BILL ANALYSIS                                                                                                                                                                                                    �



                                                                  AB 2556
                                                                  Page  1

          Date of Hearing:   April 23, 2012

                    ASSEMBLY COMMITTEE ON UTILITIES AND COMMERCE
                               Steven Bradford, Chair
                    AB 2556 (Allen) - As Amended:  March 29, 2012
           
          SUBJECT  :   Electrical lines: trimming of trees.

           SUMMARY  :   This bill would require each investor owned electric 
          utilities (IOU) and publicly owned electric utility (POU) to 
          avoid excessive tree trimming.    Specifically,  this bill  :  
           
           1)Requires the IOUs and POUs to avoid excessive tree trimming 
            that threatens the health of a tree, to make a good faith 
            effort to implement good forestry practices and vegetation 
            management practices, preserve the health of mountainous 
            lands, forest-covered lands, brush-covered lands, and protect 
            the aesthetic, cultural, and property value of the area. 

          2)Prohibit removal of trees unless specified circumstances exist 
            and require the utility to obtain the written confirmation by 
            an arborist of the need to remove a tree and to provide 
            specified notice prior to removal of a tree. 

          3)Requires an IOU or POU utility to provide notification to a 
            property owner, provide notification on its Internet Web site, 
            and publish legal notification prior to undertaking tree 
            trimming maintenance or brush removal.

           EXISTING LAW  

          1)State law requires:

             a)   A person who owns, leases, controls, operates, or 
               maintains a building or structure in, upon, or adjoining a 
               mountainous area, forest-covered lands, brush-covered 
               lands, grass-covered lands, or land that is covered with 
               flammable material maintain defensible space no greater 
               than 100 feet from each side of the structure.

             b)   Any person that owns, controls, operates, or maintains 
               any electrical transmission or distribution line upon any 
               mountainous land, or forest covered land, brush-covered 
               land, or grass-covered land shall maintain around and 
               adjacent to any pole or tower which supports a switch, 








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               fuse, transformer, lightning arrester, line junction, or 
               dead end or corner pole, a firebreak which consists of a 
               clearing of not less than 10 feet in each direction from 
               the outer circumference of such pole or tower.

             c)   Any person that owns, controls, operates, or maintains 
               any electrical transmission or distribution line upon any 
               mountainous land, or in forest-covered land, brush-covered 
               land, or grass-covered land to maintain a clearance of the 
               respective distances which are specified in this section in 
               all directions between all vegetation and all conductors 
               which are carrying electric current:

                      For any line which is operating at 2,400 or more 
                 volts, but less than 72,000 volts, four feet.
                     For any line which is operating at 72,000 or more 
                 volts, but less than 110,000 volts, six feet.
                     For any line which is operating at 110,000 or more 
                 volts, 10 feet.
                     In every case, such distance shall be sufficiently 
                 great to furnish the required clearance at any position 
                 of the wire, or conductor when the adjacent air 
                 temperature is 120 degrees Fahrenheit, or less. 
                     Dead trees, old decadent or rotten trees, trees 
                 weakened by decay or disease and trees or portions 
                 thereof that are leaning toward the line which may 
                 contact the line from the side or may fall on the line 
                 shall be felled, cut, or trimmed so as to remove such 
                 hazard.

             a)   Allows exemptions from these requirements if the person 
               does not have the legal right to maintain such clearing, 
               nor do such sections require any person to enter upon or to 
               damage property which is owned by any other person without 
               the consent of the owner of the property.

             b)   With some exceptions, state regulations require the 
               following  related to removal of flammable vegetation and 
               material within a firebreak surrounding poles or towers

                     At ground level - remove flammable materials, 
                 including but not limited to, ground litter, duff and 
                 dead or desiccated vegetation that will allow fire to 
                 spread, and;
                     From 0 - 2.4 m (0-8 feet) above ground level remove 








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                 flammable trash, debris or other materials, grass, 
                 herbaceous and brush vegetation. All limbs and foliage of 
                 living trees shall be removed up to a height of 2.4 m (8 
                 feet).
                     From 2.4 m (8 feet) to horizontal plane of highest 
                 point of conductor attachment remove dead, diseased or 
                 dying limbs and foliage from living sound trees and any 
                 dead, diseased or dying trees in their entirety.

