What an Energy Safety vegetation audit examines
Public Utilities Code section 8386.3(b)(5)(A) lets Energy Safety audit vegetation work performed by, or on behalf of, an electrical corporation after each performance year. The audit runs in three phases: an initial audit naming deficiencies, a corrective action plan due in 30 calendar days, and a published report. A commitment that is incomplete or insufficiently documented is deficient.
In 2024 PacifiCorp performed vegetation work at 8,017 locations in California and recorded debris management at 247 of them. The Office of Energy Infrastructure Safety published that pair of numbers on May 22, 2026, in a report available to anyone, and called the initiative deficient. Most of the sites with no debris record were probably clean when the crew drove away. Nothing in the record said so. The distance between work performed and work evidenced is what a vegetation management audit measures.
The power reaches work done on a utility's behalf
The audit is a statutory function, not a contractual one. Public Utilities Code section 8386.3(b)(5)(A) states it:
Following the end of the performance period, the office may, consistent with its authority pursuant to paragraph (1) of subdivision (b) of Section 15475 of the Government Code, conduct audits of the vegetation management work performed by, or on behalf of, the electrical corporation. The initial audit shall identify deficiencies in the electrical corporation's implementation of the vegetation management commitments in the wildfire mitigation plan.
One phrase there decides who is in scope: performed by, or on behalf of. A contractor's production is the utility's implementation for audit purposes, and the audit does not stop at the utility's own crews.
Two more provisions shape what follows. Section 8386.3(b)(5)(B) lets Energy Safety engage its own auditor, who "shall be a certified arborist" and operates under the direction of the office rather than the utility. Section 8386.3(b)(5)(C) requires the final report to be made publicly available and folded into Energy Safety's performance review of the utility. Government Code section 15475(b)(3) puts the same duty on the office from the other direction, requiring it to "develop a field audit and performance oversight program to assess wildfire mitigation plan implementation by each electrical corporation."
One wrinkle worth checking against any document that cites this statute. SB 254 amended section 8386.3 effective September 19, 2025 and moved the audit power. Energy Safety's own September 2024 guidelines cite the audit to section 8386.3(c)(5). The same power now sits at section 8386.3(b)(5). A contract or a scope of work that cites the old subdivision is citing a number that has moved.
Three phases, and one 30-day window in the middle
Section 8.1 of Energy Safety's December 2025 Performance Guidelines sets the sequence:
For any deficiencies identified during the audit, the electrical corporation must provide Energy Safety a Corrective Action Plan (CAP) within 30 calendar days of receipt of the initial audit, unless another date is specified by Energy Safety.
An initial audit names the deficiencies. The corrective action plan is the utility's answer, and it is the only place in the process where new evidence can be introduced. The audit report then records what remains outstanding, and is published.
The two most recent 2024 reports show the real elapsed time.
Step | Southern California Edison | PacifiCorp |
Initial audit issued | August 28, 2025, revised September 30, 2025 | December 19, 2025 |
Response due | October 16, 2025 | Not stated in the report |
Corrective action plan filed | October 24, 2025 | January 30, 2026 |
Supplemental documentation | Follow-up data request on quality control | April 22, 2026 |
Audit report published | March 27, 2026 | May 22, 2026 |
Read that table from a contractor's chair. The 30 days belongs to the utility, and it is consumed by the utility's own retrieval, review and drafting. A request that reaches a contracts or records team inside that window carries a deadline measured in days. Records that have to be reconstructed from crew memory will not arrive in time to change a finding.
The starting gun also moved. Under the September 2024 guidelines the audit began when the utility filed a notice that its vegetation management work was complete. The December 2025 guidelines tie it to reporting instead:
Energy Safety may begin the VM Audit after the electrical corporation has filed its final quarterly data report (QDR) for the performance period (the Q4 data report due on or before February 1 of the following year).
Utilities are still filing completion notices in the meantime, including a Liberty Utilities notice on March 4, 2026 and a Bear Valley notice on February 2, 2026 in the 2025 VM Audit docket. Both routes end in the same place.
The finding turns on documentation, not on fieldwork
This is the sentence to take away from the whole process. Energy Safety states the test identically in both 2024 reports:
Energy Safety determined that an initiative was "complete" if SCE provided sufficient data or supporting information demonstrating completion of all commitments (targets and/or statements) within that initiative. If any commitment was incomplete or insufficiently documented, Energy Safety determined that the initiative was "deficient."
