New construction and new business: clearing a line before energization
A construction or new business pre-inspection answers to the utility's service requirements manual and its service extension tariff. PG&E's 2026 Greenbook conditions connection of a new line on the applicant providing 15 feet of clearance. Public Utilities Code 783 freezes that specification for 18 months from the application approval date.
An applicant wants 900 feet of new 12 kV overhead line up a private road to a well pump. The application is approved on June 1, 2026. The route runs under and beside fourteen existing valley oaks, two of them dead in the top, and it taps an existing three-phase line at a pole on the county road.
All of that is project work. The inputs are a drawing, an approval date, and somebody who wants power on before the irrigation season. A maintenance circuit hands the inspector an annual date and a history of prior vegetation points. This job supplies drawings instead, so the prescription has to stand on the design. The pre-inspection in front of it answers to a different set of documents, and the first thing that changes is what stops the work.
The documents below are PG&E's, because an applicant and its contractors can read them without a login. The service requirements manual is Utility Manual TD-7001M, "Electric & Gas Service Requirements", known in the field as the Greenbook, Rev 2026-04, published April 22, 2026 and effective June 22, 2026. The tariff is Electric Rule 16, "Service Extensions". One utility's manual binds that utility. The statute underneath the tariff reaches wider.
Public Utilities Code section 783 binds every California gas and electrical corporation, and the CPUC publishes the Rule 15 and Rule 16 tariffs of PG&E, Southern California Edison and San Diego Gas and Electric side by side.
Nothing gets connected until the clearance exists
Section 1.19 of the Greenbook states the gate in one sentence:
PG&E will not connect new lines to the existing distribution system until the applicant provides 15 feet of adequate clearance from the distribution lines and trees.
The clearance is a precondition of connection. A priority level and a correction date belong to plant already in service. This facility waits instead, and the delay lands on the applicant's schedule.
Two other instructions sit on the same obligation. Table 1-3, in section 1.11, tells applicants they "must clear the area of vegetation obstructions where PG&E facilities will be installed (i.e. overhead services) per Electric Rule 16." Rule 16 itself, at section D.1, puts the job in the applicant's column:
CLEAR ROUTE. Providing (or paying for) a route on any private property that is clear of obstructions which would inhibit the construction of either underground or overhead Service Extensions.
The pre-inspection has more leverage on this job than it does on a cycle circuit, because the design is still open. Section 1.19 carries a note the assessment can trigger:
PG&E may determine that the distribution line should be installed underground, or that trees should be removed, if the planned line extension does not meet or exceed the clearance requirements between existing trees and overhead electric lines.
That is a finding with two possible outcomes, and one of them rewrites the drawing. An assessment that reports fourteen oaks and recommends fourteen prunes has answered a narrower question than the one the manual asks.
A second clock runs after the cutting is done. Section 1.17 sets a shelf life on the permit rather than on the clearance:
PG&E will only energize or pressurize applicants within 6 months of approval from the AHJ. Anything beyond 6 months will require the applicant to obtain another approval from the AHJ.
On the 900-foot extension, an authority having jurisdiction that signs off on August 12, 2026 puts the last day to energize at February 12, 2027. Growth between the cut and the connection lands inside that window, and it is the applicant's to absorb.
The specification is frozen for eighteen months
Public Utilities Code section 783(g)(1) fixes the rulebook on the day the application is approved:
Only those construction and design specifications, standards, terms, and conditions that are applicable to a new extension-of-service project by an electrical or gas corporation on the date the application is approved for the extension of service apply to the new project for the 18 months following the approval date of the application.
Section 783(h)(1) defines the approval date as the earlier of the contract's effective date or the date the utility first invoices the customer. The section was last amended by Statutes of 2020, Chapter 370, Section 252, Senate Bill 1371, effective January 1, 2021. Rule 16 section A.2 restates the freeze in PG&E's own tariff and names section 783 while doing it.
Three things override the freeze under section 783(g)(2):
An order or decision of the Commission, or of any other state or federal agency with jurisdiction.