             a)   PUC General Order 95 establishes minimum clearances 
               between vegetation and power lines and associated live 
               parts. The California Public Utilities Commission (PUC) 
               allows reasonable vegetation management practices for the 
               purposes of public safety or service reliability to obtain 
               greater clearances to ensure compliance until the next 
               scheduled maintenance. PUC guidelines allow each utility to 
               determine and apply additional appropriate clearances 
               beyond specified clearances which take into consideration 
               various factors, including: line operating voltage, length 
               of span, line sag, planned maintenance cycles, location of 
               vegetation within the span, species type, experience with 
               particular species, vegetation growth rate and 
               characteristics, vegetation management standards and best 
               practices, local climate, elevation, fire risk, and 
               vegetation trimming requirements that are applicable by 
               statute. Depending on line voltage, clearance requirements 
               are as low as 4 feet and as much as 20 feet.

          1)Federal regulation requires utilities to:
                 Trim trees and other vegetation growing in or adjacent 
               to the power line right-of-way to prevent power outages.
                 Regularly prune trees and other vegetation beyond the 
               minimum clearance distance to account for the fact that 
               they continuously grow and sway with the wind.
                 Prepare and implement a Vegetation Management Plan 
               consistent with local laws and regulations
                 Perform a Vegetation Inspection of 100% of its 
               applicable transmission lines at least once per calendar 
               year

           FISCAL EFFECT  :   Unknown

           COMMENTS  :   










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           1)Author's Statement  . In recent years, controversies have arisen 
            between communities and electrical utilities over what many 
            perceive to be unnecessary tree removals and excessive tree 
            trimming.  For example, in August of 2009, residents noticed 
            that two trees had been cut down in TJ Martin Park, a city 
            park in San Jose.  After some research, the residents learned 
            that Pacific Gas & Electric (PG&E) had removed the two trees 
            and had a plan to remove another 140 trees in both TJ Martin 
            and another San Jose park, Jeffrey Fontana Park.  The 140 
            trees represented about 30% of the trees in both parks.  After 
            months of protests and community meetings, PG&E agreed to 
            remove only thirteen trees.  However, the following year, PG&E 
            proposed to remove another fifty-five trees.  Again, after 
            many months of protests and community meetings, PG&E agreed to 
            cut only seven trees.



            More recently, a controversy has arisen in multiple areas 
            throughout Sonoma County where PG&E has decided to virtually 
            remove all trees underneath a 39-mile stretch of transmission 
            lines.  Since their original public statements, PG&E has 
            retracted and have informed residents that they are only doing 
            inventory and have yet to determine which trees will be 
            removed.  Residents in these communities estimate that PG&E 
            has scheduled at least 10,000 trees for removal though PG&E 
            has yet to verify the number despite requests from residents.  




            In every area where controversies have occurred, two common 
            themes have emerged: First, communities argue that the 
            electrical utility provided insufficient community 
            notification for scheduled tree removals.



            Second, communities argue that the electrical utility has 
            provided conflicting, inconsistent, or inadequate information 
            justifying the need for tree removals.

          2)Since vegetation growth is constant and always present, 
            unmanaged vegetation poses an increased outage risk, 








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            especially when transmission lines are operating at or near 
            their power rating. This can present a significant risk of 
            consecutive line failures thereby leading to cascading 
            outages. Once the first line fails the shift of the current to 
            the other lines and/or the increasing system loads will lead 
            to the second and subsequent line failures as contact to the 
            vegetation under those lines occurs.

          3)As a result of vegetation-induced outages affecting large 
            regions of the U.S., recent rules imposed on utilities require 
            vegetation management. Vegetation management will range from 
            pruning to removal, depending on fire risk assessment.


          4)PG&E's vegetation management program in a 40 mile corridor 
            underneath transmission lines have angered residents near or 
            adjacent to the corridor. The corridor stretches from The 
            Geysers over Oakmont and Bennett Valley to Petaluma. The 
            utility is working to perform its work prior to the start of 
            the fire season in that region.

          5)In October 2007, several severe wildfires swept through 
            Southern California. Massive evacuations, road closures and 
            power outages impacted many Californians; as thousands of 
            firefighters bravely fought the flames. People died as a 
            result of these fires, and thousands of families lost their 
            homes. Three of the fires in San Diego Gas & Electric's 
            (SDG&E) territory were linked to power lines. These were the 
            Guejito, Witch and Rice fires. The cause of the Rice fire was 
            attributed to an untrimmed sycamore tree limb broke and fell 
            onto SDG&E's 12 kV conductors during Santa Ana wind 
            conditions, starting a fire.

