On October 18, 2012, FERC issued a Notice of Proposed Rulemaking (“NOPR”) proposing to approve the revised reliability standard FAC-003-002 regarding vegetation management submitted by the North American Electric Reliability Corporation (“NERC”). Generally, the NOPR states that the revised reliability standard FAC-003-002 would, among other things: (1) expand the applicability of the current standard; (2) add a new minimum annual vegetation inspection requirement; and (3) include a minimum vegetation clearance distance (“MVCD”) into the standard.
Notably, the NOPR proposes to expand the applicability of the current standard to include transmission lines that are operated below 200kV and are either elements of an Interconnection Reliability Operating Limit (“IROL”) or a Major Western Electric Coordinating Council (“WECC”) Transfer Path. Additionally, the proposed standard would require transmission owners to inspect 100 percent of their applicable transmission lines at least once a year with no more than an 18 month gap between inspections of the same lines. The proposed reliability standard would also require, for the first time, transmission owner to complete 100 percent of their annual vegetation work plan.
Under the proposed new MVCD requirement, transmission owners would be required to maintain a MVCD regardless of whether any vegetation encroachment results in a sustained outage. MVCD is defined as the “calculated minimum distance stated in feet to prevent flash-over between conductors and vegetation, for various altitudes and operating voltages.” The proposed reliability standard would also require transmission owners to maintain strategies or procedures to prevent encroachment into the MVCD, and immediately notify the appropriate control center if they observe vegetation that is likely to cause a fault.
NERC plans to enforce the proposed reliability standard by requiring transmission owners to (1) produce evidence that it prevented vegetation encroachment; (2) document that its strategies can prevent encroachment; and (3) document that the annual vegetation work plan was completed.
FERC stated in the NOPR that the proposed reliability standard will enhance reliability and improve upon the current reliability standard. However, FERC ordered NERC to revise its violation risk factor from “medium” to “high” for encroachment upon non-IROL and Major WECC Transfer Path elements. In addition to any comments in response to FERC’s proposed revision to this risk factor, FERC requested comments from NERC on how to ensure that the IROLs are properly designated, as well as comments regarding the enforceability of certain provisions of the standard.
Comments are due 60 days after publication in the Federal Register. A copy of the NOPR is available here.