Rework: what happens to a failed unit, and who carries it
A failed unit becomes rework on the day somebody assigns it, because assignment is what starts a clock. Published vegetation contracts make the second visit inside a cycle the contractor's cost. The deficiency stays with the utility, which answers for it under Public Utilities Code section 8386.3(b)(5)(C).
A quality control specialist walks a distribution span in Tier 3, measures a valley oak at 30 inches from the primary, ties pink and black flagging to mark the finding, and files a survey. That is the whole of what happened on the ground. A crew is still to be dispatched, a purchase order is still to be written, and the tree is still at 30 inches. Everything this page is about happens in the gap between that flagging and the saw.
Four documents, and not one of them says rework
The word is a field word. It is absent from the four published California documents that actually govern the return trip:
Document | What it calls the return trip |
SCE Vegetation Management Statement of Work, section 11.0 | work "found to be inadequately performed" that shall "be corrected by Contractor as soon as possible at Contractor's expense" |
SCE Statement of Work, section 4.1 | "pruning for a second time during an annual cycle" |
QC Findings reported "to the Execution Team to implement necessary corrective action(s)" | |
PG&E SW-0003, section 3.1 | "initiate a PTT record and create a Veg survey" |
The SCE document is the most useful of the four because it is a contract rather than a procedure, and because it is public.
It reached the record as TURN hearing exhibit TURN-T3-07 in CPUC proceeding A.19-08-013, attached to a data request response dated June 14, 2021, and described on its cover as the public amended version of the Statement of Work used for tree trimming contracts in 2020. Every clause quoted below is from that document and binds those parties. Read your own agreement before acting on any of it.
The practical consequence is small and immediate. A reader who searches a master services agreement for "rework" and comes up empty has learned only that the drafters used another word. The phrases that find the clause are "at Contractor's expense," "second time," "corrected," and "additional cost."
The first trip is billable, the second one is not
Section 4.1 of the SCE Statement of Work states the economics of the return trip in three sentences:
Exception Tree pruning shall be completed within thirty (30) days after assignment. Trees requiring pruning for a second time during an annual cycle will be pruned at no additional cost to Edison. Edison will pay the appropriate T&E rate for trees requiring pruning for the first time in an annual cycle or for tree removals.
Take the valley oak. Pruned under assignment on April 9, it is billable at the time and expense rate. Back in the same annual cycle on August 22, whether because it grew, because the first cut was short, or because the auditor found it, it is free to Edison.
Sections 3.1 and 3.2 say the same thing for routine distribution and transmission work in one line: "Trees requiring additional pruning in between assigned annual pruning cycles will be pruned at no additional cost to Edison." So the contractor sells a clearance that holds for a cycle rather than a set of cuts, and every visit after the first one inside that cycle is the cost of the warranty.
At Contractor's expense, and the list that defines inadequate
Section 11.0 is the clause an auditor's finding lands on:
Any work found during the post-routine quality control found to be inadequately performed (defined as not meeting ANSI-300, PRC 4292, PRC 4293, California Public Utility Commission General Order 95 Rules 35 and 37, all Edison contract specifications, all other applicable rules and regulations, or as deemed necessary by Edison) shall be corrected within a reasonable amount of time with consideration to the infraction be corrected by Contractor as soon as possible at Contractor's expense.
The parenthesis is the operative part, because it decides what a finding has to cite in order to trigger the clause. Seven items qualify:
ANSI A300, printed in the contract as "ANSI-300"
Public Resources Code section 4292
Public Resources Code section 4293
CPUC General Order 95 Rules 35 and 37
All Edison contract specifications
All other applicable rules and regulations
Anything "as deemed necessary by Edison"
The first five are gradable by a person with a tape and a copy of the specification. Which clauses of a standard can carry a defect is worked through separately, and it matters here: a should clause stays a recommendation even where the contract names the standard.
The last two open out, and the seventh is the one to notice. "As deemed necessary by Edison" gives the utility a residual category whose criteria are unpublished. That is a deliberate reservation of judgment, and it means conformance to the named standards settles most disputes and leaves a residue the utility decides. Where a finding rests on that clause alone, the record should say so and name the Edison representative who deemed it, because the basis for the charge is a person rather than a distance.