A work order PG&E issues to implement construction or design changes made necessary by a customer-driven scope of work modification.
A material-related design change PG&E identifies to remedy a construction material defect that could pose a risk to public safety.
Run the 900-foot extension through that. The application was approved June 1, 2026. Rev 2026-04 of the Greenbook was published April 22, 2026 and took effect June 22, 2026, three weeks after the approval date. Through December 1, 2027, that project is held to the edition in force on June 1, unless one of the three exceptions fires. A field guide quoting the current manual at that job is quoting the wrong document.
The statute is silent on vegetation, and that is worth saying plainly. Section 783(g) covers "construction and design specifications, standards, terms, and conditions," and the word vegetation appears nowhere in it. The Greenbook is PG&E's construction and design manual, and its vegetation clearance requirements are inside it at section 1.19, so the freeze reaches them on the face of the statute.
A vegetation management procedure such as TD-7102P-01 is a different kind of document, issued outside the extension-of-service process entirely. Whether a mid-project revision to one of those reaches a construction job is a contract question, and the answer belongs to the job owner in writing before the walk rather than in an invoice dispute afterward. On the cycle side the revision question has a cleaner answer.
Two clearances on the same span
The conductor owes one distance. The crew owes another. Section 1.19 of the Greenbook states the second one as a caution:
Because safety is the Company's highest priority, the California Occupational Safety and Health Administration (Cal/OSHA) requires that all vehicles, equipment, tools, and people maintain a minimum 10-foot distance from all high-voltage power lines.
The same section points applicants at Title 8 Article 37, "Provisions for Preventing Accidents Due to Proximity to Overhead Lines," and Article 38, "Line Clearance Tree Trimming Operations," and then draws a line around who may do the work:
Applicants or unqualified tree-trimming contractors should never attempt to trim or remove trees that are within 10 feet of high-voltage power lines (i.e., conductors).
Applicants must notify PG&E when work inside that distance turns out to be necessary. Which approach distance applies to a qualified line clearance tree trimmer, as against the applicant's landscaper, is set by table in 8 CCR 2950. The limits on an arborist doing something other than utility line clearance are their own subject.
At the tap pole on the county road, one valley oak limb sits 16 feet clear of the primary and 6 feet off the pole face. That limb satisfies every clearance in the rulebook. It still belongs on the prescription, because the pole has to be climbed, a crossarm has to be changed, and a bucket has to be set.
A construction pre-inspection writes two overlapping lists: what has to come out for the wire, and what has to come out for the work. The second list is particular to construction, because a routine cycle walk crosses a site where the plant already stands.
On a one-off project the prescription is a dimension
A cycle prescription is written as a duration. The inspector states how many annual cycles the cut has to hold, and the number of cycles is the prescription. That form needs a next cycle to be measured against.
A one-off project ends at energization. The line enters an annual work plan only once it is in service, so the prescription has to survive on its own terms. The Greenbook writes those terms in feet.
What the row governs | The distance the Greenbook gives the applicant | Section |
Electric underground cable, distribution and transmission | Plant vegetation a minimum of 5 feet from the cables | 1.19.1 |
Gas pipeline, distribution and transmission | Plant large trees at least 14 feet from the edge of the pipeline | 1.19.1 |
Overhead distribution pole | Only certain plant types up to 50 feet on either side of the pole | 1.19.2 |
Overhead transmission pole | Only certain plant types up to 60 feet on either side of the pole | 1.19.2 |
Any pole or structure | No vegetation within 10 feet, and none within 5 feet of a guy wire | 1.19.2 |
Connecting a new line to the existing distribution system | 15 feet of adequate clearance from the lines and trees | 1.19.2 |
Five of those six rows are planting rules rather than cutting rules. The only cutting dimension in the manual is the last one, and it is the row the connection turns on. That distinction matters on a construction job, because the applicant is usually doing both jobs on the same parcel in the same month.
Section 1.19 also reserves a remedy: applicants "must not plant trees under or adjacent to primary overhead distribution lines," and on discovering new plantings PG&E "reserves the right to remove those trees to protect its facilities." A landscape plan submitted with the drawings is part of what the pre-inspection reads.
