Representing the utility at the property line: authority, limits, the record
A vegetation inspector on private property exercises the utility's easement, delegated by contract. PG&E's Utility Procedure TD-7102P-01, Revision 4, binds employees and subcontractors at any tier under one word, Personnel, and routes named decisions to a VM Representative, a supervisor or leadership. Public Utilities Code section 708 reaches only an electrical corporation's own employees.
A vegetation management inspector parks on a county road, walks up a gravel driveway, and stands under a 12 kV tap in somebody's back yard at 9:40 on a Tuesday. Almost everything in that moment belongs to somebody else. The right to be on the land is the utility's. The tablet entry goes into the utility's system of record under the utility's document number. Two of the calls they might make before lunch are reserved to a person whose name sits on a different page.
A program manager, a prime or an evaluator needs three answers about that inspector: what lets them stand there, what they are allowed to decide, and whose record they just made. The worked example here is PG&E Utility Procedure TD-7102P-01, "Vegetation Management Distribution Inspection," Revision 4, which took effect November 15, 2025.
PG&E filed it with the state inside its Base Wildfire Mitigation Plan for 2026 through 2028, and that filing is why a copy exists outside the company. A procedure like this one binds the utility that wrote it and nobody else. This one is unusually explicit about who the person in the yard is.
The right to be standing there belongs to the utility
The procedure defines the interest it is operating under, and the definition is doing more work than it looks:
Easement: An interest in land owned by another person or entity that gives the owner of the easement limited right to that land for a specific, defined purpose. It is a non-possessory, restricted right for a specific use or activity on the land of another that is less than ownership.
The land belongs to the property owner. The easement belongs to the utility. The inspector's employer holds a contract, and the inspector is standing there because the utility's right reaches that far and the utility sent them.
Two limits come with that. The first is purpose. An easement held for a distribution line supports work on that line, and the procedure's own field test draws the same boundary. A Strike Tree is one "which has the potential to impact PG&E facilities upon failure," and the definition then sets aside a tree that "leans or balances away from the facilities which makes contact unlikely."
Purpose and strike test converge on the same tree, which is why the easement question and the fall-in question are usually one question. The second limit is geometry, and it is set by an instrument filed with a county recorder long before the circuit was assigned. How far the corridor runs and which document sets the number is its own subject, and it is worth settling before the work is scoped rather than at a gate.
Where the land rights are missing entirely, California supplies a separate statutory path for clearance work, and that path has its own notice requirements and its own edges. It runs alongside the easement on its own terms.
One small merge in the definitions is worth noticing, because it can show up in a dispute. The procedure files "Right-of-Way (ROW)" with a single instruction: "See Easement definition." In the field those two words describe the same corridor. A title report treats them as two different things.
One word covers the employee and the fourth-tier subcontractor
Page 1 of the procedure names who it is written for:
VM Employees and Contract Partners (together, Personnel) that include but are not limited to:
The definitions then stretch the second half of that phrase as far as it will go:
Contract Partner: Company directly hired by PG&E to complete a specific scope of work or service. This term also applies to all subcontract partners, at any tier, which have been retained by a primary PG&E contract partner to provide a service for PG&E related project work.
Every instruction after that page lands on both. "The VMI must ATTEMPT to contact the customer/property owner directly" reads identically to a badged PG&E employee and to an inspector working for a subcontractor of a subcontractor. The far end of the chain gets the same sentence as the near end.
The enforcement sentence is the one a prime should read twice. Under Implementation Responsibilities the procedure says: "The leadership of the target audience is responsible for holding the target audience accountable to perform the procedure as written." The target audience includes contract partners. So the prime's own supervisors are the mechanism by which a PG&E document is enforced, on a document PG&E drafts and PG&E amends.
Whose document it is gets printed at the back. Revision 4's approver is Angela Sanford, Vice President, Vegetation Management, and its owner is Joe Echols, Senior Director, Vegetation Management Operations. It rescinded Revision 3, dated April 28, 2025. Every name on that page sits above the field. A prime that trained its inspectors to Revision 3 in the spring had 29 days between publication on October 17, 2025 and the effective date of November 15, 2025 to retrain them.
