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Vegetation Management Along High-Voltage Transmission Lines

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Updated January 2013<br />

<strong>Vegetation</strong> <strong>Management</strong> <strong>Along</strong> <strong>High</strong>-<strong>Voltage</strong> <strong>Transmission</strong> <strong>Lines</strong><br />

Reasons for Doing this Work:<br />

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It is critical that we maintain the reliability of our electric transmission system.<br />

<strong>Transmission</strong> vegetation management work is required so we can keep the lights on for<br />

homes and businesses throughout the region.<br />

We understand this work can cause concern for some individual landowners, and we are<br />

sensitive to that. Our first priority has to be reliable electric service for millions of people<br />

in this region.<br />

We also have an obligation to keep costs reasonable, since vegetation management costs<br />

are paid by all customers in their electric bills.<br />

Our increased vegetation management activity is already paying dividends for customers<br />

in terms of maintaining a reliable electric system.<br />

PPL Electric Utilities is required to meet federal reliability standards on certain highvoltage<br />

lines.<br />

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We take very seriously our obligation to keep our part of the nation’s power grid reliable.<br />

We are always willing to meet with property owners to hear their concerns and discuss<br />

the work we need to do to keep our lines safe and reliable.<br />

Federal Regulators Oversee Electric Grid Reliability<br />

After the Northeast Blackout of 2003 – in which a tree contact led to power loss in a very wide<br />

region – the federal government adopted strict new mandatory reliability standards for certain<br />

high-voltage power lines.<br />

And in May 2012, the Federal Energy Regulatory Commission and the North American Electric<br />

Reliability Corporation recommended that utilities increase their efforts to remove trees from<br />

around transmission lines to help prevent future storm-related outages.<br />

Overview of Electric Grid <strong>Vegetation</strong> Work<br />

PPL Electric Utilities operates 4,400 miles of high-voltage electricity transmission lines in its 29-<br />

county service territory in central and eastern Pennsylvania. These lines fall into three main<br />

voltage classes:<br />

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230-kilovolt and 500-kilovolt lines — 1,351 miles<br />

115-kilovolt and 138-kilovolt lines — 299 miles<br />

69-kilovolt lines — 2,750 miles<br />

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230-Kilovolt and 500-Kilovolt <strong>Transmission</strong> <strong>Lines</strong><br />

These highest-voltage power lines are the most critical for grid reliability and are subject to strict<br />

federal reliability standards. Over the past three years, we completed vegetation work along these<br />

lines called Wire Zone-Border Zone, recognized as an industry best practice. Power lines<br />

maintained in this way have grasses under the wires in the Wire Zone area, and low-growing<br />

compatible trees and shrubs along the sides of the wires in the Border Zone area. This work is<br />

now complete.<br />

115-Kilovolt and 138-Kilovolt <strong>Transmission</strong> <strong>Lines</strong><br />

In 2012, PPL Electric Utilities completed work on these lines. We removed trees and other tall<br />

vegetation from the PPL right of way. In residential areas, wherever feasible, we did not remove<br />

lower-growing trees and shrubs that are compatible in areas of the right of way bordering the<br />

wires. Almost all of the lines in this voltage class are in the company’s Lehigh, Lancaster and<br />

Northeast regions.<br />

69-Kilovolt <strong>Transmission</strong> <strong>Lines</strong><br />

These are the lines that supply power to neighborhood substations. Many of them are closer to<br />

residences than our higher-voltage lines. Trees and other incompatible vegetation in the rights of<br />

way will be removed because they are a safety concern and a threat to reliability. This work will<br />

be ongoing for the next three years.<br />

PPL Electric Utilities’ Rights to Manage <strong>Vegetation</strong><br />

In all cases, PPL Electric Utilities has the right to do vegetation management work because of<br />

specific written agreements the company has with property owners. The company only does the<br />

work permitted by these written agreements.<br />

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Questions and Answers about <strong>Transmission</strong> Line <strong>Vegetation</strong> Maintenance<br />

How do property owners know you are coming to do work on the right of way<br />

For planned vegetation management activities, we have a multi-step communications process.<br />

First, we mail initial notices to property owners along the transmission line about 4-6<br />

weeks before work is to be done. This letter includes a phone number to call if residents<br />

have questions, and a link to our website that contains more information.<br />

We will schedule a personal meeting to discuss the work in advance with any property<br />

owner who wishes to ask questions or get more information.<br />

Next, our contractor for the job follows up with another notice and also attempts to<br />

personally contact the property owner.<br />

In addition, we will provide another notice just before the work takes place. This notice<br />

is provided when specific concerns exist, when the property owner has requested it, or<br />

when we have been unable to reach the property owner on previous attempts.<br />

Why remove trees Can’t you just trim the branches instead<br />

We recognize that some property owners may not want the trees removed under or near<br />

transmission lines. But we know that all customers want reliable electric service. We have to<br />

think of the millions of people served by the electric grid, and do the right thing to keep their<br />

lights on.<br />

We try very hard to strike a careful balance – improving reliability for customers by keeping<br />

trees away from power lines while at the same time being sensitive to landowner concerns about<br />

vegetation management.<br />

When I look at power lines, they don’t look like they are even close to touching nearby<br />

trees.<br />

That may be true at most times. But when electric use is high, power lines significantly sag<br />

because of the large amount of current flowing through them. Also, windy conditions can cause<br />

wires to swing out and touch trees that are too close to the sides of the lines. We have to take the<br />

maximum sag and the swinging of lines in the wind into account when determining whether<br />

there is adequate clearance between the wires and the vegetation. We also have to consider the<br />

fact that trees can grow closer to lines every year. Finally, we have to consider the fact that tall<br />

trees – even those just outside our rights of way – may fall into lines and cause a problem.<br />