The distances in the table are the applicant's design constraint. What clearance the conductor owes once the line is energized is a separate rule with a separate table, and the two numbers are not interchangeable.
The easement that makes the cut lawful is bought on this job
On a maintenance circuit the right to cut was settled decades ago. On a line extension it is being created, sometimes after the prescription is written. Section 1.20 of the Greenbook names the instrument and its dimensions:
For applicants constructing an overhead service, PG&E requires a 10 feet land easement and up to 36 feet overhang easement to allow PG&E the vegetation clearance it needs around the wires.
The overhang grant is the operative half for vegetation. Rule 16 section A.11 puts the same requirement in the tariff, at the level of clearances rather than feet:
CLEARANCES. Any necessary rights-of-way or easements for PG&E's facilities shall have provisions to maintain legal clearances from adjacent structures.
Rule 16 also requires that easements crossing other property be obtained without cost to PG&E, and section A.12 lists vegetation management among the purposes for which PG&E may enter an applicant's premises at any time. A recorded 10-foot strip with no overhang grant does not reach a limb 14 feet off centerline, whatever the prescription says. Right-of-way width and easement width are different numbers, and on new construction the second one is still a draft when the inspector walks.
The Commission has spoken once on the seam between the extension tariff and the clearance rule. Footnote 5 of Decision 97-10-056, issued October 22, 1997, reads:
To the extent that Electric Rule 16 (Service Extensions) of the various utilities' tariffs may contain provisions that conflict with Rule 35 as Adams and Sevier claim, we direct them to insure that the tariffs on file are revised, as necessary, to eliminate any such inconsistency.
A tariff cannot be read as relief from the clearance rule. Where a prime believes it has been handed a specification that produces less clearance than the rule requires, that footnote is the authority for sending the question up rather than cutting to the specification.
A new transmission line sets the width it will be held to
On transmission the construction document does something permanent. The NERC Glossary defines the right of way that FAC-003 measures against:
The corridor of land under a transmission line(s) needed to operate the line(s). The width of the corridor is established by engineering or construction standards as documented in either construction documents, pre-2007 vegetation maintenance records, or by the blowout standard in effect when the line was built. The ROW width in no case exceeds the applicable Transmission Owner's or applicable Generator Owner's legal rights but may be less based on the aforementioned criteria.
For a line built in 2026 there are no pre-2007 maintenance records and no historical blowout standard to fall back on. The construction document is the whole of the evidence. A 230 kV rebuild whose drawing shows a 125-foot cleared corridor has declared a 125-foot right of way, and every later inspection of that line is judged inside it.
The Guideline and Technical Basis of FAC-003-5 sets the outer bound on that width:
This standard does not require additional easement rights to be purchased to satisfy a minimum right of way width that did not exist prior to this standard becoming mandatory.
The federal standard will not buy land. A newly designated line does get time to prepare. The same supplemental material states that a line below 200 kV identified in a future Planning Year "will become subject to the standard on January 1 of the PY specified with an allowance of at least 12 months" for the owner to prepare. Which lines the standard reaches in the first place is decided outside vegetation management, and FAC-003-5 requirement by requirement is where the annual clock lives.
Whose trees these are, and which account they land in
On the 900-foot extension the fourteen oaks divide. Eleven of them stand along plant that does not exist yet. Three stand on the existing three-phase line at the tap pole. The Greenbook draws the money line at section 1.19:
During PG&E's normal tree-trimming schedule, contractors qualified to perform high-voltage line clearances will prune or remove trees at no cost to applicants to create a safe distance between the vegetation and high-voltage power lines.
The cycle pays for the cycle's trees. Rule 16 section D.1 makes the applicant pay for the route. So the three at the tap pole are program work and the eleven along the new route are a construction cost, and the pre-inspection record has to carry that split tree by tree or somebody reconstructs it later from memory.
Federal accounting turns that split into a requirement. Item 9 of Account 365, Overhead conductors and devices, in the FERC Uniform System of Accounts at 18 CFR Part 101, reads:
Tree trimming, initial cost including the cost of permits therefor.
