FAC-003-2: A “Zero Tolerance” ApproachArticle
By William Porter, Director of Consulting, CN Utility Consulting
This article was published in the September/October 2013 issue of Utility Arborist Newsline.
On March 21, 2013 the process of crafting and adopting a new transmission vegetation standard culminated with FERC Order 777. By the time FAC-003-2 is officially implemented on July 1, 2014, it will have been seven years since FERC Order 693 initiated the process to revise FAC-003-1. The new version is a “zero tolerance” approach to UVM on transmission corridors in North America .
Direction from FERC
The revision of FAC-003-1 wasn’t motivated by current reliability, utility, industry, or societal need. In fact, it is a well-established fact that since FAC-003-1 was adopted in 2007, outages caused by trees growing into conductors have been nearly eliminated. FERC Order 693 adopted FAC-003-1 and concurrently mandated the standards development process begin for FAC-003-2. Even before the original standard was implemented, FERC determined that modifications would be necessary. FERC required NERC to modify the applicability of the standard to include more lines under 200kV and to identify appropriate inspection cycles . FERC also made the following statement in Order 693:
“Finally, the Commission directs the ERO [Electric Reliability Organization/ NERC] to develop a Reliability Standard through the Reliability Standard development process that defines the minimum clearance needed to avoid sustained vegetation-related outages that would apply to transmission lines crossing both federal land and non-federal land.”
NERC is confident FAC-003-2, as stated in their comments to FERC, will “prevent the risk of sustained outages.” The response in FAC-003-2 to Order 693’s inspection requirement is straightforward: all applicable transmission lines have to be inspected each year.
The response to applicability modifications is not a simple solution, but it is exactly what was proposed by FERC and by stakeholder comments in Order 693: “We support the suggestions by Progress Energy, SERC and MISO to limit applicability to lower voltage lines associated with IROL and these suggestions should be part of the input to the Reliability Standards development process.” In Order 777, FERC directed “NERC to develop a means to assure that IROLs are communicated to transmission owners [TO] .” Assuredly this will be developed by the time the standard becomes enforceable.
Changes in the Standard
FAC-003-2 not only satisfies the three requirements (applicability, inspections and clearance distances) specified in FERC Order 693 but also dives much further into the issues of compliance and enforcement of a “zero tolerance” approach standard. Many new ideas are introduced and infused in version 2, such as FERC approved definitions of Right-of-Way (ROW) Vegetation Inspection, and Minimum Vegetation Clearance Distances (MVCD). Other significant changes include:
• Violations to FAC-003-2 are more explicit and associated with more/different situations than the previous version.
— Encroachments into the MVCD are violations, whether an outage occurs or not, and include encroachments by fall-in trees.
— An annual inspection schedule must be completed on every applicable line.
— Imminent threat communication is more explicitly defined and now must occur without any time delay.
— Managed ROW widths must conform to ROW definition.
— Annual transmission vegetation management plans must be completed on time.
• Exemptions to violations of FAC-003-2 for circumstances beyond the control of the TO are also more explicit:
— Off- and on-ROW sustained outages are exempt from reporting if they meet a general criteria of circumstances beyond the TO’s control, including natural disasters, human or animal actions, and the TO’s or applicable regulator’s definition of major storms.
— Exemptions apply to more requirements, such as MVCD violations, completing inspection schedules, and completing planned vegetation management work.
— The utility is not exempt and is responsible for employees and contractors whose actions cause sustained outages .
• The MVCD tables are based on new engineering calculations of flashover distances for applicable voltages at various altitudes. Version 2 utilizes the Gallet Equation versus the IEEE clearance distances found in version 1.
• Corrective action is required for constraints on planned UVM, but only if the MVCD will be encroached before the next annual plan.
• Vegetation related outage reporting is not required by the standard but must be filed according to NERC Rules of Procedure, Sections 401.3 and 100.
• The MVCD is enforceable for only real-time observed encroachments. In the guidelines and the footnotes of the standard, it is stated that hard evidence of a MVCD violation is also considered. Examples of hard evidence include an observation, a momentary fault caused by vegetation, and any sustained outage caused by vegetation within the utility’s control.
Although not mentioned in the standard or guidelines, a real-time LIDAR survey of a MVCD encroachment could possibly be considered hard evidence, as it has been for Page 26 Utility Arborist Newsline W O R K I N G W I T H G O V E R N M E N T A G E N C I E S FAC-003-2: A “Zero Tolerance” Approach to Transmission vegetation management Clearance 2 violations under FAC-003-1. Modeled LIDAR data for determining maximum sag and sway has not been used as evidence for enforcement under the current standard and it isn’t mentioned in the new standards guidelines. However, the CEO of NERC has endorsed the use of LIDAR to measure vegetation clearances and to model conductor positions at maximum sag and sway.