A reasonable amount of time is not a date
Section 11.0 leaves the interval open. It says the work shall be corrected "within a reasonable amount of time with consideration to the infraction," and "as soon as possible." An auditor asked to grade that is offering an opinion, and a contractor asked to schedule against it is guessing.
The same document does set a number, twice, and both times it hangs off assignment rather than off discovery. Section 6.0: "All tree pruning shall be completed within thirty (30) days after assignment." Section 4.1 repeats it for Exception Trees. So the assignment is the event that converts an ungradable obligation into a due date.
That gives the practical rule for a rework program. Track each finding by the date it was assigned rather than the date it was written, because assignment is where the only enforceable clock in the contract starts. Where the correction is remedying a GO 95 nonconformance or a Safety Hazard rather than a contract deficiency, Rule 18A's record standard and the auditable maintenance program behind it apply on top, and the company owns the timeline it published there.
Regrowth and a defect arrive on the same span
Two trees at 30 inches can be two different transactions. One was pruned correctly in April and grew. One was prescribed and skipped. Both are free to Edison under the clauses above, so the two arrive on the invoice as one line and on the trend as two.
PG&E's SW-0045, the August 14, 2024 transmission QA standard, builds that distinction into the finding type itself. Its Facility Protect Tree category splits three ways:
If the tree has been identified for work and is awaiting mitigation, the tree is an FPT - Identified for Work, Awaiting Mitigation finding type. If it is determined that the tree died or decayed after the most recent pre-inspection, the tree is an FPT - Declined After Most Recent PI finding type. If the tree died or decayed before the most recent pre-inspection, and the pre-inspector did not identify the tree for work, the tree is an FPT - Declined Before Most Recent PI finding type.
Three trees, all dead, all needing the same saw. The first is a queue problem, the second is biology, the third is a missed pre-inspection. Only the third says anything about how the program is performing.
An audit that reports one rework count across all three tells the utility how many trips are owed, and leaves the cause for somebody else to work out. Attributing the miss to the pre-inspector or the crew is the upstream half of this, and the finding type is where the attribution has to be recorded to survive.
The finding that never joins the queue
Some findings never reach the rework queue, because the condition outruns it.
SW-0003 handles this at the point of observation. When a QC specialist examines a Major Woody Stem and any of the listed conditions fails, section 3.1 opens a second record rather than a queue entry:
If the QC specialist identifies that any of the above conditions have not been met, then initiate a PTT record and create a Veg survey for the priority tree deficiency finding in the QC Map.
The priority tag record is a parallel track with its own procedure and its own response time, and the specialist opens it standing under the span. SW-0045 goes further on transmission, requiring the auditor to notify the local vegetation program manager and hold the site until relieved. How the two severities separate in the standards, and what the pass still leaves behind covers that boundary.
On the contract side, SCE section 5.3 carries a one-line note that does the same work for a refusal: "Any refusal location identified with a Priority 1 needs to be resolved immediately," with the SCE Senior Specialist notified of the condition and location. A refused tree at Priority 1 is not an incomplete location. It is an escalation.
The rule to build into a rework queue is that severity is read at the gate. A queue that accepts every finding and sorts later has already delayed the one finding that had to move first.
The return trip is a new mobilization, and the permission may have expired
The August visit to the valley oak is a different job from the April one. Four things have usually changed by the time the crew gets back:
The crew has moved. Production has taken it to another grid, often another district, and the trip is a remobilization rather than a stop on a route.
The tree has grown. A prune that was short in April can require a removal in August, which is different work under a different rate.
The customer contact is stale. SCE's Statement of Work requires a signed Removal Form from the property owner before a tree can be removed, so a prune that became a removal needs a signature that is still to be obtained.
The access record has to be rebuilt. Section 5.3 requires two documented attempts before a location can be recorded as No Contact, and confidential customer contact information is returned to the contractor within 72 hours of request.
