By Paul S. Hurysz, Jr.
In the vegetation management (VM) industry, the pendulum is beginning to swing toward more regulations and requirements.
Prior to recent times, from a statutory and regulatory standpoint, the National Electrical Safety Code (NESC) rule 218 was generally accepted as the most common rule providing general guidelines for VM programs. The NESC provides general instructions on how to prune and remove trees that “may” interfere with the electrical lines. With that being said, most utilities didn’t see this rule as restrictive.
Congress struggled for 10 years to enact energy reform legislation. However, it wasn’t until events such as the 2003 NE blackout, and the 2004 and 2005 hurricane seasons that caused the pendulum to swing the other way and Congress to act, toward more regulations and requirements. Today’s regulatory environment pretty much started with the Energy Policy Act of 2005 when it was signed into law.
Regulatory impacts come in many shapes and sizes. NERC FAC-003-1 is changing the way vegetation managers look at all transmission right of way (ROW) maintenance, regardless of voltage, but especially those voltages that fall within the standard.
It is generally understood that federal or regional agencies or organizations, such as NERC (North American Electric Reliability Corporation) and FERC (Federal Energy Regulatory Commission), have authority over lines with transmission voltages, and State public utility or service commissions have jurisdiction over lines with distribution voltages. New state and local mandates are not necessarily an everyday event, but seem to be coming more frequently, and they tend to revolve around constituent complaints about aggressive utility tree pruning or removal practices.
For example, the New York State Public Service Commission recently adopted eight recommendations to improve and clarify utility practices regarding high-voltage transmission right of way vegetation management practices. According to Gary Brown, the commission chair, the goal of these regulations is to ensure that, “Maintaining the highest degree of electric system reliability… is among the most important of our responsibilities. However, there is a real need to ensure that the public is kept fully informed regarding changes to be made to vegetation.”
At a local level, we are seeing these types of trends. Some other examples include, but are certainly not limited to, the following:
Utility vegetation management (UVM) reporting requirements: Connecticut requires an annual submission of UVM activities and progress.
Mandatory clearance requirements: California GO 95, Rule 35 requires utilities to achieve and maintain specific clearances between vegetation and any energized primary or transmission lines. Generally, the higher the voltage of the line, the larger the clearance requirements imposed by the rule.
Mandatory cycles: Oklahoma requires utilities to develop a comprehensive plan of UVM activities and comply with a four-year or less cycle for UVM activities.
Mandatory notification: Wisconsin and Virginia require specific UVM notifications and procedures, and reporting requirements for UVM activities.
Commission audits: The State of Wyoming performs these annually.
There are several major impacts to vegetation managers from these local regulations. Those impacts usually amount to additional time and effort to improve or harden system reliability, to improve public knowledge and safety around maintenance operations, and reduce the impacts that tree contacts with power lines have on wild fires.
At a national level, we have two major developments within the last year: the 2010 NERC Alert on consideration of actual field conditions, and progress on FAC-003-2.
The most recent formal development from NERC has been this 2010 NERC Alert regarding Consideration of Actual Field Conditions in determining facility ratings. Reason for alert: a transmission owner (TO) experienced a conductor-to-ground fault caused by a vegetation contact, resulting in a lockout of that transmission line. Although vegetation caused the fault, the subsequent evaluation indicated that the conductor-to-ground clearance was less than expected. As a direct result of the outage, the TO contracted with an organization to use LiDAR (Light Detection and Ranging) and PLS-CADD (Power Line Systems – Computer Aided Design and Drafting) technologies to survey its 230 kV and 345 kV systems. The data was used to determine conductor-to-vegetation and conductor-to-ground clearances. Using these advanced technologies, the TO identified more than 100 conductor-to-ground clearance issues that had gone previously undetected. NERC found this disclosure troubling, and issued their alert to all TOs.
As similar facility rating inspection programs are implemented as a result of this NERC recommendation, vegetation managers will have significant new information about ROW conditions to help them with their UVM plans. These types of inspections will produce maximum sag and sway analysis that most vegetation managers have probably never seen in their careers, as it relates to ROW clearances. This analysis will likely produce potential reliability observations that will have to be addressed if the utility wants to maintain compliance with their TVMP (Transmission Vegetation Management Program) and the NERC standard.
FAC-003-2 – This standard has been adopted by the industry and is awaiting approval from the regulators. So what are some of major the changes from FAC003-1?
It defines active transmission line right of way as a strip of land that is occupied by active transmission facilities. This corridor does not include the inactive right of way or unused part of the right of way intended for other facilities. So utilities won’t be penalized for having a larger ROW than is used.
It proposes to change the sustained outage categories from the simple (1, 2, 3) to the more well defined categories (1a, 1b, 2a, 2b, 3, 4a, 4b), reflecting the importance of the line. Most likely this change in convention was to help NERC with data comparison across this revision in the standard. For example, Category 1A grow-ins would be sustained outages caused by vegetation growing into applicable lines that are identified as an element of an IROL (Interconnection Reliability Operating Limit) or major WECC (Western Electricity Coordinating Council) transfer path; Category 1B grow-ins would be sustained outages caused by vegetation growing into applicable lines not identified as an element of an IROL or major WECC transfer path.