FAC-003-1 served the purpose of eliminating outages caused by vegetation on the bulk electric system. In the past seven years, clearance violations resulted in fines when an outage occurred. As a result, in the last three or four years, outages caused by vegetation in the ROW have become nearly non-existent. The next step in managing risk is to ensure processes are in place to maintain this record without relying as heavily on punitive actions.
FAC-003-2 is a fresh new risk-based standard with many details that were not in the first version. The requirements in FAC-003-2 are more explicit than FAC-003-1, and the most notable is preventing encroachments into the MVCD. NERC will pay closer attention to violations of the MVCD than past violations to Clearance 2, because:
• The MVCD allows vegetation to grow closer to the conductor than Clearance 2.
• There is no longer a Clearance 1 requirement to prevent vegetation from encroaching the mandatory clearance distance.
• It is explicitly stated in the new standard that real-time MVCD encroachments are a violation regardless of whether there is a sustained outage. Future Changes Despite the current final ruling, there are several areas of the standard that could be addressed in future reliability standards development. Some of these areas been identified by FERC and NERC. Areas that are still a potential concern are:
• Substantiating the assumptions behind the method for determining the MVCD (The Gallet Equation and its applicability to tree and power line clearances).
• The definition of ROW and determination of ROW widths.
• How IROLs are communicated to transmission owners.
• Whether the MVCD will send the wrong message to property owners and federal land agencies seeking to restrict the vegetation management plans of the utility company (industry stakeholder concern).
Impact on the Industry
The transition to a new standard will require greater attention to how procedures and processes actually prevent outages. It could be argued that the new standard has less to do with vegetation management practices and more to do with proving a utility can comply with “zero tolerance” for vegetation caused outages, at least those caused by trees growing into the lines. At minimum it will require a review and update of existing Transmission Vegetation Management Programs (TVMPs) and procedures.
For the UVM industry, FAC-003-2 represents a challenge to create and/or maintain best practices for arboricultural, silvicultural, horticultural and societal understanding. For example, the ROW Steward Accreditation program has been initiated to promote best management practices on North American transmission ROWs. FERC (see sidebar) notes this in Order 777 when they state, “We believe that industry compliance with FAC-003-2, together with a continued focus by industry on best practices for vegetation management, will serve to enhance the reliability of the Bulk-Power System”.
Finally, one could say results-based FAC-003-2 is also part of a much wider change to our relationship to the natural environment. Other stakeholders, other causes and other mandates may be supporting this conclusion too: “Stephen J. Pyne, one of the nation’s leading fire historians and a professor at Arizona State University, said, ‘How we live on the land, what we decide we put on public and private lands, how we do things and don’t do things on the land, changes its combustibility’.” Other considerations, such as massively powerful storms, floods and climate change could be changing our relationship to trees and the environment, and the ways we manage vegetation.
Utility companies across North America will adjust to the new rule by revising their TVMPs to fit the new requirements of FAC-003-2. Version 2, similar to version 1, will undoubtedly have far reaching influence over utility vegetation management activities in North America.
Cieslewicz, S. R. (2011, July). Trees, Power Lines and NERC. From http://www.elp.com/articles/print/volume-89/ issue-4/features/trees-power-lines-and-nerc-aninterview-with-nerc-ceo-gerry-cauley.html.
FERC. (2007, March 16). FERC Order 693. From nerc.com: http://www.nerc.com/FilingsOrders/ us/FERCOrdersRules/ORDER%20693.pdf. FERC. (2013, March 21).
FERC Order 777. From NERC: http://www.nerc.com/FilingsOrders/us/FERCOrdersRules/E-5_Order_FAC-003-2_2013.3.21.pdf.
Foster, A. D. (2013, July 2). New York Times. Retrieved from nytimes.com: http://www.nytimes. com/2013/07/02/opinion/living-with-fire.html?_ r=0
NERC. (2012, December 1). RM12-4-000. From NERC: http://www.nerc.com/FilingsOrders/us/NERC%20 Filings%20to%20FERC%20DL/NERC_Commments_NO PR_FAC-003-2_2012.12.pdf.
NERC. (2013, May 9). 2014 Rules of Procedure. Retrieved from NERC: http://www.nerc.com/ FilingsOrders/us/RuleOfProcedureDL/NERC_ROP _Effective_20140701.pdf.