The paperwork failure costs more than the trip. Section 5.3 attaches one consequence to a departure from those procedures: "the SCE SSP will reject the invoice submittal." A rework visit that was free to the utility anyway can still take a billable grid down with it when the documentation for the incomplete locations on the same submittal falls short.
Budget the return trip as a mobilization with its own notification cycle. A rework plan that assumes the crew can simply swing by is a plan that will report the same span open for three months.
Nobody re-audits your rework
The assumption worth killing early is that the next QA/QC pass will confirm the correction. Published scoping rules push the other way. PG&E's MID Quality 0002, revision 02, dated April 10, 2024, carries two exclusions. A pole is out of QC scope when it is "any pole that was already verified by QC within the current calendar year." A span is out of scope where "2nd Patrol, or next Routine inspection has begun."
Both exclusions are sensible sampling design. Together they mean a corrected unit is, if anything, less likely to be drawn than an untouched one. How the lot is defined and when a census replaces a sample is the place to decide whether reworked units form their own lot, which is the only way they get looked at on purpose.
Meanwhile the contract puts the first verification on the party that did the work. SCE section 11.0 requires the contractor to "conduct a physical patrol of all work performed by Contractor to assure absolute and complete Compliance," and to submit quality control performance data to Edison monthly. The utility's own review is permissive rather than mandatory in the same clause: "Edison may initiate an inspection of portions of Contractor's completed work."
So verification of a correction is a step somebody has to design. Three workable versions, in order of cost:
1. A closing photograph and a measured distance recorded against the original finding, taken by the crew, which proves the unit was visited and gives a number to dispute. 2. A desk review from the office by the party that wrote the finding, checking the closing evidence against what the finding said. 3. A field re-inspection of a defined share of corrected units, drawn as its own lot with its own acceptance number.
Whichever is chosen, the choice belongs in the QA plan and the contract, because all four documents here leave it to the parties.
When the rework is the program, not the span
One failed span is a correction. A grid that keeps generating them is a contract problem, and the SCE Statement of Work escalates in stages.
Section 6.1 comes first, and it starts with acceleration paid for by the party that fell behind:
Should Contractor fall behind the services schedule, as distributed in the latest published version of the Progress Sheet, in performance of the services, Contractor shall, at no additional cost to Edison, accelerate the services to meet the services schedule, including without limitation, overtime, additional personnel, or additional shifts.
The same section requires a written plan within ten days of an Edison request, detailing the steps taken or to be taken. Then comes the clause that puts the grid itself at risk:
Edison may direct another contractor to supplement Contractor's grids or require Contractor to surrender their grids. Edison's action to supplement and/or surrender the grids to another contractor does not relieve Contractor from responsibility of maintaining Compliance of said grids on the subsequent Exception Tree and Routine Maintenance activities.
Read the second sentence twice. Surrendering the grid leaves the obligation attached to it in place.
Section 15.0 runs the parallel commercial track through a monthly scorecard covering quality, schedule adherence, incidents and documentation timeliness. The scorecard "metrics will include control stages which may result in probation or withholding of future work," and the definitions page defines a Control Stage as a designation reflecting probation, suspension or termination. The monthly compliance meeting agenda in the same section names the input directly: QC and compliance, missed or modified prescriptions.
That is the full ladder, and every rung is in one document: free correction, acceleration at the contractor's cost, written recovery plan, supplemented or surrendered grids, control stage, termination. Which of those a QA finding is allowed to trigger, and who holds the pen is a separate question, and the answer belongs in writing before the first finding.
Who carries it when the state asks
The clauses above move money between two private parties. The compliance obligation stays where it was, and two provisions say so from opposite directions.
From inside the contract, section 11.0: "Edison's inspection of any portions of Contractor's Routine Maintenance or other services shall not relieve Contractor from its obligations to keep all of Edison's T&D System in Compliance at all times." Inspecting work leaves responsibility for it where it was.