Incomplete and insufficiently documented land in the same bucket. The audit cannot distinguish between them, and does not try.
Southern California Edison's 2024 wood and slash finding shows what that means when the work was contracted out. SCE committed in its wildfire mitigation plan to remove wood and material generated by its line clearing, structure brushing, hazard tree and dead and dying tree programs. Asked to demonstrate that it had, SCE produced excerpts from its contractors' statements of work requiring the removal. Energy Safety's response is in the published report:
While SCE provided excerpts from its contractors' statement of work (SOW) requiring removal of wood and slash following vegetation management activities, SCE did not provide documentation demonstrating that it verified the wood and slash was removed from work sites.
SCE then explained that its senior specialists and quality control inspectors do check for debris removal. Energy Safety accepted that as intent and not as evidence, because no record of those reviews or their outcomes was produced. SCE added that tracking every debris removal would be burdensome, since it would have to go back to each contractor, and those contractors might not have kept the records. That answer is itself the finding.
The correction was a data field. SCE added a mandatory wood and slash entry to its work management system in late 2024, measured 97 percent of records populated by field crews during 2025, added a second change, and reported 99.8 percent after it. A clause in a statement of work did not close the deficiency. A required entry on a crew's screen did.
Thirteen initiatives, and a verdict for each
The audit walks Section 8.2 of the utility's wildfire mitigation plan initiative by initiative. Each initiative carries commitments, and Energy Safety treats two kinds as equally binding: quantitative targets such as a number of inspections, and narrative but verifiable statements such as running a training program. Southern California Edison's 2024 result, initiative by initiative:
Initiative | Initial audit | Final report |
8.2.2 Vegetation Management Inspections | Complete | Complete |
8.2.3.1 Pole Clearing | Complete | Complete |
8.2.3.2 Wood and Slash Management | Deficient | Achieved Objective |
8.2.3.3 Clearance | Deficient | Achieved Objective |
8.2.3.4 Fall-In Mitigation | Deficient | Achieved Objective |
8.2.3.5 Substation Defensible Space | Complete | Complete |
8.2.3.6 High-Risk Species | Complete | Complete |
8.2.3.7 Fire Resilient Right-of-Ways | Complete | Complete |
8.2.3.8 Emergency Response of Vegetation Management | Complete | Complete |
8.2.4 Vegetation Management Enterprise System | Complete | Complete |
8.2.5 Quality Assurance and Quality Control | Deficient | Complete |
8.2.6 Open Work Orders | Deficient | Deficient |
8.2.7 Workforce Planning | Complete | Complete |
Three verdicts are in play. Complete means the documentation supports all work. Achieved Objective means deficiencies existed, the majority of work was done, and the corrective actions address the rest. Deficient survives the corrective action plan. Five initiatives were deficient on August 28, 2025, and one was still deficient on March 27, 2026.
The clearance finding under 8.2.3.3 is the one with a number on it. Energy Safety found that of 128,014 inspections where a mitigation was prescribed, SCE completed the mitigation on 118,576 trees and did not complete it on the remaining 9,438 trees, or 7 percent, in High Fire Risk Areas. Whether a given tree met its required clearance distance is a separate question from whether the prescription was closed out, and the audit asks the second one.
A pass rate below the committed pass rate is a deficiency
Quality control is its own initiative, and it is audited against the numbers the utility wrote into its own plan. Southern California Edison's plan said 100 percent of its hazard tree and dead and dying tree work would receive quality control to verify remediation. It produced records of 1,561 quality control inspections and a 98 percent pass rate. Energy Safety found the initiative deficient on that basis. The corrective action plan had to account for the gap:
22 trees not fully remediated
Six work sites with insufficient site cleanup
A quality control auditor sent back to those locations
Two sites that needed a third visit before they passed
Sampling design is audited the same way. SCE committed to quality control across 4,718 distribution circuit miles in its highest Tree Risk Index tranche and to a 99 percent confidence level at a 3 percent confidence interval across the lower tranches. It inspected 5,381 miles in the top tranche and 1,059 miles in the lower ones, against 1,402 planned. Energy Safety calculated the consequence rather than just noting the shortfall:
The reduction in sampling reduces the confidence in QA/QC sampling for these risk categories from a CL/CI of 99/3% to 99/3.5%.
