party be provided as part of its formal safety assessment prepared for the ESMS.
Using a bow-tie diagram
Bow-ties are a valuable risk analysis tool and visual representation of key risk information, such as critical controls. The reasons we use bowtie diagrams are that:
- They provide a consistent and structured way to assess the risks being managed by industry.
- They provide a summary of risks associated with the hazard (electricity network) that is easy to understand.
- Their branching structure allows us to quickly see the different threats (causes) and consequences and whether the set of controls is acceptable.
- They allow us to monitor the health of controls and target areas where controls are starting to fail.
When we work with bow-ties, we consider the following (see diagram 1):
- The hazard (i.e. electrical distribution lines)
- loss of control event (i.e. ground-fire).
- the threats that cause loss of control of the hazard (i.e. tree branch falling onto powerline),
- consequences of losing control.
- controls for each threat that would prevent the threat from happening (i.e. cutting back vegetation),
- mitigating actions that will prevent or reduce the consequences from occurring if the loss of control event occurs.
Diagram 1:
Understanding bushfire risk
In understanding bushfire risk, we consider a high level view of the range of environmental, human, design and operational threats that could start a ground-fire (leading to bushfire) and identify the main threats that are most likely to cause a bushfire if not managed by the responsible businesses.
Click here to see our ground-fire risk bowtie:
Energy Safe regulatory action
The Electricity Safety Act 1998 and its subordinate regulations establish the duties and obligations on responsible parties to minimise hazards and risks arising from network assets
We audit and inspect to ensure that the risk controls are being implemented effectively and that the responsible businesses comply with their documented systems and plans. When they do not meet their obligations, we will investigate further to ascertain the cause of any non-compliances. We will then consider taking proportionate enforcement action, consistent with our compliance and enforcement policy:
Please see below table 1 for a summary of Energy Safe’s regulatory assurance activities associated with ground-fire risk.
Table 1: Energy Safe regulatory & assurance activities
| Energy Safe regulatory & assurance activities |
|---|
Vegetation Clearance (see ground-fire bow-tie threat “vegetation grow-in” and “vegetation falling/blowing onto live electrical asset”) Vegetation clearance around powerlines is one of our compliance and enforcement priorities. Relevant legislation Electricity Safety Act 1998 Division 2 Subdivision 1 Section 84 (distribution companies), 84A and 84B (occupiers of land), 84C (councils) and 84D (other persons) Electricity Safety (Electric Line Clearance) Regulations 2020 that include the Code of Practice for Electric Line Clearance Energy Safe oversight activities
|
REFCL (see ground-fire bow-tie, all threats) Rapid Earth Fault Current Limiters (REFCL) are being deployed at substations servicing high-risk areas within Victoria’s electricity network. REFCLs are a new type of protection system that prevents fire ignition arising from phase-to-ground faults. Energy Safe is overseeing the deployment and testing of REFCL systems. Further details on the REFCL program can be found on the DEECA website (overview) and on the Energy Safe website (details and status). Energy Safe is monitoring the Rapid Earth Fault Current Limiter (REFCL) roll-out that is due for completion by 1 May 2023. Relevant regulation Electricity Safety Act 1998 Sections 120K, 120L and 120M Electricity Safety (Bushfire Mitigation Duties) Regulations 2017 Electricity Safety (Bushfire Mitigation) Regulations 2013 Energy Safe oversight activities
|
Hazard tree management (see ground-fire bow-tie, vegetation falling/blowing onto live electrical asset threat) It is a requirement of:
Relevant legislation (MEC) Electricity Safety (Electric Line Clearance) Regulations 2020, Schedule 1 Section 9 Energy Safe oversight activities
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Powerline / Electrical Assets (see ground-fire bow-tie, “electrical asset failure or operation” and “animal and bird contact with live electrical asset”) Improving powerline maintenance of major electricity companies is one of our compliance and enforcement priorities for 2022-2023, which builds upon earlier work on wood pole management that was a priority in 2021-2022. A list of reports on the incidents leading to and the activities of this program of works can be found here. This also extends to the selection and application of asset types that are appropriate for the risks and environmental conditions of the local area, e.g. low fire risk products installed in hazardous bushfire risk areas. Electrical assets must be selected, designed and constructed in accordance with the ESMS or standards. The inspection, maintenance and replacement of electrical assets must be conducted as per the accepted BMP. Relevant regulation Electricity Safety Act 1998 Electricity Safety (Bushfire Mitigation) Regulations 2013 Electricity Safety (Management) Regulations 2019 Energy Safe oversight activities
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Third party contact (vehicles, equipment, etc.) (see ground-fire bow-tie, “third party contact”) Minimising energy network strikes and encroachments is one of our compliance and enforcement priorities for 2022-2023. Energy Safe is working with WorkSafe and industry participants to raise awareness of the dangers of working in close proximity to powerlines, to promote the No Go Zone rules, encourage the adoption of safe systems of work, and to promote the use of proximity devices and early warning systems when working near powerlines. In addition, MECs are required to implement controls in accordance with their accepted ESMS or BMP, such as installing markers and signage to show location and provide warning, controlling work activities around powerlines through permit to work systems, implementing REFCL protection, de-energising powerlines on high risk days, running Public Awareness Campaigns (promotion of No Go Zones) and providing Network Location Resources (Before You Dig Australia and the Look Up and Live App). Relevant regulation Electricity Safety (General) Regulations 2019 Electricity Safety Act 1998 Electricity Safety (Management) Regulations 2019 Electricity Safety (Bushfire Mitigation) Regulations 2013 Electricity Safety (General) Regulations 2019 Energy Safe oversight activities
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Date: 21/11/2024 5:14
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Reviewed