Initial tree trimming is a component of the installed cost of the conductor. Electric Plant Instruction 7 handles the corridor the same way, and keeps it out of the land accounts:
Do not include in the accounts for land and land rights and rights-of-way costs incurred in connection with first clearing and grading of land and rights-of-way and the damage costs associated with the construction and installation of plant. Such costs shall be included in the appropriate plant accounts directly benefited.
The maintenance side is Account 593 for distribution and Account 571 for transmission. Both item lists carry "Trimming trees and clearing brush," and both draw the boundary explicitly in the next item: "Chemical treatment of right of way area when occurring subsequent to construction of line." Account 356, the transmission counterpart to 365, has an item list of seven entries and tree trimming is not one of them, so initial clearing on a transmission line reaches its plant account through Instruction 7 rather than through a named item.
The instruction that lands on the field record is Electric Plant Instruction 11:
Each utility shall record all construction and retirements of electric plant by means of work orders or job orders. Separate work orders may be opened for additions to and retirements of electric plant or the retirements may be included with the construction work order, provided, however, that all items relating to the retirements shall be kept separate from those relating to construction and provided, further, that any maintenance costs involved in the work shall likewise be segregated.
That last clause is the one a pre-inspector on a construction job has to be able to satisfy. Fourteen trees, one parcel, one afternoon, two accounts, and the maintenance costs inside the job have to be segregated from the construction costs.
A unit that carries a prescription and no work order cannot be segregated by anyone. Instruction 11 also requires Major utilities to keep records showing, for each plant account, the annual additions and retirements "classified so as to show the number and cost of the various record units or retirement units."
None of this is optional bookkeeping. FERC states that entities under its jurisdiction "are required to maintain their books and records in accordance with the Commission's Uniform System of Accounts," and it revised that system by Order No. 898 on June 29, 2023. Which system holds the entry, and which field carries the work order, is a contract question with four parts.
No rule requires a pre-construction vegetation inspection, and one used to
Nothing in the California or federal stack requires an assessment of a proposed construction area before the poles are set. The clearance itself is required. The assessment that establishes whether the drawing can deliver it comes from the contract.
An earlier edition of the Greenbook did require it. Section 4.10.1 of the 2017 edition, in a copy posted by the Santa Clara Valley Transportation Authority, carried a lettered item the current manual does not:
D. Applicants must ensure that a thorough inspection is made of proposed construction areas. Dead, dying, diseased, or hazard trees tall enough to fall into the proposed power lines must be removed.
That instruction is gone. The phrase "thorough inspection" appears nowhere in Rev 2026-04, and neither does any applicant-facing hazard tree requirement. The 2017 edition also pointed applicants at Public Resources Code section 4292 for clearing around poles. Rev 2026-04 mentions the Public Resources Code only in its acronym list, which leaves the pole firebreak requirement to be picked up from the statute rather than from the manual the applicant is reading.
The utility's own inspection procedure does not fill the gap either. Table 1 of Utility Procedure TD-7102P-01, Revision 4, effective November 15, 2025, offers two patrol types. Routine covers the annual cycle. Hazard covers a change of conditions, and its focus list ends with three words:
Facility construction changes.
New plant arrives in the vegetation program as a change of condition on an existing circuit, assessed against the next Routine annual inspection cycle. That is the procedure catching up with construction after the fact. The assessment in front of construction, the one that decides whether the drawing is buildable, sits in the contract and the scope of work.
So say who decides, in writing, before the walk. The utility decides the specification by issuing it and freezing it under section 783. The job owner decides whether a pre-construction assessment is in scope, what it covers, and which work order each finding lands on. A prime that treats a construction pre-inspection as a cycle pre-inspection with a different start date will produce a record nobody can bill and nobody can audit.
What the record has to name on a construction job
Everything below is traceable to a document quoted above, and none of it is on a routine cycle record.
The application approval date, because it fixes the specification edition for 18 months under Public Utilities Code section 783(g)(1).
The edition and revision of the service requirements manual the assessment was written to, named the way the document names itself.