What the inspector decides, and what the procedure sends up
The limits on the inspector's authority are written as routing, scattered through the instructions. They are easier to see collected:
What the inspector meets | What the procedure requires | Who it goes to |
Pruning will not hold compliance for one Routine annual cycle | Prescribe Bi-Annual clearance "after PG&E VM Representative approval" | A PG&E VM Representative |
A removal outside the Appendix G criteria, including an R3 and above holding an annual cycle | "requires leadership approval on a case-by-case basis" | Leadership |
A mature Century plant that may bloom into facilities | "contact the local supervisor for guidance" | The local supervisor |
An abnormal field condition, on PG&E's facilities or a third party's | Report it under TD-7102P-09 | The supervisor |
A customer or property owner who interferes with the work | Follow TD-7102P-04 | The interference procedure |
Any situation where VM Personnel feels threatened by a third party | Get to a safe area, call 9-1-1 or notify the supervisor, and notify Corporate Security at (800) 691-0410 | Corporate Security, which opens a case |
Work inside a Caltrans or railroad right of way | Route to encroachment permitting under TD-7102P-31 | The permitting group |
Agency land, or a site with an environmental feature | Add Constraint data for environmental review | Environmental review |
The Century plant row is the tell. A blooming agave is a shape somebody had to write a table row for, and the row says to call the supervisor rather than to make a judgment. That is the default posture of the whole document: where the instruction runs out, so does the authority.
The rung above that one matters for a different reason. The prescription ladder that ends in Bi-Annual clearance is the inspector's own work until its last step, and at that step the pre-inspection stops producing a prescription and starts producing a request. A program tracking cycle compliance should know how many of its units sat in that state and for how long.
One naming trap sits inside this table. The procedure uses "the VM representative" in lower case for the person standing at the door, inside its definition of Interference, and "PG&E VM Representative" as a title for the role that approves a Bi-Annual prescription. The capitalization is the only thing separating them.
An offer to do the work lands in the interference definition
The procedure's definition of Interference covers three situations. Blocking access to the property is one. Getting into the work zone, creating an unsafe or hostile condition or threatening harm is another. The third is this:
Wants to Hire Own Contractor (HOC) or do work themselves.
A property owner offering to have their own arborist do the pruning is making a reasonable-sounding offer, and it lands in the same definition as somebody standing in the driveway refusing to move. The inspector classifies it. The routing runs to the TD-7102P-04 interference procedure, and it runs there the same way for all three situations.
That is an authority statement rather than a courtesy one. The utility's obligation stays with the utility whoever holds the saw, so accepting a substitute performer sits above the inspector's pay grade. What happens to the unit after that referral and what a refusal entitles the utility to do next are separate questions, and both of them start where the inspector's authority ends.
The card in the pocket is not the card in the statute
California has a statute about identifying a utility person at a customer's door. Public Utilities Code section 708, added by Statutes of 1987, Chapter 374, is one undivided paragraph:
The commission shall require every electrical, gas, and telephone corporation to prepare and issue to every employee who, in the course of his or her employment, has occasion to enter the premises of customers or subscribers of the corporation an identification card in a distinctive format having a photograph of the employee. The corporation shall require every employee to present the card upon requesting entry into any building or structure on the premises of a customer or subscriber.
Two things in that paragraph keep it away from the pre-inspector. The duty runs to the corporation and covers "every employee" of it, and a contract partner's inspector is employed by the contract partner. The presentation trigger is a request to enter "any building or structure on the premises." That trigger fires at a door and stays quiet in a back yard, a side lot or a hillside easement, even when an employee is the one holding the card.
The Commission has written the wider version of this rule, for a different industry. General Order 168, adopted May 27, 2004 in Decision 04-05-057, carries Rule 14(a) in almost the words of section 708, and then adds a definition section 708 does not have:
Employee: Includes, for purposes of these rules, employees, contract employees, contractor employees, agents, and carrier representatives of any and all types.
General Order 168 governs Commission-regulated telecommunications utilities. It reaches telephone carriers, and a prime citing it to an electric utility would be citing the wrong order. What it shows is that the Commission writes that definition when it intends to reach contractors, which is the reason to read section 708's silence as silence.
So the identification at the property line is a contract artifact. PG&E's Vegetation Management Competency Assessments program is where that lives, and it attaches to the individual rather than to the company:
PG&E requires individuals performing specific PG&E Vegetation Management work-related tasks to hold the applicable Vegetation Management Competency Assessments at the time of performing the work.
Contractors are inside it. Asked directly whether contractors need to be assessed, PG&E answers "Yes. Everyone performing Vegetation Management work will need to be assessed on some level," and the scope is set by what a person does alone: "Workers need to be assessed on the tasks they perform in the field unsupervised."
The card itself has three parties on it and no regulator. Industrial Training Services, a third-party vendor, manages the assessments. The contractor registers with ITS, provides a Certificate of Insurance showing at least $1,000,000 per occurrence in general liability, then adds its employees, uploads a photo and orders the card. The assessment behind it is valid for 2 years. The photograph on the credential in the inspector's pocket was uploaded by their employer, printed by a vendor and required by the utility. Section 708 addresses a fourth party, the corporation.
A prime reading that page for what ITS actually does should read the top of it rather than the glossary at the bottom, where a leftover entry from another program defines ITS as "A third-party vendor who manages gas qualification records for PG&E."