Does PPL Electric Utilities use herbicides<br />

Yes. The judicious use of herbicides is an important part of our vegetation management program.<br />

We use herbicides to manage undesirable growth in the right of way. These herbicides are all<br />

EPA-approved and are applied by hand, or from trucks or using small ATVs. Herbicides are used<br />

on all transmission rights of way unless the easement agreement specifically prohibits it.<br />

We take necessary environmental precautions when using herbicides, some of which are the<br />

same as those commonly used by homeowners. Herbicides are applied as part of the initial<br />

treatment of the right of way and typically in a three-year cycle thereafter. Our goal for the area<br />

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under the wires is to promote the growth of low-growing vegetation such as grasses and<br />

eliminate taller growing vegetation. We achieve this goal by using herbicides that target woody<br />

and broad-leafed vegetation but do not harm grasses and similar desirable plants.<br />

You cut down trees in the right of way, but did not remove them. Why<br />

In all cases we will do our best to work with property owners to meet their needs regarding cut<br />

vegetation. Except in dense residential areas, we generally don’t remove or dispose of any<br />

vegetation from cutting on transmission line rights of way. Many property owners want the wood<br />

for lumber or firewood. In some areas, like hillsides, leaving cut vegetation protects against<br />

erosion. It also can serve as valuable wildlife habitat. In addition, our actions in the right of way<br />

are governed by the terms of the written easement agreement with the property owner.<br />

What repercussions are there if trees get too close to high-voltage transmission lines<br />

If vegetation gets too close to a high-voltage power line, it can cause outages of electric service<br />

for our customers and potentially others in adjacent utility service areas. Tree contacts also can<br />

cause serious safety issues for customers and our employees. In some cases, our company faces<br />

penalties of up to $1 million per day for allowing even a single tree to get within a specified<br />

distance of certain high-voltage transmission lines.<br />

Does this approach mean a farmer can’t grow crops under your lines What about<br />

Christmas tree farms or orchards<br />

Seasonal crops may be permitted near our transmission lines in certain circumstances. PPL<br />

Electric Utilities will work with commercial tree farms or orchards on a case-by-case basis to set<br />

a maximum height for permissible vegetation that does not pose a threat to the line.<br />

Does PPL Electric Utilities compensate people for trees they cut down<br />

When appropriate and based on our contractual obligations in the right of way agreement, we<br />

may compensate farmers for crop damage caused by power line construction and management<br />

operations.<br />

When appropriate and based on our contractual obligations, we also may compensate<br />

commercial tree or orchard operations for trees that need to be removed because of power line<br />

work, including Wire Zone-Border Zone work.<br />

Beyond that, we generally are not obligated to reimburse for vegetation lost to clearing<br />

operations because our easements typically provide that we have the right to perform such work.<br />

In all cases, we are governed by the terms of our written easement or other agreement with the<br />

property owner.<br />

What about a private homeowner who has fruit trees or other valuable plantings in the<br />

right of way Why are they different than a business<br />

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We’re sensitive to that concern. But keep in mind that our written right of way agreements with<br />

these property owners specifically permit us to cut incompatible trees and vegetation in the right<br />

of way to maintain the safe operation of our lines. Property owners get notified well in advance<br />

and can choose to transplant vegetation.<br />

What exactly are the federal requirements for transmission line management<br />

The Northeast Blackout in August 2003 affected more than 50 million electric customers in the<br />

northeastern United States and portions of Canada. Investigations of the causes of the blackout<br />

revealed that it was initiated by a contact between a tree and a transmission line in Ohio.<br />

The U.S. Congress responded to the blackout by enacting the Energy Policy Act of 2005, which,<br />

among other things, required the Federal Energy Regulatory Commission (FERC) to implement<br />

mandatory reliability standards for transmission lines.<br />

These reliability standards were developed by and are enforced by the North American Electric<br />

Reliability Corporation (NERC), subject to FERC’s regulatory supervision.<br />

NERC Standard FAC-003-1, <strong>Transmission</strong> <strong>Vegetation</strong> <strong>Management</strong> Program, was adopted in<br />

February 2006. Its purpose is:<br />

“To improve the reliability of the electric transmission systems by preventing outages<br />

from vegetation located on transmission rights-of-way (ROW) and minimizing outages from<br />

vegetation located adjacent to ROW, maintaining clearances between transmission lines and<br />

vegetation on and along transmission ROW, and reporting vegetation-related outages of the<br />

transmission systems to the respective Regional Reliability Organizations (RRO) and the North<br />

American Electric Reliability [Corporation] (NERC).”<br />

Standard FAC-003-1 requires transmission facility owners, such as PPL Electric Utilities, to<br />

adopt and keep current a formal transmission line vegetation management plan for its higher<br />

voltage (230 and 500 kV) transmission lines. The plan is required to include the transmission<br />

facility owner’s objectives, practices, procedures and work specifications. Further, the<br />

transmission vegetation management plan is required to specify clearances, or safety zones,<br />

between vegetation and transmission supply conductors within which no vegetation is permitted<br />

to grow. <strong>Transmission</strong> facility owners may be subject to fines of up to $1 million per day for<br />

violations of the Reliability Standards.<br />

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