I received an interesting invitation and challenge from a regulatory staff member. Here is part of what he had to say.
“I just read your article titled, 'Vegetation Management Metrics' and I noticed a theme that I have seen in more than a few vegetation management articles. You seem to believe that no one understands vegetation management professionals – not senior utility managers, not the public, not local government officials, and not utility regulatory agencies. You seem to believe that we keep getting in your way and making your jobs harder or impossible to do. I have an idea that you might find interesting.
"Maybe you could write an article that explains exactly what utility vegetation management professionals need from utility regulators to help them do their jobs. I have never met a utility regulator with previous experience as a vegetation management professional so maybe we do not know what you need from us. Maybe we can listen, learn, and perhaps adopt some of your suggestions.”
Neither have I met a utility regulator with previous experience as a vegetation management professional. As Commissioners are either elected or appointed by the state governor, the lack of any VM experience is not surprising. However, as a key role of the regulatory staff is to inform the Commissioners’ decision making and trees being one of the primary causes of unplanned outages, it is somewhat surprising that, to my knowledge, only the NY PSC has a forester on its staff.
Let me begin by acknowledging your observation, “You seem to believe that no one understands vegetation management professionals – not senior utility managers, not the public, not local government officials, and not utility regulatory agencies.”
I confess that is true. Of those, there are two groups that should have a very good understanding, senior utility managers and utility regulatory agencies. In explaining what utility vegetation management professionals need from both groups but particularly, utility regulators, I will need to draw attention to what I perceive to be the current shortcomings.
I’ll open with an anecdote to convey the reality within electric utilities. For the readers from the regulatory side, not wishing to micro-manage, you may not have information regarding the support, or the lack thereof, that the VM group receives within the utility. Some years ago I was involved in a management performance audit at PECO. The manager of VM showed me their work tracking systems, their outage calendar, with the most detailed categorization of tree-related outages I had ever encountered.
When I asked her where these systems had come from, she informed that they had been built internally by the VM group working with their dedicated IT staff after a business case had been made to justify the development by their dedicated financial staff.
I asked “Do you have dedicated IT and financial staff?” and she said yes. Perhaps fearing that I had an issue with this she quickly added that some years earlier PECO senior management had concluded that VM being the largest O&M item and trees being the primary cause of unplanned outages, the VM group should have access to, and an assignment of, company resources in line with this profile. My stunned look and open mouth had her asking if everything was all right. I recovered enough to answer that while the decision her senior management had taken was absolutely logical, in over 30 years in the industry this was the first time I had encountered a utility acting from this recognition, even though it should be the obvious, rational course.
So, let me ask a few questions of the readers who would categorize themselves as either senior utility managers or utility regulators. When it comes to the distribution business, what is the largest O&M expense item? What is the top unplanned outage cause on the distribution system? In most cases, the answers will be VM and trees. Where they don’t top the list, they will nonetheless fall within the top three. As a senior utility manager, have you ensured that the dedication of resources is commensurate with the importance VM has in the reliability delivered and operating costs? As a regulator, have you ensured that VM is appropriately funded and supported? Further, how do you make the determination whether the VM program is appropriately funded?
In Part 2 we will begin with the generalities of what vegetation management professionals need from utility regulators, establish utility VM terms and show how the distinctions are necessary to direct funding to viable reliability improvement strategies.