The authority having jurisdiction approval date, because section 1.17 of the Greenbook gives the energization six months from it.
For each tree, whether it stands on existing plant or on plant being built, which decides whether it is cycle work or a construction cost.
For each tree, the work order it belongs to, so that Electric Plant Instruction 11 can be satisfied without reconstruction.
Whether the work falls inside 10 feet of an energized high-voltage conductor, and therefore whether the applicant's contractor may perform it at all.
The easement the prescription relies on, by recorded instrument, including whether an overhang grant exists.
On a transmission line, the cleared corridor width shown on the construction document, because that number becomes the right of way the line is held to for its life.
Any finding that the drawing cannot achieve the required clearance as designed, which section 1.19 turns into an undergrounding or removal decision rather than a prune.
Further reading
What a pre-inspection produces: the work order before the crew: The unit of work and the cycle-duration prescription a construction job cannot use.
Right-of-way width and easement width are not the same number: The recorded instrument a new-construction prescription rests on.
The vegetation system of record: working in the utility's, or bringing one: Where a capital entry and a maintenance entry have to be told apart.
Frequently asked questions
What gates a new service or line extension on vegetation grounds?
The connection itself. Section 1.19 of PG&E's Electric and Gas Service Requirements manual, Rev 2026-04, states that "PG&E will not connect new lines to the existing distribution system until the applicant provides 15 feet of adequate clearance from the distribution lines and trees." The same section adds that PG&E may instead require the line be installed underground, or require trees to be removed, if the planned extension does not meet the clearance requirements. There is no inspection cycle in that sentence and no correction window. The clearance exists before the connection or the connection waits.
Which revision of the specification does a construction pre-inspection work to?
The one in force on the day the application was approved, for 18 months. California Public Utilities Code section 783(g)(1) allows only those construction and design specifications, standards, terms, and conditions applicable on the approval date to apply "for the 18 months following the approval date of the application," and PG&E's Electric Rule 16 restates it. Three things override the freeze: a Commission or agency order, a work order for a customer-driven scope change, and a material-related design change addressing a construction material defect that could pose a public safety risk. The statute says specifications and standards without saying vegetation, so whether a mid-project revision of a vegetation procedure reaches the job is a contract question for the job owner.
Who pays to clear a tree on a new line extension?
It depends which line the tree is on. PG&E's manual states that during PG&E's normal tree-trimming schedule, qualified line clearance contractors "will prune or remove trees at no cost to applicants." Electric Rule 16 makes the applicant responsible for "providing (or paying for) a route on any private property that is clear of obstructions which would inhibit the construction" of the service extension. Trees along plant that does not exist yet are construction. Trees on the existing line being tapped are the cycle. The pre-inspection record has to carry that split tree by tree, because the FERC Uniform System of Accounts requires the maintenance costs inside a construction job to be segregated from the construction costs.
Is initial tree clearing on a new line a capital cost or a maintenance expense?
Capital, and the Uniform System of Accounts names it. Item 9 of FERC Account 365, Overhead conductors and devices, is "Tree trimming, initial cost including the cost of permits therefor." Electric Plant Instruction 7 keeps first clearing and grading of land and rights-of-way out of the land accounts and puts it in "the appropriate plant accounts directly benefited." The same crew cutting the same species on the same span after the line is in operation is Account 593 for distribution or Account 571 for transmission, whose item lists read "Trimming trees and clearing brush." Account 356, the transmission counterpart to 365, carries no initial tree trimming item at all.
Does any regulation require a vegetation inspection before new construction?
No California or federal rule requires one. PG&E's 2017 Greenbook did, at section 4.10.1: "Applicants must ensure that a thorough inspection is made of proposed construction areas." That instruction is absent from Rev 2026-04, which carries the clearance distances and the connection gate and no inspection step. PG&E's distribution inspection procedure TD-7102P-01, Revision 4, offers two patrol types, Routine and Hazard, and folds new plant into the Hazard patrol as a "Facility construction change." The pre-construction assessment is a contract deliverable, scoped by the job owner.