Combining Vegetation Inspection: The systematic examination of vegetation conditions on an active transmission line right of way. This inspection may be combined with a general line inspection.
Finally, the Minimum Vegetation Clearance Distances (MVCD) will be modified to more accurately reflect the risks of the voltage at its given altitude above sea level.
National regulations are appearing to have the following impacts on utility vegetation managers:
1. The ROW manager, because of these forces, must do a much better job of documenting every step in his VM management processes or risk unwanted or unneeded scrutiny by regulatory and/or internal sources.
2. Additionally, the ROW manager is most likely dealing with increasing pressure to communicate plans and maintenance intentions better that he/she has before. There is a significant trend out there to notify, publish and update plans as they are completed for those who, internally and externally, are interested in ROW maintenance practices.
3. And last, but certainly not least, more intrusive regulations require the ROW manager to be much more objective with his/her ROW scopes and specs for maintenance purposes. Those plans are likely to be scrutinized by external parties and used against you if your policies and practices are more subjective and vague, as opposed to being based on industry-tested knowledge.
Business and technology align
Here at Powel, we are not only focused on regulatory issues, but we are focused on maintenance, planning, and work analysis issues as well. The way we see it is that our technology initiatives produce business value.
This screen shot shows what a user would see out in the field in VegWorks. The system has synched out to the field all the relevant information, including poles and spans, maps, aerial photography, LiDAR observations, customer information, work history, etc. From here, an assessor would walk the line and recommend specific actions, such as trimming, removals, herbicide, TGR, etc. to maintain the right of way. This screen shot shows an area for which “Removal” is prescribed, as a well as several trees observed as threats by LiDAR, for which a DL, or Drop/Lop, treatment is prescribed.
This is the same content as the previous screen shot, but the aerial photography layer has been turned off to visually emphasize the other elements.
All images provided by Powel, Inc.
From a reliability perspective, most prioritizations used to be subjective. In other words, we relied solely on the forester or the arborist for a professional — but subjective — opinion to justify a plan or action. Today, combined with subjective analysis, we can use objective analysis through these technical tools, or databases, we now have to improve planning, levelize work load and work forces, and prevent outages or improve circuit reliability by doing a better job of documenting and tracking inspection observations through completion. With the technology we have access to today, we can justify and quantify decisions based on actual need.
From an efficiency perspective, we can work smarter by having access to more information in order to make better decisions. We can bundle work by location and type to improve crew efficiency. For projects that get bid out, it’s easier to generate bid packets. We can document and share access routes and hazards, so that others within our organizations don’t have to reinvent the wheel every time they go out into the field or run into the same hornets’ nest.
And from a project management perspective, you can better manage your plans through these types of applications to ensure that you are on schedule and see how contract workforces compare to each other. If that doesn’t interest you, you can just compare past performance to current crew performance. Those types of evaluations are invaluable whether you are evaluating a proposed bid project or just checking the efficiency of your current T&M crews against the past performance of others.
The possibilities with technology are only limited by time, money and ideas. As VM budgets become increasingly difficult to grow in our economy, technology will continue to find its way into our day-to-day operations to improve our decision making capabilities and efficiencies within our industry.
To maximize efficiency and productivity, treat your technology purchases like any other major purchase or change in your life or career. For example, let’s take a new equipment purchase or the acquisition of a new contractor to perform maintenance activities for you on your system into consideration. Within your inner circle of friends, family and peers, how many of you drive the same model and make of a car or truck? It’s not that you don’t trust your friends, family, and peers; you most likely have different preferences or needs. Sometimes they are the same, but most of the time, probably not. The same holds true in the contract acquisition world. It’s unlikely that you would make a wholesale change in your contract strategy or workforce without testing that strategy or trying that new contractor out on a smaller scale before you made a significant investment to that new line of thinking.
I certainly don’t want to discount recommendations of friends, family or peers; or even, for that matter, undermine a salesman’s testimonial or assurances. However, vegetation managers probably realize more than most in the industry that there are inherent regional, environmental, economical and even regulatory differences that make us all different in our industry. My point is, test drive that new technology first. Become familiar with what your preferences might be. Whether it’s a piece of hardware you’re choosing for your arborists to use in the field, or software that is intended to improve your business process flows or reporting capabilities. Try it out first. Let your manager and the field users try it too. Be sure that you don’t let the needs of the vegetation department get lost or undervalued. I’ve seen a lot of money wasted over the years, within a multitude of organizations, because someone made a purchase decision without testing it in their environment or with their people first.
Paul S. Hurysz, Jr. formerly a utility forester and arborist, is now the product manager, vegetation management system solutions, at Powel, Inc. For more information about the topics and technologies outlined here, visit www.powelinc.com