Two things follow for anyone whose work is sampled. A pass rate is read against the commitment, not against an industry norm, so a program that promises 100 percent has no headroom. And sample counts are read as a statistical design, so miles inspected in the wrong tranche do not substitute cleanly for miles inspected in the right one. The same figures reappear in contractor scorecards with a commercial consequence attached.
Open work orders are where the crew's calendar gets read
Initiative 8.2.6 is the one Southern California Edison failed for 2024, and it is the most contractor-facing finding in either report. SCE's plan committed to completing work orders inside risk-based timeframes. Energy Safety compared the commitment to the records.
Priority | Commitment | Completed on time | Completed late |
P1, vegetation contact | 24 hours | 2,694 of 3,215 (83 percent) | 521, between 2 and 340 days |
P1, within 18 inches in HFRA | 72 hours | 2,236 of 2,452 (91 percent) | 216 |
P2, inside required clearance, beyond 18 inches | 30 days | 5,042 of 13,960 (36 percent) | 8,918 |
P2, routine line clearing | 90 days | 98,941 of 134,381 (74 percent) | 35,440 |
Energy Safety also found that SCE had not documented the 30-day revisits its plan promised for overdue P2 work orders, and wrote that SCE and its contractors "had record keeping deficiencies which suggest that SCE is not properly or promptly tracking inspections."
What SCE described in response is the machinery a contractor actually lives inside. It had already changed its contractor scope of work to include penalties for late work, after the same finding appeared in its 2023 audit, and had covered the change in contractor training in 2024 and 2025. It runs weekly backlog and aging reports classifying each work point by days between creation and completion, sends them to contractors, and expects updates back.
It maintains a SharePoint site "containing individual folders where each tree trimming contractor is expected to upload a weekly updated Excel spreadsheet indicating the status of their most recent re-inspections for the P2 work orders that have not yet been completed." It has since proposed a centralized Contractor Inspection Follow-Up Tracker as the single source of truth for those follow-ups.
Energy Safety then checked whether any of it worked. SCE's September 2025 review found 708 of 712 P1 24-hour conditions and 159 of 167 P1 72-hour conditions closed as expected. That improvement was credited. P2 performance had not moved the same way, and the initiative stayed deficient.
PacifiCorp's version of the same finding is blunter: it "did not complete 39% of work orders within six weeks of inspection, leaving an unknown level of ignition risk in its system." Its pole clearing finding lands on a number already traced through an approved plan. PacifiCorp inspected 1,384 poles and cleared 1,018 in Local Responsibility Area high fire threat district, against a target of 3,126. That same 3,126 figure is the baseline its 2026 through 2028 plan raises to 3,192.
What changed on December 12, 2025
Energy Safety adopted the 2025 Performance Guidelines on December 12, 2025, replacing the September 2024 Compliance Guidelines. The substance survived. Most of the vocabulary did not.
Old term | Current term |
Compliance Guidelines | Performance Guidelines |
Substantial Vegetation Management (SVM) audit | WMP Vegetation Management (VM) audit |
Notice of violation | Notice of nonperformance |
Notice of defect | Wildfire Safety Concern |
Violation, defect | Deficiency |
Electrical Corporation Annual Report on Compliance | Electrical Corporation Annual Implementation Report |
Independent Evaluator Annual Report on Compliance | Independent Evaluator Annual Implementation Report |
Compliance period | Implementation period |
One substantive change sits under the renaming. The September 2024 text read "Energy Safety annually conducts an audit." The current text reads "Energy Safety may audit," matching the permissive wording SB 254 put in the statute. An annual audit is no longer guaranteed for every utility in every year.
The renaming is incomplete in the places a filer touches. Energy Safety's docket for the 2024 cycle is still titled 2024 WMP Substantial Vegetation Management Audits, and PacifiCorp's corrective action plan inside it is titled "2024 SVM Audit Corrective Action Plan Rev.0," while the reports in the same docket are titled Vegetation Management Audit Reports. The destination moved too. Under the September 2024 guidelines an SVM corrective action plan was filed to the applicable SVM docket.
Table 3 of the current guidelines sends a VM audit corrective action plan by email to the Environmental Science Division inbox, copying the Audit Branch supervisor and the Audit Branch project manager. A document named to the wrong convention or sent to the wrong place is a filing problem, and the version of the guidelines a solicitation cites tells you which convention it was drafted against.
