Chairman Jon Wellinghoff Statement
June 21, 2012
Docket No. IN12-16-000
Item No. A-3

"A recurring cause in this and many blackouts has been vegetation-related outages. Environmental issues, property rights and cost, among other things, play an important role in every company’s vegetation management program. In my view, the most successful vegetation management program have, as one of the core elements, a strategy to engage the property owners in an adequate, timely and forthright manner and to work cooperatively with those property owners.

For example, it is important to give the property owner sufficient notice about the impending activity including the type of vegetation management that is planned - for instance trimming or herbicide application. In some cases, a company may get the property owner to agree to the planned action by simply switching methodologies say from herbicide application to trimming.

Successful vegetation management programs also help property owners maintain and even enhance the environmental benefits and aesthetics of the right-of-way while ensuring sufficient clearance between the vegetation and energized conductors. For example, trees that are expected to grow into the transmission lines are removed and replaced with lower growing native species that provide a shelter for indigenous wildlife. Another practice that property owners appreciate is a small tree voucher program that allows them to select smaller trees from nurseries to replace the larger trees that are removed from the right-of-way. These efforts may even help persuade property owners to allow vegetation management outside of both jurisdictional facilities and the existing right-of-ways.

The current reliability standard FAC-003 requires both a formal transmission vegetation management plan and an annual plan for vegetation management work. I believe that companies should make these plans available to the public, including the affected landowners, by posting them on their website.

I urge all companies to include these components in their vegetation management programs.

As a final point, we continue to receive complaints that utilities are clear-cutting right-of-ways in order to comply with reliability standard FAC-003. In some cases, reliability standard FAC-003 has been cited as the reason for clear-cutting even when it does not apply, e.g. transmission lines below 200 kV and distribution lines. The standard only requires that a minimum clearance be maintained and does not prescribe the methodology that utilities are required to use. Companies should not misrepresent the reason for the vegetation action by overstating the requirements or applicability of the standard."

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