From outside, the state addresses the utility and only the utility. GO 95 Rule 18A(1)(a) makes each company "responsible for taking appropriate corrective action to remedy Safety Hazards and GO 95 nonconformances posed by its facilities." And Public Utilities Code section 8386.3(b)(5)(C) sets out what happens to a deficiency that outlives its correction window:
Following the expiration of the time period for an electrical corporation to respond to and develop corrective actions for any deficiency identified in the initial audit, the office or the independent auditor shall issue an updated audit report to the electrical corporation identifying any outstanding deficiency in the electrical corporation's implementation or planned corrective actions relative to its vegetation management commitments in the electrical corporation's wildfire mitigation plan. The report shall be made publicly available.
Three facts follow from that sentence. The report is addressed to the electrical corporation, whatever the contract says about the contractor who left the span short. It names outstanding deficiencies in planned corrective actions as well as in implementation, so an unexecuted plan is itself a finding. And it is public, then folded into the performance review.
So the answer to who carries it depends on which question is being asked. The cost of the second trip is the contractor's under the clauses above. The deficiency is the utility's, every time, and the contract leaves it there.
What the rework record has to name
A correction with thin evidence behind it is a trip somebody took. The fields below are the ones that make it a record, and each one exists because something above requires it:
Field | Why it is there |
Original finding ID and the clause it cites | Section 11.0 charges only work that fails a named standard or a named Edison judgment |
Finding type, including which of the three FPT cases applies | Separates a queue problem, biology, and a missed pre-inspection |
Severity read at observation | Priority conditions leave the queue under SW-0003 section 3.1 and SCE section 5.3 |
Assignment date | The only clock in the contract runs thirty days from assignment |
Completion date and the measured condition at completion | Proves the unit was visited and gives a number to dispute |
Billability decision and who made it | Section 4.1 pays a first prune and not a second one |
Verification step performed, and by whom | No document here requires one, so the plan has to |
Access and permission documents refreshed for the return trip | Section 5.3 rejects the invoice submittal when they are missing |
SCE's own work management system field list already asks for a quality control start date, a quality control completion date and days past due. Those three are the skeleton. The rest is what turns a correction into something an evaluator can follow from the flagging on the tree to the day the span was right, and what the closure itself has to survive picks up from there.
Further reading
Was the unit closed properly?: The statuses a corrected unit can close into, and the three facts California asks for.
Who audits whom: The non-billable exception, and who decides what is payable.
Was the trim type correct?: Attributing the miss to the pre-inspector or the crew, which is what sets the cost.
Frequently asked questions
Does the word rework appear in utility vegetation contracts and QC standards?
Not in the four published California documents this page works from. Southern California Edison's Vegetation Management Statement of Work, PG&E's SW-0003, PG&E's MID Quality 0002 and PG&E's SW-0045 contain no instance of the word. The obligation is there under other names: work corrected at Contractor's expense, pruning for a second time during an annual cycle, and necessary corrective action. Searching your own agreement for rework and finding nothing does not mean the clause is absent.
Who pays for a second trip to a span that failed audit?
In the SCE Statement of Work, the contractor. Section 4.1 says Edison pays the time and expense rate for a tree pruned the first time in an annual cycle, and that trees requiring pruning for a second time during that cycle are pruned at no additional cost to Edison. Section 11.0 says work found to be inadequately performed is corrected by the contractor at the contractor's expense. Both clauses are specific to that agreement, so read your own.
How long does a contractor have to correct a failed span?
The SCE Statement of Work gives no number for correcting inadequate work. It says the work shall be corrected within a reasonable amount of time with consideration to the infraction, as soon as possible. The only hard pruning clock in the same document is thirty days after assignment. Assigning the correction is therefore the act that starts a clock anybody can audit.
Will the QA/QC sample come back and check the rework?
Usually not on its own. PG&E's MID Quality 0002 puts a pole already verified by quality control in the current calendar year out of scope, and puts a span out of scope once the second patrol or the next routine inspection has begun. Verification of the correction has to be designed in as its own step rather than assumed to fall out of the next sample.
Does a rework clause move the compliance obligation to the contractor?
No. GO 95 Rule 18A(1)(a) makes each company responsible for corrective action on its own facilities, and Public Utilities Code section 8386.3(b)(5)(C) puts any deficiency still outstanding after the correction window into a public updated audit report addressed to the electrical corporation. The contract allocates cost between two private parties. The state addresses the utility.