          6)SDG&E is estimating that uninsured wildfire costs could reach 
            $594 million.

          7)PG&E and its subcontractors have recently settled two lawsuits 
            over fires n Eldorado and Shasta-Trinity National Forest. The 
            settlement is reported to be nearly $30 million. One of the 
            two fires was caused by a Douglas Fir falling on a 
            transmission line.

          8)Vegetation management takes place over the large service areas 
            of a utility and requires taking into account weather, bird 
            breeding seasons, and scheduling vegetation inspection and 








                                                                  AB 2556
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            management on hundreds of thousands of trees along thousands 
            of miles of wires. The proposed notice requirements would 
            significantly impede the ability of utilities to comply with 
            federal vegetation management laws.

           9)The author may wish to clarify that nothing in this bill 
            prevents a utility from complying with federal or state law.

           10)The provision in the bill to 'avoid excessive tree trimming 
            that threatens the health of the tree' may conflict with 
            vegetation management requirements to take into consideration 
            the planned maintenance cycle.  The author may wish to modify 
            this provision to take into account the planned maintenance 
            cycle.  

          11)The provision in the bill to protect "aesthetic, cultural or 
            property value" is not clear nor does it provide a means by 
            which to determine this.   The author may wish to consider 
            removing this provision.  

          12)The provision that a utility provide property owners with 120 
            day notice prior to removing a tree is likely to interfere 
            with implementing required vegetation management plans within 
            seasonal constraints.  The author may wish to consider 
            requiring that utilities annually provide copies of their 
            vegetation management plans to cities and counties and make 
            those plans available on their internet web sites. In 
            addition, the author may wish to add a provision that the 
            utilities send a notification to property owners in the area 
            when the utility is working that locality to inform property 
            owners that the utility is conducting vegetation management in 
            their area and that trees that are unhealthy or close to power 
            lines may be removed. The utility should also include a point 
            of contact in case property owners would like to find out more 
            information or express concerns.  

            On Page 3, line 19 Avoid excessive tree trimming that 
            threatens the health of a tree,  unless necessary due to the 
            vegetation management maintenance cycle  .
            On Page 3, line 24, strike:  Protect the aesthetic, cultural, 
            and property value of the area.  
            On Page 5, beginning at line 7:
            In performing tree trimming maintenance or brush removal, each 
            electrical corporation and local publicly owned electric 
            utility shall do all of the following:








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            (a) Provide annually   written notification to the property 
            owner of the intent to trim trees or remove brush no less than 
            120 days prior to the scheduled tree trimming or brush removal  
             a copy of the company's vegetation management plan to the 
            city, county, city and county, or other entity of local 
            government.   If the owner of the property is a city, county, 
            city and county or other entity of local government, notice 
            shall be given to the city council, board of supervisors, or 
            other governing body. If the owner of the property is the 
            state, notice shall be given to the state entities that 
            administer and occupy the property and to the city council or 
            board of supervisors of the city, county, or city and county 
            where the state property is located.
            (b) Provide notification on the utility's Internet Web site no 
            less than 120 days prior to the scheduled tree trimming or 
            bush removal.   Publish the vegetation management plan on the 
            utility's Internet Web site.   
            (c) Publish legal notification of the scheduled tree trimming 
            or brush removal at least once in a newspaper of general 
            circulation serving the area of the proposed tree trimming or 
            brush removal not less than 120 days prior to the scheduled 
            tree trimming or brush removal.   Utilities shall provide a 
            notification to affected property owners in the locality when 
            the utility to provide information that the utility is 
            conducting vegetation management in their area and that trees 
            that are unhealthy or close to power lines may be removed. The 
            utility shall also include a point of contact in case property 
            owners would like to find out more information or express 
            concerns.  


           REGISTERED SUPPORT / OPPOSITION  :   

           Support 
           
          None on file.

           Opposition 
           
          Bear Valley Electric Service
          California Association of Small and Multi-jurisdictional 
          Utilities (CASMU)
          California Chamber of Commerce (CalChamber)
          California Licensed Foresters Association (CLFA) (unless 
          amended)








                                                                  AB 2556
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          California Pacific Electric Company
          Northern California Power Agency (NCPA)
          Pacific Gas and Electric Company (PG&E) (unless amended)
          Pacific Power
          San Diego Gas & Electric Company (SDG&E)
          Southern California Edison (SCE)
           
          Analysis Prepared by  :    Susan Kateley / U. & C. / (916) 
          319-2083