A notice of nonperformance can order records fixed
The audit is one instrument. Field inspection is another, and since December 2025 it produces notices of nonperformance in place of the notices of violation and notices of defect it produced before. Who enforces what covers that route, its clocks and where a finding goes next. Two features of it reach a records desk directly.
The first is scope. Energy Safety may direct corrective action that includes a requirement "to inspect, assess, repair, or remediate subject electrical corporation lines, equipment, records, or vegetation," and to report the results of it. Records sit in that list alongside vegetation. A defective dataset is a correctable condition in its own right.
The second is proof. The guidelines list what Energy Safety may require as evidence that a deficiency was corrected:
Before and after photographs demonstrating that the deficiency has been corrected
A corrected version of a dataset, record or document identified as deficient
Work orders or other records documenting the action taken, the date it was taken, and a point of contact who can answer questions about it
Every one of those three is generated in the field. The third one names a person.
Where this lands on a contract
An audit of a utility becomes a demand on a contractor through the evidence it accepts. Four consequences are worth writing into a bid or an operating plan.
Completion is proved by the record, so a field data entry that is blank, mistyped or chosen from the wrong dropdown is a completion that cannot be counted. SCE's clearance and debris findings both resolved into software changes that stop crews leaving fields empty.
Commitments stated in the plan are the yardstick, including pass rates and sample sizes. A 98 percent quality control pass rate was a deficiency because the plan said 100 percent, and what a scope of work obliges is where that number reaches a crew.
Closure timing is audited separately from the work itself. Late closure in a work management system was read as late mitigation until SCE demonstrated otherwise, and a P1 closed on paper 340 days after identification is a published finding.
Retention has to outlast the cycle. The 2024 audits were issued between August 2025 and December 2025 and reported in 2026, so records supporting a 2024 work point were being retrieved roughly two years after the crew left the site.
The audit reports themselves are the most useful reading here, because they show exactly which evidence was offered and which was rejected. They sit in the 2024 VM Audit docket and the 2023 SVM docket on Energy Safety's e-filing system, one per utility, appendices included.
Further reading
The three-year WMP cycle and what changes between filings: The filing calendar the audit sits at the end of, and which plan version governs.
How California utility Wildfire Mitigation Plans work under AB 1054: Where the commitments an audit tests against are written down.
What a utility safety certification requires: The quarterly statement whose veracity is a separate audit trigger.
Frequently asked questions
Who conducts an Energy Safety vegetation management audit?
Energy Safety's Environmental Science Division, or an independent auditor engaged by Energy Safety. Public Utilities Code section 8386.3(b)(5)(B) requires that engaged auditor to be a certified arborist and to operate under the direction of the office. The utility does not select this auditor, which is what separates the audit from the independent evaluator report the utility contracts for itself.
How long does a utility have to respond to an audit finding?
Thirty calendar days from receipt of the initial audit, unless Energy Safety specifies another date, under section 8.1 of the December 2025 Performance Guidelines. Southern California Edison received its 2024 audit on August 28, 2025, revised September 30, 2025, and filed its corrective action plan on October 24, 2025. A contractor asked to produce records inside that window has days, not weeks.
Is the audit report public?
Yes. Public Utilities Code section 8386.3(b)(5)(C) requires the updated audit report to be made publicly available, and the reports are posted to Energy Safety's e-filing dockets. The 2024 reports for Liberty Utilities, San Diego Gas and Electric, Southern California Edison, Pacific Gas and Electric and PacifiCorp were published between February 3 and May 22, 2026.
What makes an initiative deficient?
Either incomplete work or insufficient documentation of complete work. Energy Safety states the standard plainly in both 2024 reports: an initiative is complete if the utility provided sufficient data or supporting information demonstrating completion of all commitments, and deficient if any commitment was incomplete or insufficiently documented. Contract language requiring the work is not treated as evidence that the work happened.
Did the Compliance Guidelines change?
They were replaced. Energy Safety adopted the 2025 Performance Guidelines on December 12, 2025, renaming the Compliance Guidelines and renaming most of the instruments in them. The Substantial Vegetation Management audit became the WMP Vegetation Management audit, and notices of violation and notices of defect became notices of nonperformance.