The entry is a company asset the moment it is made
The procedure's compliance block settles ownership in one sentence:
PG&E Data, Information, and Records are company assets that must be traceable, verifiable, accurate, and complete and can be retrieved upon request.
That applies to the vegetation point the inspector created at 9:40 on the Tuesday, before anybody has reviewed it and before the crew has seen it. The contractor's employee made it. The utility owns it.
The regulator then requires the person to be named in it. CPUC General Order 165 Section III.C sets the content standard for a distribution inspection record, and "the inspector" is one of the fields it names. What that standard reaches and what it leaves alone is worth reading in full, because the identity field is the part that survives the contract.
Three consequences follow for a prime, and all three are contract questions rather than field questions. An inspector's name travels with every unit they touched, for as long as the retention clock runs. A correction to a closed entry is an amendment on the utility's system rather than an edit on the contractor's, and amending a closed record has a shape.
And the data stays behind when the contract ends, which is a problem to solve while the contract is being written. Which retention clause names whom and where the vegetation point lives after the tablet closes are each their own subject.
What the code leaves open, and the four instruments that close it
California's rules address the utility and stop there. The qualification for a pre-inspector, the identity of the person who may enter under the utility's easement on its behalf, and the identification they carry in a yard are all settled somewhere else. Private documents fill the gap, four of them.
Instrument | What it settles | Who holds it |
The easement or right of way | Where the authority runs and what purpose it serves | The utility and the landowner |
The contract | That the utility's authority extends to this company and to its subcontractors at any tier | The utility and the prime |
The utility's procedure | What the person in the field must do and what they must send up | The utility |
The competency program | Which individuals may perform which tasks unsupervised | The utility, through a third-party administrator |
Every one of the four is held by the utility, or by the utility and a counterparty. The inspector arrives holding a copy of one of them. That is the answer to the authority question, and to the liability question behind it. An evaluator asking who is accountable for a bad call in a back yard is asking about a chain of documents, and the field is the last link in it.
The inspector walking back down that gravel driveway carries a tablet, a card ordered by their employer against the utility's requirement, and a purpose written into a deed that sits in a county recorder's office. Everything produced in the half hour they spent up there is the utility's, including the mistakes.
Common questions
Further reading
What a pre-inspection produces: the work order before the crew: The unit, the prescription ladder and the notification fields the inspector fills in.
The refusal workflow: What happens after a property owner says no, and who picks it up.
Right of way width against easement width: How far the corridor runs, and which instrument sets the number.
Frequently asked questions
Does a utility vegetation inspector have to be an employee of the utility?
No California rule says so. PG&E's Utility Procedure TD-7102P-01, Revision 4, names its target audience as 'VM Employees and Contract Partners (together, Personnel)' and defines Contract Partner to reach 'all subcontract partners, at any tier.' Every instruction in the procedure lands on a fourth-tier subcontractor's inspector exactly as it lands on a badged employee. The authority is delegated by contract, not held by the person.
Does California law require a vegetation inspector to show identification at the door?
Not in the yard. Public Utilities Code section 708 requires the Commission to make every electrical, gas and telephone corporation issue a photo identification card to 'every employee who, in the course of his or her employment, has occasion to enter the premises of customers or subscribers,' and to require that employee to present it 'upon requesting entry into any building or structure on the premises.' A contract partner's inspector is not the corporation's employee, and a back yard is not a building or structure. Identification at the property line is set by the utility's contractor requirements instead.
Which decisions can a pre-inspector not make alone?
The ones the procedure routes upward. In TD-7102P-01, Revision 4, a Bi-Annual clearance prescription follows 'PG&E VM Representative approval,' an exception to the Appendix G removal criteria 'requires leadership approval on a case-by-case basis,' a mature Century plant sends the inspector to the local supervisor for guidance, and a property owner who interferes goes to the TD-7102P-04 interference procedure.
Can a property owner hire their own arborist instead?
Under TD-7102P-01, Revision 4, that request is classified rather than negotiated. The procedure's definition of Interference covers a Customer or Property Owner who 'Wants to Hire Own Contractor (HOC) or do work themselves,' in the same list as physically blocking access and threatening the VM representative. The inspector routes it to the TD-7102P-04 interference procedure and has no authority to accept a substitute performer.
Whose record is the inspector's tablet entry?
The utility's, from the moment it is made. TD-7102P-01, Revision 4, states under its compliance requirement that 'PG&E Data, Information, and Records are company assets that must be traceable, verifiable, accurate, and complete and can be retrieved upon request.' CPUC General Order 165 Section III.C then requires an inspection record to specify the inspector by name. The individual's identity is a required field in a company asset.
