Since the North American Electric Reliability Corporation (NERC) began enforcing the FAC-003-1 transmission vegetation management program standard in 2007, approximately 85 violations and US$5.1 million in associated fines have been levied to utilities. Interestingly, no known registered entity has been cited or fined twice for violating this standard. In most cases, the fines also included violations to other standards.
Utilities have spent at least $30 million to correct the root causes of violations to FAC-003-1. Approximately $153 million has been levied to utilities for all violations of NERC reliability standards. Since the adoption of FAC-003-1, the number of outages caused by trees growing into transmission conductors on the bulk electric system was reduced from 15 in 2007 to zero in 2011. This is a noteworthy accomplishment considering the standard affects more than 200,000 miles (321,869 km) of transmission rights-of-way (ROW).
This error-free record allows risk measurements to be transferred from reliability outcomes to improving the reliability process. The success of a regulation-driven utility vegetation management (UVM) program does not come without some carefully constructed customer and public relations.
Educating Customers
The complex mitigation of societal obstacles to a societal benefit — electric reliability — consumes a lot of time, and causes anxiety and sleepless nights for those whose jobs are at stake when the risk increases for a category-one electric interruption. There are people who do not want to part with trees that could interfere with power lines. There also are people who want interfering trees to be pruned or removed only when it is fully proven they are going to touch or fall on power lines.
Of the 347 million North Americans served by the grid, only a few thousand attempt to prevent necessary vegetation management on extra-high-voltage transmission ROW. But, it only takes one tree to have a substantial negative impact on the reliability of the grid. When a major event occurs and citizens are without lights or heat, or even a functioning society around them, it is unquestionably a bigger issue than the minor problem of whether to cut the tree or not.
The 2003 Northeast blackout and other storms that hit every year illustrate this fact, but memories can be short. The reality that trees precipitated the largest blackout in U.S. history is fading quickly from the general public's consciousness. Tens of millions of people may not know the blackout occurred or may have forgotten it happened. They may not fully appreciate that an unmanaged tree could be the penultimate event before a widespread outage.
When a utility attempts to prevent such an outage and comply with the objectives of federal and state rules for electric reliability, sometimes a disconnect develops between the utility, its customers and the public. To address this problem, the electric utility industry has found ways to educate people. Some of these strategies have been successful and some have not. For example, the probability statistics of tree failures, how quickly trees grow and the logistics of treating millions of trees every year are not common household knowledge.
Customer Communications
After a series of perceived UVM communication breakdowns, the New York State Public Service Commission issued an order in 2011 adopting recommendations designed to encourage best management practices for educating electric customers and the general public about electric utilities' practices. In the commission's new order, effective mid-2011, the overarching message is communication with the customer. Case 10-E-0155 enables “increased public access to information regarding utilities' ROW management programs.”
The new order contains eight requirements that compel utilities to address the concerns of the public, document their plans for preserving desirable vegetation and develop criteria for replanting vegetation when warranted and appropriate.
The commission responded to 200 written comments submitted during the proceeding by political office holders, activist groups, utilities and individual citizens, as well as hundreds of comments voiced at six public hearings. The resulting 10-E-0155 order requires “…establishing a direct line of communication between the public and the companies' vegetation management personnel for questions regarding ROW vegetation management work.”
Direct Line of Communication
A rule specifying customer communications for the vegetation management program is notable because so much communication by utilities is asynchronous, including call centers, door hangers, e-mails and websites.
How many utilities have a direct line of communication between customers and their vegetation management personnel? What other department in the utility publishes direct-line phone numbers in literature that goes to the majority of customers? Vegetation management programs have been one of the ways customers can communicate directly with utility representatives. This rule will likely further expand customer interaction with vegetation management personnel.
Historically, customer service training has been provided to the arborist performing work because the arborist has more person-to-person exposure to utility customers than any other utility personnel. The arborist represents the interests of the utility, and a portion of the arborist's responsibility is to ameliorate potentially hostile responses directed at the utility and the vegetation management program.
Customer Service Objectives
The new Case 10-E-0155 rule, so carefully crafted, may lessen the need to focus on customer satisfaction because the customer, the utility's vegetation management department and the commission will all share in the inconvenient fact that some vegetation management work has to be performed. This process may be a bit painful for some.
Utilities across the United States ranked their customer service objectives in a 2011 UVM benchmark survey by CN Utility Consulting. According to the survey, the most important objectives were customer satisfaction with the work on their property, customer understanding of the UVM program and customer support of the utility. The lower-ranking customer support of the UVM program indicates a dichotomy with the higher-ranking customer satisfaction with the work on their property.
Clearly, to reach these objectives as well as compliance with reliability goals, the UVM department has to find success in properly educating the customer but not by satisfying the customer with too much compromise. Positive personal relationships with customers are not the most important objective, since the likelihood of getting the maximum reliability risk reduction is oftentimes in opposition to satisfying customers' expectations.
As the CASE 10-E-0155 ruling suggests, improved customer communication and customer education are the best solutions to this problem.
Will Porter is director of consulting services and the principal project manager for benchmarking and research for CN Utility Consulting. He has nearly 20 years of experience in the UVM industry. Since joining CN Utility Consulting in 2008, he has directed many program and compliance reviews and special projects, and has performed detailed analysis of all existing UVM metrics. Porter and his staff also continually monitor and evaluate legal and regulatory changes, issues and trends related to UVM in North America and abroad.
